Volunteer

The New Canadians Centre Peterborough and its volunteers will uphold confidentiality and respect privacy rights to protect the well-being of clients including sponsored persons. As a New Canadians Centre volunteer, I agree to the following:

1) I will not speak to the media about clients unless I have prior permission from the New Canadians Centre.

2) When confidential information is revealed to me, I will inform the clients of my role and duty to respect their privacy & confidentiality.

3) I will uphold the confidentiality of:

• - documentation containing personal information
• - the location / address of clients’ homes
• - the names, office locations and payment arrangements of health personnel caring for clients (i.e. doctors, dentists, social workers, etc.)
• - clients’ family budgeting arrangements and financial situation
• - any information regarding health status and health histories of clients
• - any other information that may be considered personal, sensitive or confidential

4) If I work within a client’s home, I will avoid being intrusive, and I will be present only when necessary and welcomed. I will protect the peacefulness and privacy of client’s personal and family times.

5) I will be sensitive to existing gender norms; I will not be alone with clients and sponsored family members of another gender.

6) I will protect the right to privacy of clients and sponsored children in the school setting. I will avoid being alone with children at any time unless absolutely necessary; in those cases, I will not be alone with children without expressed consent from the parents.

7) If disclosure of the client’s confidential and/or personal information is legally necessary, I will do my best to ensure that the clients have given their consent.

1.0 Purpose

The New Canadians Centre Peterborough (NCCP) is committed to developing young citizens to become active and committed members of the community. This development is achieved through the services offered by the SWIS and Community Connections programs and other special events involving Youth. Child abuse will not be tolerated by the NCCP. The Board of Directors and Executive Director are dedicated to protecting the safety and dignity of any youth involved in organizational activities, programs and events; adult volunteers; paid employees and anyone who has contact with the NCCP. This policy sets out steps to prevent and deal with allegations and cases of Abuse against Children and Youth, as defined within this policy.

2.0 Scope

All members, volunteers and staff are required to abide by the guidelines and regulations contained within this policy. This policy deals only with the prevention of abuse of children/youth. For details on workplace policies regarding Harassment please request a copy of NCC's Harassment Policy and Anti-Discrimination, Access, & Equity.

3.0 Definitions

Abuse, as defined by the Ontario Child and Family Services Act, includes sexual, physical, emotional or psychological abuse, neglect and general risk of harm.

Children/Youth are defined as any individual under the age of 18.

4.0 Code of Conduct

All adult volunteers and staff are expected to:

• i. respect the rights and dignity of themselves and others
• ii. demonstrate a high degree of individual responsibility
• iii. act with consideration and good judgment in all interpersonal relations
• iv. respect everyone’s right to privacy
• v. avoid unaccompanied and unobserved activities with youth wherever possible
• vi. avoid any physical contact that may make a youth feel uncomfortable
• vii. avoid vulgar, disparaging and/or sexually suggestive language
• viii. avoid the consumption of alcohol or other controlled substances while in the presence of a youth or during the time responsible for monitoring a youth
• ix. establish appropriate relationships with youth (i.e. instructor, guide, mentor) and avoid contact outside of NCCP Programs
• x. ensure, where reasonably possible, that two adult members supervise or accompany youth during NCCP activities, or that other adults are with earshot or within sight
• xi. realize that bullying, physical, verbal or cultural abuse, and/or sexual harassment are unacceptable conduct by any staff member or volunteer

5.0 Recruitment of staff and volunteers

Two types of checks will be required:

Police Record Checks

• - All staff and volunteers in a position of responsibility at youth targeted events, or other NCCP events where youth will be present, are required to submit to a police record check
• - Police checks will be required as a condition of employment for all applicable NCCP positions
• - Applicable staff and volunteers will be expected to submit a police record check every three years. If an employee or volunteer leaves the NCCP and then returns, another police record check must be completed
• - If any police record check is returned with a criminal conviction, the involved party must be prepared for a verification of conviction to be completed with local police services. This information will be submitted to the Executive Director who will determine whether the individual will be hired or secure a volunteer placement based on the nature of the position, risk involved and nature of the conviction. During this phase, the individual in question will not conduct employment or volunteer duties.

Personal Reference Checks

• - Personal reference checks must be verified for all staff applying for positions at the NCCP. Personal reference checks must be verified for key volunteer positions.
• - The staff member engaging the individual (prospective volunteer or employee) is responsible for completing these checks. A minimum of two reference checks should be completed.

6.0 Responsibility for Reporting Abuse

The Ontario Child and Family Services Act, recognizes that each NCCP staff member and volunteer has a responsibility for the welfare of children.

