Personal information is defined under PIPEDA as any information that is identifiable or directly attributable to an individual. It does not cover information about an individual that is available from a public source, such as a telephone directory or legal directory. It also does not cover aggregated data, used for statistical and reporting purposes, from which data a client’s identity cannot be determined.
Purposes for Collecting Personal Information
SJHOL collects personal information for the following limited purposes:
- to establish and maintain a client database for record keeping and statistical purposes, for fundraising purposes and to respond to legitimate inquiries from the public; and
- to establish and maintain mailing lists for newsletters, notification of workshops, seminars or services and updates that HOL believes might be informative or of benefit to its’ clients.
Consent to the Collection, Use, and Disclosure of Personal Information
When an individual uses the services of SJHOL, he or she will be deemed to consent to SJHOL collecting, using and disclosing personal information obtained for the purposes listed above unless he or she explicitly advises otherwise in writing.
SJHOL does not sell, barter, or lease personal information it obtains from its clients to third parties (i.e. SJHOL does not provide its mailing list to businesses).
Under PIPEDA and other Federal and Provincial Legislation, HOL may disclose personal information without a client’s consent to:
- government or legal enforcement agencies if SJHOL determines that the client has provided incorrect information for fraudulent or illegal purposes;
- legal enforcement agency if SJHOL determines that there is imminent risk of death or serious bodily harm, including psychological harm, to an identifiable person or group of
- disclosure to a third party individual or organization if so ordered by a Court or Tribunal of competent jurisdiction.
Accuracy of a Client’s Personal Information
SJHOL endeavours to ensure that all personal information provided by the client and/or his or her family, and in its possession, is accurate, current and as complete as is necessary for the
purposes for which the personal information was collected, used and maintained. Upon notification by a client or representative that the personal information requires correction or updating, SJHOL will make the necessary amendments to the client’s file where applicable.
Retention of the Client’s Personal Information
If the person is no longer a client of SJHOL, his or her personal information will continue to be updated and maintained unless the person requests otherwise.
SJHOL has implemented a number of physical, organizational and technological safeguards appropriate to the sensitivity of the client’s personal information, including but not limited to:
- Clients’ files are maintained electronically and in paper form, located in areas where access is restricted to authorized personnel.
- SJHOL utilizes the most current firewall, virus protection and other technological safeguards to protect personal information that is retained on the computer network. SJHOL has developed and implemented safe Internet and email use protocols for its staff, volunteers and contracted employees to reduce the risk of inadvertent disclosure as a result of Internet-sourced viruses.
Regarding electronic transmission of personal information (i.e. email), there is no method of transmitting or storing data that is completely secure. SJHOL uses all available technological security in the transmission of the client’s personal information. Notwithstanding these technological safeguards, all Internet transmissions are susceptible to possible loss, misrouting, interception and misuse.
SJHOL makes available its privacy policies and procedures regarding the handling of personal information that it collects on the Internet website at www.sjhospicelondon.com. As well, any inquiries regarding personal information management practises may be directed to the Executive Director of SJHOL.
Under PIPEDA, an individual is entitled to access to the personal information held about him/her with the following exceptions as permitted under the Federal Privacy Legislation:
- SJHOL will deny access if the individual seeking access fails to produce sufficient identification to verify that they are the individual about whose personal information access is being sought;
- No access will be granted to personal information that is not about the individual seeking access;
- No access will be granted to information that is part of a criminal investigation;
- No access will be granted where such access would harm or interfere with law enforcement activities and other investigative functions of a body authorized by statute to perform such functions;
- No access will be granted to information where such access might threaten the life, safety and security, including psychological safety, of the individual seeking access;
- No access will be granted to the individual who is a minor or mentally incompetent.
SJHOL reserves the right to refuse access that it believes is repetitious, frivolous, or vexatious.
Upon receiving a request for access in writing, SJHOL will endeavour to have the information available to the individual seeking access within 60 days of verification of the individual’s identity.
The individual entitled to access may challenge the completeness of his or her personal information under SJHOL’s care and control. Upon successful demonstration that there is an error in the personal information held by SJHOL, SJHOL will amend the information where appropriate.
The Executive Director of SJHOL will investigate all concerns or complaints respecting the handling of personal information under the control of SJHOL that are received in writing. As promptly as possible, the Executive Director will report to the individual the results of the investigation and, where the complaint is found to be justified, steps will be taken to resolve the matter.
If the individual is dissatisfied with the report provided by the Executive Director, or feels that the corrective action taken by SJHOL is insufficient, the individual may direct a complaint to the President of the Board of Directors of SJHOL or the Federal Privacy Commissioner in writing.
If a question arises regarding access to your personal information held by SJHOL, or there is a concern about the manner in which SJHOL collects, uses, retains and discloses your personal information as a client of SJHOL, please contact:
Julie Johnston, Executive Director
St. Joseph’s-Hospice of London
485 Windermere Road, 3rd Floor
P.O. Box 1449, Station B
London, ON N6A 5M2