ISANS is committed to ensuring that any personal information collected from clients during the course of registration administration and client service delivery is protected.
Summary of Principles
- Accountability: ISANS is responsible for the personal information under its control and ISANS leadership team is responsible for overseeing compliance by their staff to PIPEDA. This includes personal information transferred to third parties for processing or for providing ongoing services to clients.
- Purposes for collection: ISANS identifies and communicates the purpose for which personal information is being collected from clients at or before the time the information is requested. ISANS will collect, use and disclose personal client information for the following purposes:
- To review and process client registrations
- To develop aggregate information and statistics used for monitoring and evaluation of the overall success of Programs and Services and to identify service areas to improve upon.
- To create and maintain the ISANS client databases.
- To identify and select services and service providers to meet client needs or preferences.
- To comply with legal requirements.
- To comply with funder requirements.
- Consent: ISANS will obtain client consent, either expressed or implied, before or when it collects, uses or discloses personal information, except where authorized by law.
- The express, written consent of a client will be required before ISANS shares personal client stories and photographs on our website or through on-line or hardcopy publications including the ISANS Annual Report.
- When an individual is registered as an ISANS client they complete the Client Registration Form and are required to read the following statement and provide their written express consent accordingly.
- A client can refuse to provide their consent to ISANS collecting their personal information and the implications of that refusal on the services ISANS can provide will be explained to them at the time.
- Consent to share personal information can be withdrawn by a client at any time by notifying ISANS at firstname.lastname@example.org and allowing 5 business days for processing.
- In the case of any ISANS client under 19, their parent or guardian will be asked to provide express written consent on their behalf.
- Limiting collection: ISANS makes every reasonable effort to limit the collection of personal information to that which is necessary for the purposes identified by ISANS.
- Limiting use, disclosure and retention: ISANS makes every reasonable effort not to use or disclose personal information for purposes other than those for which it was collected, except with the consent of the client, or as required by law. ISANS will use contractual or other means to protect personal information that has been transferred to ISANS partner organizations and client service providers. A client may, at any time, request or be given an explanation of how their personal information is being used by email@example.com.
- Maintaining accuracy: ISANS will keep personal information as accurate, complete and up-to-date as reasonably possible. Clients are responsible for advising ISANS of any changes to their personal information, for example, home address or contact information.
- Safeguards and Security: ISANS will use appropriate security safeguards to protect client personal information against loss, theft, unauthorized access, disclosure, copying, misuse or modification, regardless of the format in which the information is heldl
All client personal information is accessible only by authorized ISANS personnel, or authorized Atlantic Immigration Pilot Project service providers, who need access to client information for the performance of their duties or provision of services to ISANS clients.
- Access to personal information: Upon receiving a written request from a client, and subject to exemptions stipulated by law, ISANS will inform a client of the existence, use and disclosure of their personal information and will provide access to that information. A client will be entitled to challenge the accuracy and completeness of the information and have it amended where inaccuracies exist.
- Complaints Process: An ISANS client can raise any concerns they may have with the protection of their personal information by following the ISANS Client Complaint Process and/or emailing firstname.lastname@example.org.
- Sharing personal information without client’s consent: There are situations where ISANS does not need the consent of a client in order to share their personal information. The exceptions are:
- Section 23 of the Children and Family Services Act states that “Every person who has information, whether or not it is confidential or privileged, indicating that a child is in need of protective services shall report that information to an agency.”
- Section 5 of the Adult Protection Services Act provides that “anyone who has information, confidential or privileged, indicating that an adult is in need of protection must report that information to the Minister of Community Services through designated officials.”
- If you pose a threat of harm to yourself or to another person, ISANS will take whatever steps are required by law, or permitted by law, to help prevent any potential harm from happening.
- A court order, issued by a judge, could require ISANS to release your personal information or could require an ISANS employee or volunteer to testify in court.
- Expressed consent is consent that has been clearly established between the ISANS employee and the client and can be verbal or in writing.
- Implied consent is consent which is inferred from a client’s actions and the facts and circumstances of a particular situation.