The Lambton Kingsway Before & After School Program ( B&A) has provided this Personal Information Policy to describe how personal information is handled. This policy ensures the B&A’s compliance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA).
Identified Purposes:
The B&A collects, uses and discloses personal information only for purposes related to the provision of child care services. Such purposes include the following:
· To meet legislative, regulatory and licensing requirements;
· To process, track and maintain child enrolment and re-enrolments;
· To process enrolment fees, subsidy and receipts for child tax credit purposes;
· To record, process and collect outstanding enrolment fees;
· To assess and implement centre policies, practices and programs;
· To maintain up-to-date records;
· To communicate with parents/guardians;
· To meet and respond to daily care needs;
· To respond to emergencies, including communication with emergency contacts, hospitals and/or medical practitioners;
· To provide the B&A’s staff and third parties (where applicable) with necessary medical information (e.g. dietary restrictions, allergies).
Retention Policy:
Personal information is retained as long as there is a purpose to do so and/or as is required by the legislation that governs the operation of the B&A Program. For example, the provincial legislation upon which the operating license is based requires that child files be retained for three years beyond the date of discharge from the Program. Once personal information is no longer required to fulfill the identified purposes or to comply with legal requirements regarding retention, it will be destroyed or rendered anonymous.
Safeguards:
The B&A will protect personal information by security safeguards appropriate to the sensitivity of the information. Safeguards will vary depending on the sensitivity, format, location and storage of the personal information.
Staff is trained to collect, use and disclose personal information only as necessary to fulfill their duties as childcare providers. It is the policy of the B&A program that staff do not interact with current families, including parents and children on social media networks.
Access and Accuracy:
Individuals have the right to access their personal information that is held by the B&A. Requests for access to the information must be made in writing and will be addressed within a reasonable time (generally within 30 days).
The B&A will make every efforts to ensure that the Personal information used on an ongoing basis is accurate, complete and up-to-date.
Transfers and Disclosures of Personal Information:
Other than for the purposes indicated below or unless required by law, the B&A does not disclose the personal information under its control to any other parties.
In order to meet the purposes set out above, the B&A may transfer or disclose applicable personal information to:
- Service providers retained by the centre to perform functions, such as catering;
- The Lambton Kingsway School administration;
- Government agencies, where the Centre has received consent for such disclosure or where the disclosure is required or permitted by law.
When personal information is transferred by the B&A to third parties, information will be handled confidentially and in accordance with this policy and applicable privacy legislation.
Consent:
By submitting personal information to the B&A, you agree that we may collect, use and disclose such personal information in accordance with this Privacy Policy and/or as required by law. Subject to legal or contractual requirements and reasonable notice, you may refuse or withdraw your consent to our use of your personal information for certain purposes at any time. However, if you refuse to consent or withdraw consent previously given, the B&A may be limited or unable to provide some or all of the childcare services to your family.
The way in which consent is sought, including whether it is express or implied, may vary depending upon the sensitivity of the information. In addition, in certain circumstances as permitted or required by law, personal information may be collected, used or disclosed without the knowledge or consent of the individual. These circumstances include: personal information which is subject to solicitor-client privilege or is publicly available; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to investigate a breach of an agreement or a contravention of law; to act in respect to an emergency that threatens the life, health or security of an individual; or to comply with a subpoena, warrant or court order.
Changes to the Privacy Policy:
The B&A reserves the right to modify or supplement the Personal Information Policy. Any changes to this policy will be posted on the website and the revised policy and changes will be available upon request.
Inquiries or Further Information:
Any questions or concerns related to the Personal Information Policy or the handling of personal information by the B&A should be directed to the program Supervisor.