Statement and Purpose

North Shore Crisis Services Society respects and upholds an individual’s right to privacy and to the protection of his or her personal information. North Shore Crisis Services Society is committed to ensuring compliance with applicable privacy legislation including but not limited to Personal Information Protection Act (PIPA) and Freedom of Information and Protection of Privacy Act (FOIPPA).

This Privacy Policy outlines our policies and principles that we follow regarding the confidentiality and security of personal information that we collect in carrying out our responsibilities to residents, clients, employees, service contractors, volunteers, customers, and donors. We believe that ensuring the accuracy, confidentiality, and security of the personal information we hold is a moral as well as legal responsibility.

Scope

This policy applies to all of the programs within the North Shore Crisis Services Society, to all residents, clients, employees, volunteers, customers, and donors about whom North Shore Crisis Services Society gathers, uses, and discloses personal information. It outlines the principles and commitments we make to protect the privacy of personal information. This Privacy Policy provides guidelines for ensuring privacy, but it is not exhaustive with regard to the provisions of privacy laws in place in British Columbia. With regard to personal information, both North Shore Crisis Services Society and its residents, clients, employees, volunteers, customers and donors are subject to the privacy provisions of the Personal Information Protection Act of BC which details privacy rights and responsibilities as applicable.

Definitions

“North Shore Crisis Services Society” refers in a collective sense to all of the following programs:

• SAGE Transition House and Second Stage Housing Program

• HOPE’s Place Second Stage Housing Program

• Janet’s Place Second Stage Housing Program

• Good Stuff Connection Clothing Program and Thrift Store

Homeless Prevention Program

“Personal Information” means information about an “identifiable individual”. It includes any factual or subjective information, in any form, about an “identifiable individual including: age, weight, height, marital status, SIN, other ID numbers, medical records, income, purchases and spending habits, contents of a personnel file, employment history and education, race, ethnic origin and colour, home address, and telephone number. It does not include a job title, business address, or office telephone number of an employee.

Implementation

Accountability

North Shore Crisis Services Society is accountable for the personal resident, client, employee, volunteer, customer and donor information under its control. North Shore Crisis Services Society has appointed a Privacy Officer who is responsible for North Shore Crisis Services Society’s compliance with this Policy. The Privacy Officer may from time to time, delegate certain aspects of compliance with this policy to other individuals within North Shore Crisis Services Society.

Purposes for Collection, Use, and Disclosure

North Shore Crisis Services Society will communicate the purpose for which personal information is being collected either verbally or in writing.

North Shore Crisis Services Society collects and uses personal information about residents, clients, employees, volunteers, customers, and donors for the following purposes:

• To provide shelter and support services,

• To communicate with and manage our professional relationship with residents and clients,

• To provide referral services as requested by a resident, client, or employee,

• To determine the eligibility of residents and clients for participation in various public or private services including but not limited to: housing programs, government services, legal services, and other miscellaneous social services and educational programs

• To screen potential residents about residency in our shelter,

• To carry out the necessary duties and responsibilities we have to establish, manage, and terminate an employment relationship, and,

• To inform of the activities of North Shore Crisis Services Society, including programs, services, special events, funding needs, opportunities to volunteer or to give, open houses, and more, through periodic contacts (i.e. newsletters, annual reports, etc.)

• To meet regulatory requirements.

Consent to Collect, Use, and Disclose Personal Information

North Shore Crisis Services Society is committed to following the applicable privacy laws with regard to obtaining consent to collect, use, and disclose personal information of residents, clients, employees, volunteers, and donors. Consent under law may be expressed, implied, or not required as various circumstances dictate. North Shore Crisis Services Society will make reasonable efforts to ensure that residents, clients, employees, volunteers, customers or donors understand how their personal information will be used and disclosed.

Limiting Collection

North Shore Crisis Services Society will collect resident, client, employee, volunteer, and donor personal information only for the purposes identified above. North Shore Crisis Services Society will only use methods that are lawful and will not collect personal information indiscriminately.

Limiting Use, Disclosure, and Retention of Personal Information

North Shore Crisis Services Society will not use or disclose personal information for any purpose other than those for which it was collected, or as required by law.

Disclosure of Information to Third Parties

The only circumstance under which personal information may be disclosed to third parties is for the fulfillment of any purposes identified above, or as required by law. If personal information is disclosed to third parties for the fulfillment of any purposes identified above, North Shore Crisis Services Society will ensure that appropriate security undertakings, including but not limited to confidentiality clauses in contractual agreements and computer safeguards, are employed to protect the transfer and use of personal information. North Shore Crisis Services Society does not sell, trade, or rent information to third parties. Subject to applicable laws, any North Shore Crisis Services Society program, may, from time to time, transfer resident, client, employee, volunteer, or donor personal information between each other.

Accuracy

North Shore Crisis Services Society will make all reasonable efforts to ensure that personal information is as accurate, complete, and current as required for the purposes for which it was collected. In many cases, North Shore Crisis Services Society will rely on residents, clients, employees, volunteers, customers, and donors to ensure that the personal information provided is accurate, complete, and current, but may, as required by law or government agreements, submit the information provided to verification by a third party. If this is required, North Shore Crisis Services Society will provide notice to the resident, client, employee, volunteer, customer or donor regarding the verification of personal information provided.

North Shore Crisis Services Society will not routinely update personal information unless it is necessary to fulfill the purposes for which it was collected or if it is required to maintain the active status of a resident, client, employee, volunteer, customer or donor.

Safeguarding Personal Information

North Shore Crisis Services Society is committed to protecting personal information with appropriate security safeguards in order to prevent its loss, theft, unauthorized access, unauthorized disclosure, unauthorized duplication, unauthorized use, or unauthorized modification. Safeguards include physical, administrative, and electronic security measures. North Shore Crisis Services Society will use appropriate security measures when disposing of resident, client, employee, volunteer, customer or donor personal information.

The development of North Shore Crisis Services Society policies and procedures for the protection of personal information is an ongoing process. Changes in technology necessitate that North Shore Crisis Services Society continually develops, updates, and reviews information protection guidelines and controls to ensure ongoing information security.

Providing Access to Personal Information

All clients, employees, volunteers, and donors (past and present) have the right under law to access their own personal information under the control of North Shore Crisis Services Society. Upon receiving a request in writing, North Shore Crisis Services Society, within 30 business days will provide access to an individual’s personal information that North Shore Crisis Services Society has under its control in person. The written request is to be directed to the Executive Director of North Shore Crisis Services Society.

As provided by law, with the exception of employee personal information, North Shore Crisis Services Society reserves the right to charge a minimal fee for retrieval of personal information, the amount if any, to be communicated to the resident, client, ex-employee, volunteer, customer or donor prior to retrieval of the information.

In certain exceptional situations, North Shore Crisis Services Society may not be able to provide access to certain personal information that it holds about residents, clients, employees, volunteers, or donors. If access cannot be provided, North Shore Crisis Services Society will notify the individual, in writing, of the reasons for the refusal.

Concerns or Questions Regarding North Shore Crisis Services Society Compliance

Clients, employees, volunteers, customers, and donors (past and present) should direct questions or concerns regarding North Shore Crisis Services Society compliance with this Privacy Policy to the attention of the Privacy Officer:

Laura Reynolds, Executive Director
North Shore Crisis Services Society
200-147 West 16th Street
North Vancouver, BC, V7M 1T3

Tel: 604-987-0366, ext. 103
Fax: 604-987-1623
Email: lreynolds@nscss.net