Dated: August 22, 2019
Our Privacy Policy informs you of our commitment to and policy on privacy. It tells you about the ways we ensure that the privacy and confidentiality of your Personal Information is protected.
We will conduct periodic reviews of our Privacy Policy to make sure that it remains consistent with changing standards, technologies and laws.
Table of Contents
- Compliance with Legal and Industry Standards
- Our Privacy Policy
- Purposes for the Collection, Use, Retention and Disclosure of Information About You
- Key Principles
- Information Regarding Website Practices
- Updating this Privacy Policy
Compliance with legal and industry standards
The objective of our Privacy Policy is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada) and other applicable privacy legislation. We will make every reasonable effort to comply with industry standards and all applicable privacy legislation.
Our Privacy Code
Our Privacy Policy applies to our residents and their family members, designated contacts and visitors, our volunteers and donors, job applicants who apply for positions with us but whom are not employed by us, independent contractors and other identifiable individuals whose personal information we collect, use, retain and disclose in the course of our activities. However, our Privacy Policy does not pertain to our employees or past employees, as our relationship with such individuals is governed by contractual arrangements and other applicable laws.
When we use the words “personal information” or “information” in our Privacy Policy, we mean information about an identifiable individual, with the exception of the name, title, business address or telephone number of an employee of an organization, which is considered to be public information. These terms also do not include information that does not identify particular individuals, like aggregate statistics or anonymous data.
Purposes For The Collection, Use, Retention And Disclosure Of Information About You
Our purposes for collecting, using, retaining and disclosing your personal information depends upon your relationship with us. The following outlines our purposes if you are a resident, a resident’s designated contact person, family member or visitor, a volunteer, a donor, a job applicant who does not become employed by us, or an independent contractor.
With respect to our Residents:
We collect, retain and disclose your personal information for the following purposes:
- to assess your suitability to lease or rent a suite at Concordia Village;
- to establish you as a resident, if applicable, and obtain necessary basic and beneficiary information;
- to serve you as a tenant and ensure the safety, security, and reasonable enjoyment of the rented premises for each resident, including access to the premises, equipment, and services that CWPI has agreed to provide;
- to assess and evaluate the services we provide and to run our day-to-day operations;
- to obtain payment for rent and other services we provide and to maintain adequate accounting and tax records;
- to detect and prevent fraud, and to safeguard the interests of you and CWPI; and
- to maintain your information in a form that we reasonably require for our business needs and so we can transfer it to a third party in the unlikely event of a sale, re-organization or transfer of our business in whole or in part.
With Respect to a Resident’s Designated Contact Persons, Family Members and Visitors:
We collect, use, retain and disclose your personal information for the following purposes:
- to communicate with you, as reasonably authorized and required, regarding the resident with whom you are associated;
- to assist us in planning and providing services to a resident and to document significant events and circumstances relating to a resident;
- to run our day-to-day operations;
- as applicable, to obtain payment for rent and the services we provide and to maintain adequate accounting and tax records;
- to determine your interest, experience and availability with respect to our various volunteer positions;
- to provide you with information and invite you to contribute or participate in events and programs at Concordia Village, including events and programs for fundraising purposes; and
- to meet legal, governmental and/or regulatory requirements, to detect and prevent fraud and to promote and protect the interests of our residents and our properties.
With Respect to Volunteers:
- to establish you as a volunteer and to provide us with a means of contacting you;
- to determine your interest, experience and availability with respect to our various volunteer positions;
- to assess any special qualifications, needs or requirements you may have in order to place you in an appropriate position;
- to assess your interest in extra training or responsibility related to your volunteer position;
- to assess the quality of our events, programs and services and to provide you with information and invite you to contribute or participate in events and programs at Concordia Village, including events and programs for fundraising purposes;
- to have information in such form as we may reasonably require for our business needs and so we can transfer it to a third party in the unlikely event of a sale, re-organization or transfer of our business in whole or in part; and
- to meet legal, governmental and/or regulatory requirements, to detect and prevent fraud and to promote and protect the interests of our residents and our properties.
With Respect to Donors:
- to establish you as a donor;
- to process your donation with a financial institution (such as your credit card company, your bank or our bank) and to issue income tax receipts or other documentation that may be reasonably required;
- to publish information regarding your donation in accordance with your consent;
- to inform you about the progress of campaigns, the results of fundraising events and/or the use made of donations and to assess the quality and quantity of our campaigns, events and programs;
- to provide you with information and invite you to contribute or participate in other events and programs at Concordia Village, including fundraising events and programs; and
- to maintain adequate accounting and tax records to detect and prevent fraud, to promote and protect the interests of our residents and our properties, to have information in such form as we may reasonably require for our business needs and so we can transfer it to a third party in the unlikely event of a sale, re-organization or transfer of our business in whole or in part.
