OANHSS Privacy Policy
General Privacy Statement
The Ontario Association of Non-Profit Homes and Services for Seniors
(OANHSS) respects the privacy of our members and others who provide
personal information to us. Personal information provided to us or which
we learn about through our normal process of providing service to
members or others will only be used for the purpose we have identified
when obtaining the information. If at any time you wish to access,
modify or remove your personal information simply contact us by phone at
905-851-8821 and we will gladly accommodate your request.
Privacy Policy
a. Introduction
The Ontario Association of Non-Profit Homes and Services for Seniors
(OANHSS) is committed to protecting and safeguarding the privacy and
security of the personal information provided to us by members and
others. Our policy complies with the Personal Information Protection and
Electronic Documents Act (PIPEDA) and the 10 principles of the Canadian
Standards Association Model Code for the Protection of Personal
Information.
By becoming a member, requesting information, purchasing products or
services or registering for events or courses offered by OANHSS, an
individual is giving OANHSS permission to contact him or her by way of
the information provided.
During the course of servicing the needs of members and others we may
gather personal information. Anyone from whom we collect such
information should know that it will be carefully protected and used
only as necessary and as authorized. This policy explains why we may
need your personal information, how the confidentiality of this
information is protected, and how you can find out what information
concerning you is recorded.
b. Personal Information
Personal information is defined as any information that can be used
to distinguish, identify or contact a specific individual including
member and non-member information that pertains to the use of OANHSS
services, credit card information and purchase information whether
provided in writing, orally or by electronic means.
Personal information does not include business contact information
(with the exception of email addresses which are considered personal
information) and certain publicly available information, such as names,
addresses and telephone numbers as published in telephone directories
(i.e. information on a business card). Most of the information OANHSS
collects is not personal information.
Where an individual uses his or her home contact information as
business contact information as well, OANHSS considers that the contact
information provided is business contact information and is therefore
not subject to protection as personal information.
c. Privacy Practices
OANHSS adheres to the following privacy practices:
Personal information gathered by OANHSS is held in the
strictest confidence and carefully protected.
OANHSS collects data for specifically identified purposes.
Safeguards are in place to ensure that the information is not disclosed
or shared more widely than is necessary to achieve the purpose for which
it was gathered.
OANHSS staff are authorized to access personal information
based only on their need to deal with the information for the reason(s)
for which it was obtained.
No more than the minimum amount of personal information will be
collected in the course of providing any service.
Members and others have the right to opt out of providing
certain information recognizing that in doing so, the purpose may then
not be fulfilled or OANHSS may not be able to provide some services to
the member or non-member.
Members and others have the right to access their own
information. Procedures for accessing information are detailed under
Privacy Principles in
Section 9.1. Measures
are taken to ensure the integrity of this information is maintained and
to prevent its being lost or destroyed.
OANHSS staff receive appropriate training in the protection of
personal information.
OANHSS will advise all members of our Privacy Policy
at the time they apply for membership.
on the website in the form of an online privacy
statement.
at the time when major activities are undertaken to gather
information (e.g. annual membership directory).
OANHSS will advise non-members accessing our products and
services of our Privacy Policy
at the time they register, purchase or access a product or
service as appropriate
on the website in the form of an online privacy
statement
d. OANHSS Website
When members access the secure section of our website, a small text
file or “cookie” is sent from our web server to your browser
and stored on your computer. Cookies allow us to recognize you while you
are logged into the OANHSS website and expire when you close your
browser window.
The OANHSS website may also log Internet Provider (IP) addresses of
visitors. This information is used, in aggregate form, to provide
statistical measures about usage of our site. This allows us to
continually improve the content and design of our website.
The OANHSS website contains links to other websites owned and
operated by external parties. OANHSS is not responsible for the content
or privacy practices of such sites.
e. Privacy Principles
OANHSS is committed to the following ten privacy principles:
1. Accountability
1.1 - OANHSS is responsible for personal information under our
control and we have designated a Privacy Officer who is accountable for
OANHSS’ compliance with the Act. There are other individuals
within OANHSS who are designated with the responsibility for day to day
collection and management of personal information.
1.2 - OANHSS has policies and procedures in place to implement and
comply with this Privacy Policy, including procedures relating to the
collection, handling, storage and destruction of personal information.
OANHSS staff has also been provided with education and training to
protect personal information and to deal with complaints on privacy
issues.
1.3 - OANHSS is responsible for personal information transferred by
us to third parties, if any, for processing on our behalf. OANHSS uses
contractual means to provide an appropriate level of protection for such
transferred information. Third parties entering into a business
relationship with OANHSS are required to adhere to these privacy
principles, this privacy policy, the Act and any other applicable law
dealing with the protection of personal information.
2. Identifying Purposes
2.1 - OANHSS identifies the purposes for which personal information
is being collected at or before the time of such collection.
