Privacy

KWCS Privacy Policy

POLICY

KW Counselling Services recognizes the sensitivity of an individual’s personal information. KW Counselling Services is committed to protecting the privacy and personal information of its clients, members, employees, volunteers, donors, and other stakeholders as required by Canadian Privacy Legislation. KW Counselling Services takes every step possible to maintain the confidentiality of personal information.

This Privacy Policy applies to KW Counselling Services’ Board of Directors, members, volunteers, agents, employees, stakeholders, and contracted employees. As well, KW Counselling Services ensures that all third parties sign confidentiality agreements prior to any transfer of an individuals’ personal information (except under circumstances listed below).

Definitions

“Personal Information” is defined as any information that can be used to distinguish, identify or contact a specific individual. This information includes, without limitation, information relating to identity, nationality, age, gender, address, telephone number, e-mail address, Social Insurance Number, date of birth, marital status, education, employment/health/social history, assets, liabilities, payment records, credit records, loan records, income and information relating to financial transactions, as well as certain personal opinions or views of an Individual.

PROCEDURE

Collection of Personal Information

Clients

KW Counselling Services collects personal information in a variety of ways and for a variety of purposes, including when services are provided to individuals and when fundraising activities are conducted. Data is only collected as required for a specific purpose.

Client information typically collected includes:

Name, date of birth, address, e-mail address, telephone number and other contact information
Income, employment information, personal, medical and social history
Information or presenting problems, medical information; and
Donation/fundraising details or history of giving.

Information will only be collected indirectly, that is, from other family members or professionals, if necessary to the provision of services, with an individual’s consent or if permitted/required to do so by law.

Donors/Agency Members/Event Registrants

KW Counselling Services collects personal information in order to process donations, track donation history, conduct fundraising activities, process event registrations and track event attendance. Data is only collected as required for a specific purpose.

The personal information typically collected includes:

Name, date of birth, address, e-mail address, telephone number and other contact information
Donation/fundraising details and/or history of giving
Event registration details and/or history of event attendance

KW Counselling Services operates websites that provide information about KW Counselling Services and our services. Through these websites, individuals can request more information about the agency, provide feedback and make other comments and inquiries. Unless an individual chooses to provide personal information to us (e-newsletter subscription, e-mail messages, online event registration, photos, or on-line donations) no identifying information is collected. Our Internet servers may passively and automatically collect certain information about website traffic, which may be linked to a visitor's Internet Protocol (IP) address (a unique Internet "address" assigned to all Internet users by their Internet Service Providers). Servers may record statistical information—such as visitors' IP addresses, types of operating systems, time and duration of visit, pages requested—and identify categories of visitors by items such as domains and browser types. These statistics are gathered and used collectively; no individuals are identified.

Consent

There are various ways for individuals to give their consent to KW Counselling Services to collect, use and disclose personal information. Types of consent include:

"Express consent" means the individual signs a consent form, or other forms containing personal information, authorizing KW Counselling Services to collect, use, and disclose the individual's personal information for the purposes set out in the application and/or forms.
"Implied Consent" means the organization may assume that the individual consents to the information being used, retained and disclosed for the original purposes, unless notified by the individual.

An individual’s express, written consent will be obtained before or at the time of collecting personal information. An individual’s implied consent is assumed for the collection of personal information if an individual verbally requests service before express consent can be obtained (i.e. a telephone intake). The purposes for the collection, use, or disclosure of and who will have access to the personal information will be provided to the individual at the time of seeking consent. Once consent is obtained from the individual to use information for those purposes, KW Counselling Services has the individual's implied consent to collect or receive any supplementary information that is necessary to fulfill the same purposes. Express consent will also be obtained if, or when, a new use is identified.

Consent may be given by an individual’s authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing personal information it is assumed that individuals consent to collection, use and disclosure of that information for the purposes identified in this privacy statement or otherwise at the time of collection.

Withdrawal of Consent

Individuals may withdraw consent to collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice.

Note that if individuals withdraw consent to certain uses of personal information, KW Counselling Services may no longer be able to provide certain products and services.

Use of Personal Information

KW Counselling Services generally uses personal information for the following purposes:

Providing services or information to clients;
Providing information to third parties for which clients have consented;
Responding to questions and comments with respect to our services;
Contacting clients to evaluate services provided;
Contacting individuals with respect to fundraising activities;
Providing receipts for services or donations;
Providing information about KW Counselling Services activities;
Providing the public and funders information about the Board of Directors.