It states clearly that, members of the public, including professionals who work with children, have an obligation to report promptly to a children’s aid society if they suspect that a child or youth under the age of 16 is or may be in need of protection.

If a person has reasonable grounds to suspect that a child is, or may be in need of protection, the person must promptly report the suspicion and the information upon which it is based to a children’s aid society.

Reporting & Investigation Procedures

All incidents of disclosures or suspicions of abuse will be reported to an individual’s Supervisor and/or the Executive Director. Notifications should be made in writing and should include:

• i. name of staff or volunteer(s) involved
• ii. date of incident
• iii. short description of incident/allegations
• iv. any other individuals or potential witnesses which might have input or information with respect to the incident
• v. signature and name of individual compiling the report and date compiled

Alleged Staff/Volunteer Involvement

• i. Upon receipt of the incident report, the Executive Director and individual responsible for completing the incident report will promptly contact the Children’s Aid Society (CAS) to report the allegation of abuse. The Executive Director and any staff involved will cooperate fully with any investigation being conducted by Police or CAS.
• ii. The Executive Director shall undertake an initial investigation of the allegation(s) immediately following the receipt of an incident report. Caution will be taken by the Executive Director not to impede any investigations being conducted by police or child protection services.
• iii. The Executive Director will keep the Governance Committee informed of the status of the investigation during the filing of all reports and investigations.
• iv. Once written notice has been received, the staff member or volunteer under investigation will be immediately removed from duty, in accordance with standard Federal and Provincial labour legislation. For employees, this type of suspension could include suspension from duty with or without pay.
• v. If the incident involves the Executive Director, an incident report should be filed directly to the Chair of the Board of Directors. The Governance Committee will then follow the same steps as described above.
• vi. All information is to be collected according to the Freedom of Information and Protection of Privacy Act.

Alleged Home Incident(s)

When abuse is suspected to have been perpetrated by the parent/guardian, the above reporting procedures for staff/volunteers will apply. CAS will take a lead role in investigating allegations with full cooperation from NCC staff and volunteers.

7.0 Disciplinary Action

If a complaint is substantiated, an employee or volunteer will face disciplinary action up to and including immediate termination due to gross misconduct. Reinstatement of an employee or volunteer will occur only after all allegations have been cleared to the satisfaction of the Executive Director and where necessary the Governance Committee.

8.0 Training

Training will be made available to all employees, including applicable volunteers, addressing the issue of abuse, recognition and reporting of abuse, and possible termination.

9.0 Compliance

Any staff member or volunteer, failing to comply with this or any other policy regarding the prevention of child/youth abuse risks disciplinary action up to and including the termination of employment. If illegal activity has taken place, the proper authorities will be notified and the NCC will fully cooperate with any investigations.

1.0 Introduction

Ontario’s new accessibility standard aims to give people with disabilities great customer service. This guide will help you do that. It will help you learn about:

• - The Accessibility Standard for Customer Service and how it will help you welcome customers with disabilities
• - How to serve customers with different kinds of disabilities
• - How to help customers who use assistive devices, like wheelchairs or oxygen tanks
• - Service animals, such as guide dogs, and how to welcome customers who use them
• - What a support person does and how to help customers who are accompanied by a support person ,/li>
• - What to do when a customer with a disability needs help accessing your goods and services

Under the Accessibility for Ontarians with Disabilities Act, the Ontario government is putting accessibility standards in place in the following areas:

• - Customer service
• - Employment
• - Information and communications
• - Transportation
• - Built environment

2.0 What you need to do under the standard

The Accessibility for Ontarians with Disabilities Act (AODA) was passed in 2005.

The Accessibility Standard for Customer Service applies to all people or organizations in Ontario that provide goods or services, and have one more employees. It affects private, non-profit and public sectors.

To provide accessible customer service, organizations need to:

Create and put in place an accessibility plan that:

• - Considers a person’s disability when communicating with them
• - Allows assistive devices such as wheelchairs, walkers, oxygen tanks, etc.
• - Allows service animals
• - Welcomes support persons
• - Lets customers know when accessible services aren’t available
• - Invites customers to provide feedback
• Train staff and volunteers on accessible customer service

If you would like to read New Canadians Centre Peterborough's Accessibility Plan, please request a copy of the plan.

3.0 How to communicate with people with different types of disabilities

There are many types and degrees of disability. Openly communicating and responding to your customers’ needs is the key to excellent customer service for all. If you’re not sure about the best approach, just ask a person with a disability how you can best communicate with them.

Here are a few tips for interacting with people who have various disabilities:

People with physical disabilities

Only some people with physical disabilities use a wheelchair. Someone with a spinal cord injury may use crutches while someone with severe arthritis or a heart condition may have difficulty walking longer distances.

