A1.5 & C1.14 - Confidentiality policy
Confidential Information is defined as: the information received or observed about persons served, staff, Board members, volunteers, students or the affairs of Community Connections (Revelstoke) Society and is to be considered privileged and disclosed only when properly authorized to do so. This definition includes, but is not limited to, intellectual property, business information, identifying information about clients, services provided and received by Community Connections, medical information, financial information, demographic backgrounds and care preferences, and information with any commercial value or utility.
Community Connections has an inherent responsibility to be open and accessible while, at the same time, demonstrating the greatest respect for protection of the persons served/staff/volunteer/board member/student privacy.
All persons served, staff, volunteers, Board members and students are entitled to having their personal information kept confidential. This must be balanced with the need of Community Connections to collect, use and disclose personal information for legitimate business purposes only.
Specifically, during the course of their association with Community Connections and afterward, persons served, staff, Board members, volunteers and students must maintain confidentiality and refrain from using, directly or indirectly, all information known or used by Community Connections in its activities.
1. Accountability – Community Connections is responsible for personal information under its control and shall designate a Privacy Officer who is accountable for Community Connections compliance with the principles of the Code.
2. Identifying Purposes – The purposes for which personal information is collected shall be identified by Community Connections at or before the time the information is collected.
3. Consent – The knowledge and consent of the persons served/staff/volunteer/board member/student is required for the collection, use and disclosure of personal information, except in specific circumstances.
4. Limiting Collection – The collection of personal information shall be limited to that which is necessary for the purposes identified by Community Connections as essential for the delivery of services. Information shall be collected by fair and lawful means.
5. Limiting Use, Disclosure and Retention – Personal information shall not be used or disclosed, except with the consent of the person served/staff/volunteer/Board member/student or as required by law. All consent to release information must be in a written form prior to release of personal information.
6. Accuracy – Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
7. Safeguards – Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Community Connections will apply the same standard of care as it applies to safeguard its own confidential information of a similar nature. All documents pertaining to information around persons served/staff/volunteers/Board members/students are kept locked.
8. Openness – Community Connections shall make readily available to persons served/staff/volunteer/Board member/student, specific, understandable information about its policies and practices relating to the management of personal information.
9. Individual Access – Upon request, persons served/staff/volunteer/Board member/student shall be informed of the existence, use, and disclosure of their personal information, and shall be given access to that information. They are entitled to question the accuracy and completeness of the information and have it amended as appropriate. Information will not be released unless under written authorization from those it pertains to except where required by law. Upon release of person served/staff/volunteer/Board member/student information the individual will be notified of the information that was released. All correspondence pertaining to the release will be documented and held in that person’s file.
10. Challenging Compliance – Persons served/staff/volunteers/Board member/students shall be able to question compliance with the above principles to the Privacy Officer accountable for Community Connections compliance.
PROCEDURE
1. It is the right of every person served, staff, Board member, volunteer, and student to:
a. See any information about them that is to be released to a third party prior to the authorization for release of that information.
b. To see any personal record or information held by Community Connections pertaining to them;
c. Obtain copies of any personal information at their own expense;
2. No case record, personnel file or privileged information shall be disclosed unless:
a. Consent to release information is provided in writing;
b. The consent to release information is specified the information to be released, the name of designate to whom that information will be released (specific at agency if possible), make time line for release of information.
c. It is information regarding qualifications of personnel, paid, volunteer or Board, requested by a funding body and is, in the opinion of Community Connections, necessary that such information be released;
d. It is a legal requirement that information be released;
e. There is a professional obligation to release information.
3. Where information is requested that names or identifies a third party all reference to that third party shall be removed prior to release.
4. Review of file:
a. Request is both verbal and written, with a letter to the Executive Director requesting a copy of the file.
b. Within five working days a request to review a person’s file will be accommodated. If the person requests a copy of the file, it will be made and the costs associated with reproducing the file must be paid by the person so requesting.
c. If a person served requests to see their file, they will meet with the counselor or case worker to review the file together and identification is presented. If staff, volunteers, students request to see their personnel file, they will meet with Human Resources to review the file together. At no time is the file to be left with a person served, staff, volunteer or student without counselor/case worker/Director present.
d. If unable to review the file in person, the counselor or case worker may review the information over the telephone with the person served, only if the counselor/case worker is certain of the persons served identification. For staff, volunteers, or students, the Director may review the file over the telephone only if they are certain of the person’s identification.
e. If the person served/staff/volunteer/student picks up the file copy at the office, then the person must sign for the copy and pay the costs associated with reproducing the file. Front Desk staff writes down the ID information and witnesses persons served/staff’s/volunteer’s/student’s signature.
f. Copy of signed receipts for files will be kept in persons served/staff’s/volunteer’s/student’s file with letters of request, dates of review, calls, etc.
5. All persons served seeking services from Community Connections are to receive comprehensive information about this organization and the rights and expectations the person served has of us.
6. Each employee is responsible for the orientation and informed consent of the people they serve. Refer to A1.9 Informed Consent for more information.