2.2 - Generally, OANHSS collects personal information for the
following purposes:
a. To process membership and maintain member and non-member
records.
b. To conduct surveys and facilitate data collection.
c. To facilitate commercial transactions.
d. To permit and assist OANHSS members to communicate with each
other and participate in OANHSS.
e. To provide members access to secure area of OANHSS site.
f. To register members and non-members for OANHSS events.
g. To develop, market and sell OANHSS products and services.
h. To communicate and provide information about OANHSS activities,
member benefits, programs, services and other opportunities.
i. To collect and verify academic and work experience as part of
the eligibility requirements of the Administrator Leadership Program.
j. For any other purposes as benefits members and the
Association.
2.3 - In the event that OANHSS is required to use, disclose or
collect personal information for a purpose that is not listed above and
in respect of which the member or non-member has not previously granted
his or her consent, the personal information will not be used or
disclosed without first identifying the new purpose and obtaining the
member or non-member’s consent, unless otherwise exempted from
doing so under the Act.
3. Consent
3.1 - OANHSS collects personal information by fair and lawful means
and obtains the individual’s consent for the collection, use or
disclosure of his or her personal information as required by the Act or
by law.
3.2 - The consent may be expressed, implied or given through an
authorized representative.
3.3 - A member or non-member may withdraw consent to use his or her
personal information at any time, subject to any legal or contractual
restrictions upon giving OANHSS reasonable notice. OANHSS will inform
individuals of the implications, if any, of withdrawing consent and how
to do so.
4. Limiting Collection
4.1 - OANHSS limits the collection of personal information to that
which is reasonably necessary for the identified purpose(s).
5. Limiting Use, Disclosure and
Retention
5.1 - OANHSS does not use or disclose personal information for
purposes other than those for which it was collected, except with the
consent of the individual, or as permitted or required by law.
5.2 - OANHSS retains personal information only as long as is
necessary for the fulfillment of those purposes or as required by
law.
5.3 - From time to time OANHSS may disclose personal information to a
person or organization involved directly or indirectly in supplying a
product or service to OANHSS members or non-members, including without
limitation, our endorsed program and service partners, those who conduct
research for OANHSS, data processors, and others responsible for
providing products and services requested or required by members. This
disclosure is only made to the extent the personal information is
required and is used only for purposes such as the efficient supply of
OANHSS services. Such disclosure requires the receiving person or entity
to keep the personal information confidential.
5.4 - OANHSS does not disclose credit card account information
provided by members or non-members except to the appropriate banking
institutions and/or clearinghouses in order to obtain debit
authorization and payment.
6. Accuracy
6.1 - OANHSS takes reasonable steps to keep personal information
accurate, complete and up to date as is necessary for the identified
purpose(s). Individuals are entitled to check on the accuracy of their
personal information and submit a correction request, if necessary.
OANHSS will rely exclusively on individuals in determining the
completeness, accuracy, and timeliness of his or her personal
information and will have no further obligation to seek independent
verification of any personal information supplied by the individual.
7. Safeguards
7.1 - OANHSS protects personal information from unauthorized access,
use and disclosure by establishing and maintaining appropriate security
safeguards. All safety and security measures are appropriate to the
sensitivity level of the information.
7.2 - OANHSS has implemented safeguards to protect against such risks
as loss or theft, unauthorized access, disclosure, copying, use,
modification or destruction of personal information. OANHSS staff is
made aware of the need to maintain the confidentiality of all personal
information.
8. Openness
8.1 - OANHSS makes information readily available about our policies
and practices related to the management of personal information of
member and non-members.
8.2 - OANHSS’ Privacy Policy is posted on our website and
informs members and non-members about the type of personal information
we may collect, what it is used for and to whom the information may be
disclosed.
9. Individual Access
9.1
- Upon request OANHSS provides members and non-members with access to
their personal information. Requests are to be directed to our Privacy
Officer:
Ontario Association
of Non-Profit Homes and Services for Seniors
7050 Weston Road, Suite 700
Woodbridge, ON L4L 8G8
P. 905-851-8821
F. 905-851-0744
9.2 - Upon request OANHSS will inform members and non-members whether
their personal information has been disclosed to any third parties.
9.3 - OANHSS will make every effort to respond to requests for access
to personal information within 30 days.
10. Challenging
Compliance
10.1 - Any questions, requests or complaints with respect to this
Privacy Policy or about our privacy practices may be directed to our
Privacy Officer (see 9.1 above for contact information).
f. Changes to Privacy
Policy
OANHSS regularly reviews our privacy practices for our various
activities and update our Privacy Policy. We recommend that you check
this policy periodically so that you are aware of any changes.
g. Further Information
For more information on privacy and your rights in regard to your
personal information visit the website of the Privacy Commissioner of
Canada at www.privcom.gc.ca.