Tips:

• - If you need to have a lengthy conversation with someone who uses a wheelchair or scooter, consider sitting so you can make eye contact at the same level
• - Don’t touch items or equipment, such as canes or wheelchairs, without permission
• - If you have permission to move a person’s wheelchair, don’t leave them in an awkward, dangerous or undignified position, such as facing a wall or in the path of opening doors

People with vision loss

Vision loss can restrict someone’s ability to read, locate landmarks or see hazards. Some customers may use a guide dog or a white cane, while others may not.

Tips:

• - When you know someone has vision loss, don’t assume the individual can’t see you. Many people who have low vision still have some sight
• - Identify yourself when you approach and speak directly to the customer
• - Ask if they would like you to read any printed material out loud to them (for example, a menu or schedule of fees)
• - When providing directions or instructions, be precise and descriptive
• - Offer your elbow to guide them if needed

People who have hearing loss

People who have hearing loss may be Deaf, deafened or hard of hearing. They may also be oral deaf – unable to hear, but prefer to talk instead of using sign language. These terms are used to describe different levels of hearing and/or the way a person’s hearing was diminished or lost.

Tips:

• - Once a customer has identified themselves as having hearing loss, make sure you are in a well-lit area where they can see your face and read your lips
• - As needed, attract the customer’s attention before speaking. Try a gentle touch on the shoulder or wave of your hand
• - If your customer uses a hearing aid, reduce background noise or move to a quieter area
• - If necessary, ask if another method of communicating would be easier (for example, using a pen and paper)

People who are deafblind

A person who is deafblind may have some degree of both hearing and vision loss. Many people who are deafblind will be accompanied by an intervenor, a professional support person who helps with communication.

Tips:

• - A customer who is deafblind is likely to explain to you how to communicate with them, perhaps with an assistance card or a note.
• - Speak directly to your customer, not to the intervenor.

People with speech or language impairments

Cerebral palsy, hearing loss or other conditions may make it difficult for a person to pronounce words or may cause slurring. Some people who have severe difficulties may use a communication board or other assistive devices.

Tips:

• - Don’t assume that a person with a speech impairment also has another disability
• - Whenever possible, ask questions that can be answered with “yes” or a “no”
• - Be patient. Don’t interrupt or finish your customer’s sentences

People who have learning disabilities

The term “learning disabilities” refers to a variety of disorders. One example is dyslexia, which affects how a person takes in or retains information. This disability may become apparent when a person has difficulty reading material or understanding the information you are providing.

Tips:

• - Be patient – people with some learning disabilities may take a little longer to process information, to understand and to respond
• - Try to provide information in a way that takes into account the customer’s disability. For example, some people with learning disabilities find written words difficult to understand, while others may have problems with numbers and math

People who have intellectual developmental disabilities

Developmental or intellectual disabilities, such as Down Syndrome, can limit a person’s ability to learn, communicate, do everyday physical activities and live independently. You may not know that someone has this disability unless you are told.

Tips:

• - Don’t make assumptions about what a person can do
• - Use plain language
• - Provide one piece of information at a time

People who have mental health disabilities

Mental health issues can affect a person’s ability to think clearly, concentrate or remember things. Mental health disability is a broad term for many disorders that can range in severity. For example, some customers may experience anxiety due to hallucinations, mood swings, phobias or panic disorder.

Tips:

• - If you sense or know that a customer has a mental health disability be sure to treat them with the same respect and consideration you have for everyone else
• - Be confident, calm and reassuring
• - If a customer appears to be in crisis, ask them to tell you the best way to help

4.0 How to interact with people who use assistive devices, and how to use any equipment that your organisation provides to help customers with disabilities

An assistive device is a tool, technology or other mechanism that enables a person with a disability to do everyday tasks and activities, such as moving, communicating or lifting. Personal assistive devices can include things like wheelchairs, hearing aids, white canes or speech amplification devices.

Tips

• - Don’t touch or handle any assistive device without permission
• - Don’t move assistive devices or equipment, such as canes and walkers, out of your customer’s reach
• - Let your customers know about accessible features in the immediate environment that are appropriate to their needs (e.g. public phones with TTY service, accessible washrooms, etc.)

If your organization offers any equipment or devices for customers with disabilities, make sure you know how to use them. It could be helpful to have instruction manuals handy or an instruction sheet posted where the device is located or stored.

Some examples of assistive devices that your organization might offer include:

• - Lifts, which raises or lowers people who use mobility devices
• - Accessible interactive kiosk, which might offer information or services in Braille or through audio headsets
• - Wheelchairs

5.0 How to unteract with a person who has a service animal

People with vision loss may use a guide dog, but there are other types of service animals as well. Hearing alert animals help people who are Deaf, deafened, oral deaf, or hard of hearing. Other service animals are trained to alert an individual to an oncoming seizure.

