At Faye Schwab Counselling Services, we are
committed to providing our clients, with exceptional service. As providing this service involves the
collection, use and disclosure of some personal information about our clients,
protecting their personal information is one of our highest priorities.
While we have always respected our clients,
privacy and safeguarded their personal information, we have strengthened our
commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1,
2004, sets out the ground rules for how B.C. businesses and not-for-profit
organizations may collect, use and disclose personal information.
We will inform our clients of why and how we
collect, use and disclose their personal information, obtain their consent
where required, and only handle their personal information in a manner that a
reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in
compliance with PIPA, outlines the principles and practices we will follow in
protecting clients’ personal
information. Our privacy commitment
includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to
request access to, and correction of, their personal information.
Definitions
Personal Information –means information about an identifiable individual
including name, date pf birth, home address and phone number, marital status,
medical information, Personal information does not include contact
information (described below).
Contact information – means information that would enable an individual to
be contacted at a place of business and includes name, position name or title,
business telephone number, business address, business email or business fax
number. Contact information is not
covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for
ensuring that Faye Schwab Counselling Services complies with this policy and
PIPA.
Policy
1 –
Collecting Personal Information
1.1 Unless the purposes for collecting personal
information are obvious and the client voluntarily provides his or her personal
information for those purposes, we will communicate the purposes for which
personal information is being collected, either orally or in writing, before or
at the time of collection.
1.2 We will only collect client information that
is necessary to fulfill the following purposes:
·
To verify identity;
·
To deliver requested
counseling services
·
To ensure a high
standard of service to our [clients];
Policy 2 – Consent
2.1 We will obtain client consent to collect, use
or disclose personal information (except where, as noted below, we are
authorized to do so without consent).
2.2 Consent can be provided, orally, in
writing, electronically or it can be implied where the purpose for
collecting using or disclosing the personal information would be considered
obvious and the client voluntarily provides personal information for that
purpose.
2.3 Consent may also be implied where a client
is given notice and a reasonable opportunity to opt-out of his or her personal
information being used for mail-outs and the client does not opt-out.
2.4 Subject to certain exceptions (e.g., the
personal information is necessary to provide the service or product, or the
withdrawal of consent would frustrate the performance of a legal obligation),
clients can withhold or withdraw their consent for Faye Schwab Counselling
Services to use their personal information in certain ways. A client’s, decision to withhold or withdraw their consent to certain uses of
personal information may restrict our ability to provide a particular service
or product. If so, we will explain the
situation to assist the client in making the decision.
2.5 We may collect, use or disclose personal
information without the client’s, knowledge or
consent in the following limited circumstances:
·
When the collection,
use or disclosure of personal information is permitted or required by law;
·
In an emergency that
threatens an individual's life, health, or personal security or harm to another
·
When the personal
information is available from a public source (e.g., a telephone directory);
·
When a file is
subpoenaed by a court of law;
Policy 3 – Using and
Disclosing Personal Information
3.1 We will only use or disclose client personal
information where necessary to fulfill the purposes identified at the time of
collection or for a purpose reasonably related to those purposes such as:
·
To contact our clients
directly about appointments or requested information
3.2 We will not use or disclose client personal information
for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal
information to other parties.
Policy 4 – Retaining
Personal Information
4.1 If we use client personal information to make
a decision that directly affects the client, we will retain that personal
information for at least one year so that the client has a reasonable
opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client
personal information only as long as necessary to fulfill the identified
purposes or a legal or business purpose.
Policy 5 – Ensuring
Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure
that client personal information is accurate and complete where it may be used
to make a decision about the client or disclosed to another organization.
5.2 Clients may request correction to their
personal information in order to ensure its accuracy and completeness. A request to correct personal information must
be made in writing and provide sufficient detail to identify the personal
information and the correction being sought.
A request to
correct personal information should be forwarded to the Privacy Officer [or
designated individua].
5.3 If the personal information is demonstrated
to be inaccurate or incomplete, we will correct the information as required and
send the corrected information to any organization to which we disclosed the
personal information in the previous year.
If the correction is not made, we will note the clients’, correction request in the file.
Policy 6 – Securing
Personal Information
6.1 We are committed to ensuring the security of
client personal information in order to protect it from unauthorized access,
collection, use, disclosure, copying, modification or disposal or similar
risks.
6.2 The following security measures will be
followed to ensure that client personal information is appropriately protected:
The use of locked filing
cabinets; physically securing offices where personal information is held; the
use of user IDs, passwords, encryption, firewalls; restricting access to
personal information as appropriate (i.e., only those that need to know will
have access.
6.3 We will use appropriate security measures
when destroying client’s, personal
information such as shredding documents, and deleting electronically stored
information].
6.4 We will continually review and update our
security policies and controls as technology changes to ensure ongoing personal
information security.
Policy 7 – Providing
Clients Access to Personal Information
7.1
Clients have a right to access their personal information, subject to
limited exceptions.
7.2 A request to access personal information
must be made in writing and provide sufficient detail to identify the personal
information being sought. A request to access personal information should be
forwarded to the Privacy Officer [or Faye Schwab.]
7.3 Upon request, we will also tell clients how
we use their personal information and to whom it has been disclosed if
applicable.
7.4 We will make the requested information
available within 30 business days, or provide written notice of an extension
where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing
access to personal information. Where a
fee may apply, we will inform the client of the cost and request further
direction from the client on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part,
we will notify the client in writing, providing the reasons for refusal and the
recourse available to the client.
Policy 8 – Questions
and Complaints: The Role of the Privacy
Officer or designated individual
8.1 The Privacy Officer or Faye Schwab is
responsible for ensuring Faye Schwab Counselling Services’ compliance with this policy and the Personal
Information Protection Act.
8.2 Clients should direct any complaints,
concerns or questions regarding Faye Schwab Counselling Services’ compliance in writing to the Privacy Officer. If the
Privacy Officer is unable to resolve the concern, the client may also write to
the Information and Privacy Commissioner of British Columbia.
Contact
information for Faye Schwab Counselling Services’ Privacy Officer or
Faye Schwab:
Phone: (780) 466 - 7452