Personal Information may also be used for quality assurance, evaluation, accreditation, auditing and licensing processes. Individuals accessing personal information for these purposes are required to sign confidentiality agreements. This Privacy Policy does not cover statistical data from which the identity of individuals cannot be determined. KW Counselling Services retains the right to use and disclose statistical data as it determines appropriate.

Disclosure of Personal Information

Personal information will be disclosed to only those KW Counselling Services employees, members, agents and the Board of Directors who need to know the information for the purposes of their work.

KW Counselling Services is permitted to use and disclose personal information to third parties without the individual's knowledge and/or consent, where:

KW Counselling Services is required to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
KW Counselling Services has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
an emergency exists that threatens an individual’s life, health or security
legally required to report a child who may be at risk of harm;
required to report suspected professional abuse;
a government agency or department requests the information;
the information is publicly available;
the use is clearly in the individual’s interest, and consent is not available in a timely way;
knowledge and consent would compromise the availability or accuracy of the information;
required by accrediting body;
required by law

For further information please see KW Counselling Services policy 1.5.2-Confidentiality & Release/Receipt of Client Information.

Retention of Personal Information

Personal information will be retained for such periods of time as may be prescribed by applicable laws and regulations.

For further information please see KW Counselling Services policy 1.5.1- Security & Retention of Records.

Accuracy

KW Counselling Services endeavors to ensure that any personal information provided by the individual in active file(s) is accurate, current and complete as is necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed. Individuals are requested to notify KW Counselling Services of any change in personal or business information.

Information contained in inactive files (files with no activity for 1 year or more) is not updated.

Safeguards

KW Counselling Services will use physical, organizational, and technological measures to safeguard personal information. Only those KW Counselling Services employees, volunteers, or third parties who need to know personal information, for the purposes set out in this Privacy Policy, will have access.

All KW Counselling Services employees, members, volunteers, agents and/or Board of Directors are required to sign a Statement of Confidentiality binding them to maintaining the confidentiality of all personal information to which they have access.

All personal information no longer required is shredded prior to disposal to prevent inadvertent disclosure to unauthorized persons.

For further information on client files, please see KW Counselling Services Policies: 1.4—Confidentiality, 1.5.2—Confidentiality & Release/Receipt of Client Information, 1.5.1—Security & Retention of Records.

Access, Correcting or Updating Personal information

An Individual who wishes to review or verify what personal information is held by KW Counselling Services, or to whom the information has been disclosed (as permitted by law), may make the request for access, in writing, to the KW Counselling Services’ Chief Privacy Officer at:

Chief Privacy Officer
KW Counselling Services
480 Charles St. East,
Kitchener, ON N2G 4K5
privacyofficer@kwcounselling.com

Upon verification of the individual's identity, the Chief Privacy Officer will respond within 30 days in writing. KW Counselling Services will provide access to personal information at no cost.

If the individual finds that the information held by KW Counselling Services is inaccurate or incomplete, upon the individual providing documentary evidence to verify the correct information, KW Counselling Services will make the required changes to the individual's active file(s) promptly.

For further information see KW Counselling Services policy 1.5.3—Client Access to Records.

Complaints

If an individual has a concern about KW Counselling Services’ personal information handling practices, a complaint, in writing, may be directed to the KW Counselling Services’ Chief Privacy Officer.

Upon verification of the individual's identity, KW Counselling Services’ Chief Privacy Officer will act promptly to investigate the complaint and provide a written report of the investigation's findings to the individual.

Where KW Counselling Services’ Chief Privacy Officer makes a determination that the individual's complaint is well founded, the Chief Privacy Officer will take the necessary steps to correct the offending information handling practice and/or revise KW Counselling Services’ privacy policies and procedures.

Where KW Counselling Services’ Chief Privacy Officer determines that the individual's complaint is not well founded, the individual will be notified in writing.

In the event that the complainant is not satisfied with the response, they may choose to follow KW Counselling Services policy 1.5.4—Client Complaints and Appeals.

Updating of Privacy Policy

KW Counselling Services regularly reviews our privacy practices for our various activities, and update our policy. Please check www.kwcounselling.com/privacy on an on-going basis for information on our most up-to-date practices.

Contact information

If individuals have questions or concerns relating to KW Counselling Services’ Privacy Policy or the treatment of personal information, please contact:

Chief Privacy Officer
KW Counselling Services
480 Charles St. East,
Kitchener, ON N2G 4K5

privacyofficer@kwcounselling.com

519-884-0000

Further information on privacy and individual rights in regard to your personal information may be found on the Web site of the Privacy Commissioner of Canada at www.privcom.gc.ca/