Under the standard, service animals must be allowed on the parts of your premises that are open to the public. In some instances, service animals will not be permitted in certain areas by law (for example, a restaurant kitchen).

Tips:

• - Remember that a service animal is not a pet. Avoid touching or addressing them
• - Avoid making assumptions about the animal. If you’re not sure if the animal is a pet or a service animal, ask your customer

6.0 How to serve a person accompanied by a support person

Some people with disabilities may be accompanied by a support person, such as an intervenor. A support person can be a personal support worker, a volunteer, a family member or a friend. A support person might help your customer with a variety of things from communicating, to helping with mobility, personal care or medical needs.

Welcome support people to your workplace or business. They are permitted in any part of your premises that is open to the public.

Tips:

• - If you’re not sure which person is the customer, take your lead from the person using or requesting your goods or services, or simply ask
• - Speak directly to your customer, not to their support person

7.0 How to assist people with disabilities who need help accessing your goods and services < p> If you notice that your customer is having difficulty accessing your goods or services, a good starting point is to simply ask “How can I help you?”

Your customers are your best source for information about their needs. A solution can be simple and they will likely appreciate your attention and consideration. Learn More

You can get more information on anything related to accessibility at www.ontario.ca/AccessON

New Canadians Centre (NCCP) strives to promote a harassment-free environment in which all individuals respect one another and work together to achieve the agency’s goals.

1.0 Scope

1.1 This policy applies to complaints of harassment that involve employees and volunteers of NCCP. Harassment by or towards clients is addressed in the agency’s Anti-Discrimination, Access & Equity Policy, though this policy may be instructive.

2.0 What is Harassment?

2.1 Harassment means any behaviour that threatens, demeans, humiliates, or embarrasses a person, and that the other person knew or ought to have reasonably known would be considered unwelcome or offensive. It includes actions, comments or displays. It may be a single incident or continue over time.

Some examples of harassment include, but are not limited to: unwelcome remarks, slurs, jokes, or taunts; unwelcome sexual remarks, invitations, or requests; displays of sexually explicit, sexist, racist, or other offensive or derogatory material; written or verbal abuse or threats; practical jokes that embarrass or insult someone; leering (suggestive staring) or other offensive gestures; unwelcome physical contact, such as patting, touching, pinching, hitting; patronizing or condescending behaviour; humiliating an employee or volunteer in front of co-workers; vandalism of personal property; physical or sexual assault.

2.2 Work-related harassment can take place in the workplace itself, or outside of the workplace in a situation that is connected to work.

3.0 Harassment is against the law

3.1 Ontario’s Human Rights Code protects people against discrimination in employment (which may, in some cases, include volunteer work) on the basis on the enumerated grounds of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, age, record of offences, marital status, same-sex partnership status, family status and handicap. The Commission regards harassment as a form of discrimination. NCCP is committed to upholding its legal obligations to prevent and address situations of discrimination and harassment in the workplace.

4.0 Personal Harassment

4.1 Personal harassment is additionally covered by this policy. Personal harassment is behaviour which meets the test for harassment, but is not based on one of the protected grounds named above. Any further mention of the term “harassment” in this policy shall refer to both personal harassment as well as harassment as explained in all previous sections of this policy.

5.0 Informal Procedure

5.1 If an individual believes they are being harassed, they should Immediately make the individual(s) aware that the behaviour is unwelcome and ask him/her to stop.

5.2 If an individual is unable or unsuccessful in dealing directly with another’s harassing behaviour, or feels that the harassing behaviour should be dealt with by the Executive Director of the NCCP, they can choose to proceed with a complaint informally at first. The Executive Director is designated to assist individuals with this process which may include helping the individual speak to the other person, or to speak to the other person on the individual’s behalf. If the complaint is against the Executive Director, the individual should contact the Chair of the Board of Directors who will act, or designate an appropriate person to act, to assist the individual to resolve the complaint informally. Mediation may be attempted if appropriate, and with permission of all parties.

6.0 Formal Complaint

6.1 An individual may make a formal complaint if they are not satisfied with the outcome of the informal procedure or should they not want to proceed informally. A formal complaint shall be made in a timely manner in writing to the Executive Director (or to the Chair of the Board of Directors if the complaint is against the Executive Director). All formal complaints will be investigated by an impartial person designated by the Executive Director/Chair.