With Respect to Job Applicants:
We collect, use, retain and disclose your personal information for the following purposes:
- to make staffing and human resources decisions, which may include contacting those who may have information about you, your work experience and your work practices;
- to assess any special qualifications, needs or requirements you may have in order to determine your eligibility for the position for which you applied and any other position which may become available with CWPI;
- to meet any legal, governmental or regulatory requirements, to detect and prevent fraud, and to promote and protect the interests of our residents and our properties.
With Respect to An Independent Contractor:
We collect, use, retain and disclose your personal information for the following purposes:
- to communication with you with respect to our needs and requirements and to the extent necessary for the services you perform for us, with respect to our residents and the services we provide to them;
- to run our day-to-day operations, to arrange for payment for the services you provide and to maintain adequate accounting and tax records;
- to maintain your information in a form that we reasonably require for our business needs and so we can transfer it to a third party in the unlikely event of a sale, re-organization or transfer of our business in whole or in part;
- to meet any legal, governmental or regulatory requirements, to detect and prevent fraud, and to promote and protect the interests of our residents and our properties.
Key Principles
Our Privacy Policy consists of the following key principles, which apply to all aspects of our handling of an individual’s personal information, including the collection, use, retention and disclosure of such information.
A. Collecting and Using Information
We collect, use, retain and disclose information about you with your consent, except as outlined in this Privacy Policy.
In obtaining your consent, whether express or implied, our purposes for which we require your information are outlined in this Privacy Policy. If our purposes differ than those outlined herein, we will advise you of our purposes at the time of collection of your information.
We may depart from this consent principle in accordance with the limited exceptions described in this Privacy Policy, where the information is publicly available or accessible, or where required or permitted by applicable laws (for instance, we may disclose personal information in an emergency to protect human life or safety).
We gather and use personal information about you in connection with your relationship with us. We obtain our information about you to foster the growth of a mutually beneficial relationship. The type of information we gather and collect and the extent of information we obtain depends upon the nature of our relationship with you.
For example, for our residents we require a designated contact person, financial payment information, and where necessary, health information. For every volunteer, we require information regarding your availability, experience and special requirements to ensure that you are provided with the appropriate volunteer opportunities. For every job applicant, we need some background information including, for example, your training and experience, your resume, and your references.
We only collect the information we need and only use it for the purposes explained to you.
We only collect the information we believe we reasonably need and only use it for the purposes outlined in this Privacy Policy or if applicable, outlined to you at the time of collection of your information. If we wish in the future to use the information collected for purposes not previously identified, we will ask you for your consent at that time.
B. Releasing Information
Our disclosure of your personal information occurs in limited circumstances and depends upon your relationship with us.
We disclose your personal information to parties outside CWPI in the following limited circumstances:
- when we have your consent, whether express or implied;
- to agents and third parties whom we use or retain to assist us in our operations;
- when we are required or permitted by law or regulation to do so;
- when we wish or are required to disclose to fulfill a public duty, such as reporting abuse or preventing fraud;
- when we are protecting or advancing our interests in the context of dealings with governmental or industry bodies, administrative tribunals or courts; and
- when we are operating under an exception to the requirement for consent set out in applicable laws.
In all such cases, we will only make disclosure to the extent that is necessary to accomplish our purposes or discharge our regulatory, legal or public duty. Whenever reasonably required, we will request that the party receiving the information provides reasonable assurances that he or she will also respect the privacy of your information in accordance with applicable laws.
The following list provides some examples of situations where we disclose the personal information of our residents and, at times, other individuals:
- We may maintain directory information about you at Concordia Village while you are a resident. This information may include your name, suite number, and phone number.
- We may disclose your personal information, including your personal health information, to a family member, close friend or other relative, or any individual you designate, who is involved in the services we provide or your care.
- We may disclose your information in order to obtain care and treatment for you in the event of an emergency and will share and exchange information with others involved in your treatment and care.
- We may disclose your information to those who will become involved in your care in the event you are admitted to a health care facility.
- We may disclose your information for performance evaluation and for training programs purposes and in connection with accreditation, certification, licensing and credentialing activities, review and auditing activities, and business management activities such as resolution of internal grievances and due diligence in connection with any proposed sale, reorganization or transfer of our business.
- We may disclose your information in order to advise you about services, to provide you with appointment reminders and to inform you about various services that may be of interest to you.
