Personal Information Privacy Statement
Christian Horizons is committed to protecting the privacy of the people it serves and their immediate family, its donors, volunteers, prayer partners, employees, directors, officers and any other persons about or from whom Christian Horizons collects personal information and complies with all applicable privacy laws. Christian Horizons embraces the principles of the Canadian Standards Association Model Code for the Protection of Personal Information to ensure that all personal information including personal health information as defined by the Personal Health Information Protection Act is properly collected, used and disclosed only for the purposes for which it is collected and that it is properly safeguarded while it is retained by Christian Horizons and is disposed of in a safe and timely manner when no longer required. As such Christian Horizons has developed a formal Policy which sets out how it will deal with the personal information it collects. Personal information collected by Christian Horizons may take on a commercial purpose if it is sold, rented, leased or otherwise used to facilitate the transfer of goods or services in exchange for money or other consideration. It is in these areas that personal information is collected, used and disclosed and is protected by privacy legislation.
In accordance with Christian Horizons Policy, no personal information collected by it will be used or disclosed to any other person for a commercial purpose without the consent of the individual. Except as otherwise required by the operation of law, every person has the right, in accordance with the policy provisions, at any time, to withdraw his or her consent.
Other persons or organizations that act for, or on behalf of, Christian Horizons are required to undertake compliance with the Policy and will be given restricted access to personal information solely to perform the services they may be retained to perform for Christian Horizons.
Christian Horizons has designated Barbara Wallace to be its Personal Information Compliance Officer. Any inquiry, request or concern related to privacy matters should be made in writing to Barbara Wallace, who may be contacted at:
Personal Information Compliance Officer
4278 King Street East
Kitchener, Ontario N2P 2G5
Personal Information – its Collection, Use and Disclosure
Inquiries and Complaints Procedure
To make an inquiry or issue a complaint regarding the handling of your personal information, please send a written request to the Personal Information Compliance Officer at the above address. This written request should include a consent to use your personal information for an investigation into the complaint. The Personal Information Compliance Officer of Christian Horizons will investigate the complaint or inquiry. If a complaint is found to be justified, appropriate measures will be taken. The Personal Information Compliance Officer will notify you of the findings of the investigation and corrective action taken, if any.
Information Correction Procedure
To correct any personal information on file with Christian Horizons, please send a written update of information to the Personal Information Compliance Officer, at the address noted above. You may be asked to give information that demonstrates the inaccuracy or incompleteness of personal information, and information will be amended as required.
Information Request Procedure
To access your personal information on file with Christian Horizons, please send a written request to the Personal Information Compliance Officer at the address above. You may be asked to give sufficient information to permit Christian Horizons to provide an account of your personal information. Christian Horizons will endeavor to provide you with access to the information within 30 days. If an extension is required, the Personal Information Compliance Officer will inform you in writing before the end of the first 30-day period of the need for an extension.
Christian Horizons, in accordance with applicable privacy laws, is committed to protecting the privacy of its supported individuals, employees, volunteers, directors and officers and any other persons about or from whom Christian Horizons collects personal information.
Christian Horizons embraces the principles of the Canadian Standards Association Model Code for the Protection of Personal Information to ensure that all personal information is properly collected, used only for the purposes for which it is collected and is disposed of in a safe and timely manner when no longer required.
Personal information in this policy means the information about an identifiable individual except the individual’s name, business address, business telephone number and business title. Personal information also includes personal health information as it is defined in the Personal Health Information Protection Act.
Christian Horizons is responsible for maintaining and protecting the personal information under its control. Christian Horizons has appointed a Personal Information Compliance Officer who is responsible to ensure that Christian Horizons complies with its privacy obligations in accordance with applicable privacy laws.
Christian Horizons collects and uses personal information for a variety of purposes including, but not limited to:
- Providing services, including care, to individuals supported by Christian Horizons;
- Providing care to immediate family members of individuals supported by Christian Horizons;
- Establishing and maintaining the appropriate level of care and interaction with corporate members, members of the religious order, volunteers and prayer partners;
- Managing payroll and benefits for staff;
- Staff performance evaluations;
- Establishing and maintaining an appropriate level of donor care and interaction;
- Providing information to other individuals who request to be placed on our mailing list;
- Conducting risk management activity; and
- Conducting quality improvement activities. Christian Horizons shall identify and explain the purposes for which it collects personal information to the person from whom the personal information is being collected, before or at the time the information is collected for any commercial purpose.
Consent will be obtained from the person whose personal information is collected, used and disclosed, unless obtaining the consent would be inappropriate or not required by law. Sometimes the person’s consent may be implied by the person’s conduct and relationship with Christian Horizons. When it is appropriate, written consent will be obtained.
Written consents will be kept on file for as long as the information is reasonably necessary. A person may withdraw his or her consent at any time, subject to legal or contractual restrictions and reasonable notice. The person will be informed of reasonably foreseeable implications of the withdrawal. Except as otherwise required by the operation of law, every person has the right, at any time, to withdraw his or her consent, in accordance with the policy provisions. The ability of Christian Horizons to provide services to individuals may be adversely affected by such withdrawal of consent.
Information collected will be limited to that required for the purpose or purposes identified by Christian Horizons. Christian Horizons is committed to collecting personal information in a fair, open and lawful manner.
Limiting Use, Disclosure and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the person or as required by law. All collected personal information will be destroyed, erased or made anonymous as soon as the purpose for which it was collected is fulfilled or completed.
Where personal health information is received from a health information custodian, Christian Horizons will use, disclose and retain that personal health information in accordance with any limitations, restrictions that have been imposed on or by the health information custodian who has provided the personal health information to Christian Horizons.
Personal information shall be maintained in as accurate, complete and up-to-date a form as necessary in order to fulfill the purposes for which it was collected.
Personal information will be protected by security safeguards that are appropriate to the sensitivity of the personal information. This safeguarding may include physical measures such as locked filing cabinets and premises security, organizational measures such as restricted access to files with personal information or technological measures such as security software.
Information regarding the personal information policy of Christian Horizons, as well as the personal information management, will be publicly available on its website. The information will include:
- Name and address of Personal Information Compliance Officer
- Means of gaining access to personal information held by the organization
- Copy of any information that explains the organization’s policies, standards or codes
Access to Personal Information
The general principle with respect to access to personal information is that each individual has the right to access their own personal information. Christian Horizons will provide access upon written request. The existence, use and disclosure of the personal information will be granted within a reasonable amount of time. Any inaccuracy or incompleteness of personal information will be amended as required.
There may be some instances where access to personal information will not be granted as a result of legal requirements.
Where access to the personal health information is requested, Christian Horizons will advise the health information custodian who provided the information of the request so that the health information custodian can deal directly with the individual requesting access to his/her personal health information.
Complaints or inquiries about the collection, use, disclosure or retention of personal information and Christian Horizons compliance with these ten principles should be directed to the Personal Information Compliance Officer. The Personal Information Compliance Officer will investigate complaints and ensure appropriate measures are taken.