7.0 Investigation

7.1 An investigation will involve: getting all pertinent information from the complainant; informing the alleged harasser of the details of the complaint, and getting his/her response; interviewing any witnesses; deciding whether, on a balance of probabilities, the harassment did take place; and possibly recommending appropriate remedies or other action.

7.2 If the investigator determines that a complaint is valid, he/she will report in writing to the Executive Director (or Chair of the Board of Directors) promptly. The Executive Director/Chair will decide what action to take and will inform both parties of the decision in writing. If a good faith complaint is found not to be substantiated, no action will be taken.

7.3 NCCP recognizes its responsibility to ensure that harassment ends as soon as possible after the agency becomes aware of it. Investigations into formal complaints will be completed as quickly as possible, ideally within one month from the time the formal complaint is made.

8.0 Remedies and Corrective Action

8.1 Depending on their position with NCCP and the nature and severity of the harassment, remedies for a person who has been harassed may include, but is not limited to: an oral or written apology from the harasser and possibly NCCP; lost wages; a job promotion that was denied; compensation for any lost employment benefits, such as sick leave; compensation for hurt feelings.

8.2 Corrective action for harassers may include, depending on their position with NCCP and the nature and severity of the harassment: mandatory attendance of an anti-harassment education session; a written reprimand; a suspension, with or without pay; a demotion; dismissal.

9.0 Bad Faith Complaints

9.1 If a complaint is found to have been made in bad faith, the complainant may be subject to the same penalties as a harasser, and the person unjustly accused will be given the benefit of any necessary remedies that would be given in a case of harassment.

10.0 Retaliation

10.1 Anyone who retaliates in any way against a person who has been involved in a harassment complaint may be subject to the same penalties as a harasser.

11.0 Confidentiality

11.1 Complaints will be treated in as confidential a manner as possible. NCCP will not disclose information about a complaint except as necessary to investigate the complaint or to take disciplinary action, or as required by law. Employees and volunteers are encouraged to respect the confidentiality of others.

12.0 Ontario Human Rights Commission and Police

12.1 Individuals are encouraged to contact the Ontario Human Rights Commission about their rights and should be aware they only have a limited amount of time to file a complaint with the commission. If harassment involves physical or sexual assault, which are criminal offenses, the police are the appropriate avenue.

1.0 Policy Statement

The Organisation is committed to the establishment of a healthy and safe workplace and to the integration of health and safety practices in all areas of the workplace. The underlying principle of the policy is the responsibility of all volunteers in maintaining a safe workplace which is best achieved through consultation and co-operation between management and volunteers.

2.0 Guidelines

The Organisation shall adhere to all requirements of the Occupational Health and Safety Act (OHSA). The requirements of the OHSA apply to every employee who is being paid, regardless of the location where the work is performed. If employees work at home and are being paid or are driving and being paid en route, they are covered under the Act.

The Executive Director or designate shall develop, review at least annually, and revise as necessary occupational health and safety policy procedures and develop and maintain a program to implement those procedures.

Volunteers are expected to work in compliance with the law and use safe work practices and procedures. In order to know how to do this, volunteers must be provided with information, training, and supervision to know how to do their jobs safely and to protect their health and safety.

Volunteers should never knowingly put themselves at risk. If a volunteer has concerns about the safety of something they were asked to do, they have the right to speak up. Volunteers have the responsibility to report violations of safety standards, hazardous or dangerous situations.

All volunteers have the following rights:

• - To participate in the process of identifying and resolving workplace health and safety concerns
• - To know about potential hazards to which he or she may be exposed
• - To refuse work that they believes is hazardous to either his or her own health and safety or that of another worker
• - All other rights indicated in the Occupational Health and Safety Act

The Organisation will comply with the legislative requirements surrounding the investigation and reporting of a critical injury or fatality, as prescribed by the Occupational Health and Safety Act and other relevant legislation.

Pursuant to the Occupational Health and Safety Act, this policy must be posted in the workplace and reviewed on an annual basis.

1.0 Purpose

The New Canadians Centre Peterborough, hereby referred to as "the Organisation", is committed to an environment where personal information is protected. The following principles shall govern the collection and use of personal information.

Information should be:

• • adequate, relevant & not excessive
• • accurate and up-to-date
• • accessed only by those who need to know
• • kept only as long as necessary
• • securely stored
• • disposed of appropriately
• • in accordance with all funder requirements and government legislation

2.0 Scope

All active and former board members, staff members and volunteers are required to abide by this policy and to sign an oath of confidentiality. The obligation to maintain confidentiality continues indefinitely.