- We may disclose information about you for public health purposes, including:
- prevention or control of disease, injury, disability or death;
- reporting deaths;
- reporting abuse or neglect;
- notifying individuals who may have been exposed to a disease or may be at risk for contracting or spreading a disease.
- As applicable, we may disclose your information so that the treatment and services you receive may be billed to you, a government program, an insurance company or other third party payor.
- We may disclose information if you are involved in a lawsuit or a dispute and in response to a subpoena, a request during an examination for discovery or other lawful process, or as required or permitted by law.
C. Protecting Information
We will protect your information with appropriate safeguards and security measures.
We have reasonable security standards to protect our systems and your information against unauthorized access and use. All of our employees are familiar with the procedures that must be taken to safeguard personal information. Our security practices are reviewed on a periodic basis to ensure that the confidentiality and privacy of your information is protected.
We retain your information only as long as it is legally or reasonably required by us.
The length of time we retain information varies depending on your relationship with us and the nature of the information. For example, if you are a resident we retain your information for so long as you are a resident and for a designated period of time after you are no longer a resident. Our retention period may extend beyond the end of your relationship with us but only for so long as required by law or as is reasonably required by us.
For unsuccessful job applicants, any information we collect about you during the application process will be destroyed within 180 days of your application. During such 180 days, we may consider your application for other positions that become available and will contact you if appropriate.
When your information is no longer needed by us, we have procedures to destroy, delete, erase or convert it to an anonymous form. For information about the retention periods of other service providers, please consult such entity directly.
D. Providing Information Access and Accuracy
We will give you access to the information we have about you.
Please contact our Privacy Officer if you wish to have access to any information we may have about you. You will need to document your request in writing and provide us with identification at the time of access. We will advise you in advance if a minimal charge is required for us to conduct a search of our records for information about you, and will do our utmost to respond to your request within 30 days.
Please note that we may not be able to provide information from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to us, is too costly to retrieve, or cannot be disclosed for other legal reasons.
We will make reasonable efforts to keep your information accurate and up-to-date. It is important that your personal information is accurate and complete. If you find any errors in our information about you, let us know and we will make the appropriate corrections and endeavor to ensure they are conveyed to anyone we may have previously misinformed. In order to make a change to the personal information we hold about you, please send us the correction in writing by mail or fax. If we do not correct your information as you request, we will nevertheless make record of your request and your opinion as to the accuracy of the information in our files.
E. Respecting and Responding To Your Privacy Concerns
We will explain your options of refusing or withdrawing consent to the collection, use or disclosure of your personal information, and we will record and respect your choices subject to any legal or contractual restrictions and reasonable notice.
Please contact our Privacy Officer if you have any questions related to your options for refusing or withdrawing consent. For example, for job applicants, we may decline to accept your application where you refuse or withdraw consent for us to contact your references. In each circumstance, our Privacy Officer will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and to record your options.
We will investigate and respond to your concerns about any aspect of our handling of your information. If you have any concerns or questions about privacy and confidentiality – or any concerns about the way a request for information was handled – you can take the following action:
Contact our Privacy Officer at:Charlene Corlett, Executive Assistant, serving as the Privacy Officer.
Phone: 204-667-6479 ext. 5261
Email address: ccorlett@concordiavillage.ca
Our Privacy Officer has the decision-making authority to resolve most concerns.
Information Regarding Website Practices
We collect and store your e-mail addresses from any communications that you may send to us by clicking on any of our e-mail links.
We may use your e-mail address to communicate with you, especially if your e-mail indicates that a response to your inquiry is requested or to address a concern or complaint you may have.
If we receive an inquiry from you where it is reasonable to infer that we may respond by e-mail, we may communicate by e-mail. We are not responsible for any liability or loss caused by the fact that e-mail transmission cannot be guaranteed to be secure of error or that it could be intercepted, corrupted, lost, destroyed, arrive late or incomplete or contain viruses.
We do not require or request cookies. (“Cookies” are alphanumeric identifiers that are transferred to your computer’s hard drive through your Web browser to enable sites to recognize visitors on subsequent visits.) The service providers for our website (currently Vimeo, Font Awesome, and Adobe Fonts) use cookies to ensure that our website functions properly and to optimize your experience on our website; they may collect and store aggregate statistics but we are advised that they do not collect or obtain identifiable personal information about users. We do not have control over the cookies they set.
Links to external sites are provided for your convenience only and we assume no responsibility or liability for such linked sites or for the privacy practices of any third party.
Updating This Privacy Code
Any changes to our Privacy Policy or our information handling practices will be recorded in a timely manner.
We may add, modify or remove portions of this policy when we feel it is appropriate to do so. However, we will not use any information collected prior to such changes for any new purposes without first obtaining your consent.