3.0 Responsibilities

Executive Director shall,

• • Be responsible for the implementation and monitoring of privacy protection policies and procedures.
• • Oversee privacy compliance with all contribution agreements and legislation on behalf of the Board of Directors
• • Monitor changes in contribution agreements and legislation, or assign the responsibility to a designate
• • Ensure that each member of the management team administers policies in a fair and consistent manner

4.0 Definitions

Confidentiality

Confidentiality is the protection of personal information. Confidentiality applies to information that is obtained verbally, in writing or through observation. The types of information considered confidential can include, but are not limited to:

• • personal information such as date of birth, address and contact information
• • immigration records or documents
• • employment contracts and appraisals
• • payments and donations
• • details of funding agreements

iCARE

Immigration Contribution Agreement Reporting Environment (iCARE) is the reporting database used by Immigration, Refugees and Citizenship Canada. Client information in iCARE is sensitive information and must be kept confidential at all times in accordance with privacy provisions in the IRCC Contribution Agreement. IRCC site visits, reviews and/or audits may be conducted at any time, and iCARE usernames and passwords may be revoked by IRCC at any time.

Informed Consent

Informed consent is a process for getting permission before disclosing personal information. Informed consent requires that the person giving consent is told what information is being disclosed, to whom it is being disclosed, and for what reason it is being disclosed before agreeing to the disclosure.

Third Party

Any individual who is not a current employee of the Organisation.

5.0 Relevant Legislation

• • Child and Family Services Act CFSA s.72 (1)
• • Criminal Code (R.S.C., 1985, c. C-46)
• • Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5)
• *Note, non-profit organisations are not covered by PIPEDA unless engaged in commercial activities

6.0 Client Confidentiality

Policy Statement

The Organisation recognises the importance of confidentiality in building and developing a trusting relationship that allows for the flow of information. The Organisation collects, stores, accesses, releases, communicates and destroys client information in a confidential manner.

Guidelines

• • All clients shall be informed of the Organisation’s approach to confidentiality.
• • Only information that is reasonably necessary to provide services is collected from clients. Copies may be made of relevant documents. Originals are kept securely and returned to clients as soon as possible.
• • Client information is stored securely and protected from unauthorised access. Employees and volunteers only access information required to perform their work.
• • Client information is disclosed to a third party on a “need to know” basis where clients have given informed consent to the disclosure or where disclosure is required by law.
• • Communication with clients, regardless of the medium, is conducted in a confidential manner.
• • After a period of inactivity of seven years, clients' paper and electronic records are destroyed and their contact information, street address and immigration number are removed from the Organisation's database. Names, country of residence, date of birth and record of services may be stored indefinitely for the purposes of statistical analysis. Documents purged of identifying information may be kept for training purposes.

Procedures - 1) Collecting Information

Location

Staff will meet with clients in a private space such as meeting rooms and staff offices. For non-sensitive issues only, staff may meet clients in a quiet public space or shared office, provided there are no other clients present and that the clients give consent.

If data is inputted in an open office area, precautions are taken to ensure that monitors are not able to be viewed easily by unauthorized persons. Computers are locked when left unattended, even for short periods of time.

Policy Communication

Clients are informed of the Organisation’s confidentiality policy before the information is collected and before services are delivered. Clients are informed that:

• • Personal information such as contact, immigration status, date of birth and date of arrival are required by funders. Copies of the IRCC brochure Gathering information to better meet the needs of newcomers to Canada are available in the language of their choice.
• • Information is shared with supervisors and other staff involved in service delivery.
• • No information is shared with third parties without informed consent or where there is reason to suspect harm to self, harm to others or harm to children.

Type of Information

Information is collected directly from the client, except in the case of minors or where clients consent to others speaking on their behalf. Staff confirm that information is accurate, up-to-date and complete.

Regardless of what information a client discloses, only information relevant to the delivery of the client service is collected. The type of information required will depend on the service being delivered. For all services, staff collect at minimum:

• • Full, legal name
• • Contact information
• • Address
• • Date of Birth
• • Country of Birth
• • Date of Arrival in Canada
• • Immigration Status
• • Immigration Number

Clients may choose to remain anonymous or refuse to disclose personal information. Due to funder requirements, not all services may be accessed by clients who do not disclose required information (e.g. language assessments). All data for anonymous client will be recorded in the database, using the established contact "Anonymous".

If there are safety concerns, staff disable the Safe to Contact field in the Contact form in the database and instead include contact details in the comments section. This prevents the possibility of accidental contact (e.g. a query for client emails for the purposes of sending a survey).

Case Notes

Case notes contain sufficient detail for supervisors to clearly understand the client’s situation and the services provided to the client. For particularly sensitive issues, supervisors can place a security lock on the case notes.

Procedures - 2) Storing Information

Secure Spaces

Client information is stored securely. Secure spaces include rooms, drawers and filing cabinets that are locked, and password-protected computers that are not left unattended.

Client information is stored on the shared drive, not on hard drives of individual staff computers, on staff drives, or on public or personal computers. Confidential information is never stored on email or email calendars. Client information may be stored on Google Drive or other secure shared networks when the shared drive is not appropriate; however, permission to share the document will not be given to any individual who is not an employee of the Organisation.

The Executive Director will record which staff have remote access to the shared drive. Staff will store laptops and phones in secure, off site locations.

Client Files

Individual files are created for all clients. Client files, including resumes, applications and case notes, are the property of the Organisation.

All general client information (e.g. date of birth) and client service records are stored in the Organisation's database. Resumes, applications and scanned documents (e.g. immigration records) are stored in the Client section of the shared drive. Paper files are only created when documents must be stored for funders (e.g. language assessment booklets) and are stored in centralised, locked filing cabinets. Cabinet keys are kept in a secure location.

Files, regardless of type, are clearly labeled and organized. Access to client files is limited to employees who work directly with clients.

Where required for service delivery, staff may make copies of identity or other documents with the consent of the client, provided the original is returned to the client as soon as possible. Where original documents are forgotten or otherwise cannot reasonably be returned, they will be kept in a secure location; important identity documents such as passports will be kept in the Executive Director's safe.

Procedures - 3) Accessing Information

Staff Access

Staff may access client information where required to provide services or collect/tabulate data. If data is accessed in an open office area, precautions are taken to ensure that monitors are not able to be viewed easily by unauthorized persons. Computers are locked when left unattended, even for short periods of time.

Volunteer Access

Volunteer access to client information is restricted to volunteers who require access to fulfill their volunteer role, who have signed a confidentiality oath and who have reviewed a copy of this policy. Placement students or volunteers providing direct services to clients work under a staff member who will take responsibility for protecting confidentiality.

Client Access

Clients may request:

• • A list of any documents or applications on file
• • Copies or destruction of any personal documents or applications on file, excepting records required by funders (e.g. language assessments)
• • A record of services that includes date of service and description of service.

Clients may not access:

• • Staff notes, assessments and observations
• • Information in their file pertaining to another client (e.g. from a shared service).

Requests normally are fulfilled within one business week but may take longer for large files.

Procedures - 4) Releasing Information

Client information is disclosed to a third party on a “need to know” basis where the client has given informed consent.

Age

Consent is obtained directly from the client or, for minors under 14 years of age, from the parent or legal guardian.

Extent

Clients are told what information will be discussed with the third party and the criteria of the service to which they are being referred. Where possible, staff work with clients to initiate partner referrals together and agree on what information needs to be shared. However, another important consideration in sharing information is not withholding information that the service provider needs to know, if they are to fulfil their duty of care to the client and other clients within the service. For instance, if the client has a violent background (they may have been charged by police), and staff are referring them to an accommodation service, then the service has a right to know that information. This is for the safety of other clients in the service. Similarly, if the client has a mental illness, the service may need to know so they can ensure the client receives adequate care and access to a specialist service if required.

Consent is limited to the minimum number of individuals and organisations and the shortest period of time required to allow for service delivery. The period of consent cannot be greater than 6 months, but consent can be renewed if required for service delivery. The consent form contains full details on who the consent is for, the purpose (and limitation) of the consent, and how long the consent will last.

“Blanket” consent - approval is where the client gives broad approval for disclosure of information to multiple stakeholders– is not used unless effective service delivery would not otherwise be possible. The most typical exception is for newly arrived Government Assisted Refugees with multiple complex issues and language barriers who benefit from coordination with large numbers of volunteers and partner agencies. In these situations staff explain clearly to clients, partners and volunteers that the period of “blanket” consent is limited and will not be extended unless clearly required. “Blanket” consent is replaced with individual consent with volunteers or partners who continue to collaborate in service delivery.

The staff person who initiates the consent is responsible for monitoring the end of the consent period.

Form

Consent may be given verbally or in writing. In either case, clients are entitled to receive a printed or electronic copy of the consent. Another organisation may obtain consent on behalf of a client to speak with both organisations, provided the Organisation is clearly named in the consent and the consent is signed by the client. All consent forms are recorded in the Organisation's database.

Procedures - 5) Breaches of Confidentiality

There are two situations in which an employee or volunteer is legally required to breach client confidentiality: Duty to Report under the CFSA, and court orders. The Organisation also allows for a breach of confidentiality to avert an imminent risk of serious bodily harm to an identifiable person or group.

Duty to Report - CFSA

Section 72 of the Child and Family Services Act (CFSA) imposes a statutory duty on every person, including a person who performs professional or official duties with respect to children, to forthwith report reasonable suspicions of a child in need of protection, and the information upon which those suspicions are based, directly to the Children’s Aid Society (CAS).

• • Who is a child in need of protection?

  The CFSA defines a child in need of protection as a child who appears to be enduring physical, sexual abuse, emotional abuse, neglect, and/or risk of harm.

  The CFSA applies to any child who is under the age of 16 years. It also applies to children already under a child protection order who are 16 and 17 years old.

• • What is reasonable suspicion?

  It is not required that a person be absolutely certain that a child is or may be in need of protection to be responsible to report under the CFSA. All that is required is that a person have reasonable grounds, referring to the information upon which the suspicion is based, that an average person using normal and honest judgement would need in order to decide to report to the CAS. It is then the responsibility of the CAS to assess the information upon which the suspicion is based. The CAS will investigate the information and then has the authority and responsibility to decide how to proceed.

  Even if an individual knows a report has already been made about a child, they must make a further report to the CAS if there are additional reasonable grounds to suspect that the child is or may be in need of protection.

  Staff may discuss a case hypothetically with Children’s Aid, who will determine if there is a sufficient basis to warrant further assessment of the concerns about the child and if there is a duty to report.

Court Order

• • What is a subpoena?

  A subpoena is a document that most often orders a witness to attend at proceedings. The subpoena will set out the time, date and place of the required attendance. Usually, the subpoena also directs the witness to bring "any documents or materials which are relevant to the action."

  Contacting the legal counsel who served the subpoena is typically a useful first step in determining what is required. Serious sanctions can be imposed if a subpoena is ignored.

• • Does a subpoena influence the responsibility to maintain client confidentiality?

  A subpoena is not authorization to breach client confidentiality. It is a command to attend. A subpoena alone does not grant employees authority to speak to the lawyer who issued the subpoena or to agents such as police officers about the contents of client records or any aspect of a client’s case before appearing in court.

  If the subpoena requires, employees must bring the original paper records or a printout of any electronic records with them to court and be prepared to release them (or a copy) when a direction is issued by a court or a judge requiring an individual or the Organisation to do so. Only the information specified in the order should be provided.

Imminent Harm

The only other situation in which the Organisation would consider a breach of confidentiality is to avert an imminent risk of serious bodily harm to an identifiable person or group. All such cases should be reported to a supervisor, who will assess the risk and make a determination on how to proceed. In the case of immediate threat, staff will CALL 911 and take the appropriate emergency response measures.

The degree to which confidentiality is breached, self-determination is usurped, and outside intervention is imposed should be directly related to the seriousness of the threat and the vulnerability of the client.

Suicidal risk factors include:

• • Suicidal ideation
• • Recurrent, chronic major depressive episodes
• • Previous suicide attempts and hospitalization
• • Knowing others who have committed suicide
• • Relational, social or economic losses
• • Age (15-24, 50 and over)
• • Physical illness and disability
• • High isolation, stigma and isolation
• • Immediate access to methods of self-harm

High-Risk Behaviours (Violence Potential) include but are not limited to:

• • Specific threats with details (who what how)
• • Repeated threats
• • Past history of violence
• • Possession of weapons
• • Aggressive behavior

Unauthorized Breach of Confidentiality

Employees concerned about a co-worker’s conduct should refer to the Dispute Resolution section of HR Policy # 2 for guidance. In addressing unauthorized breaches of confidentiality, supervisors should refer to the Discipline section of HR Policy # 5.

All attempts or occurrences involving actual or potential unauthorized access to client information is immediately reported to Executive Director.

Procedures - 6) Communicating Information

Once appropriate access and consent is determined, care should still be made in how, when and where information is communicated.

General The preferred methods of communicating confidential information are through phone, in-person meetings, hard copy documents, USB drives, or Google Drive or other secure shared networks. For Google Drive and other shared networks, permission to share the document will not be given to any individual who is not an employee of the Organisation. Confidential information is shared through email and email calendars only when necessary and is limited to essential information; under no circumstances are SIN numbers, bank information or credit card information communicated via email. Confidential information is only shared via fax to known and trusted organisations.

Partners

Staff provide only facts and refrain from communicating personal opinions and judgments so that staff at other agencies can form their own relationship without being influenced by another’s perceptions.

Staff and Volunteers

Discussions about clients are in the furtherance of service-delivery or client well-being. Discussions are held only with supervisors, or staff or volunteers directly involved in service delivery. Discussions are held in private areas, not public areas inside or outside of the agency (e.g. reception, kitchen area, parking lot) where others not directly involved in the service can hear the conversation.

Clients

Discussions with clients, including phone calls, are held in private spaces. Voicemails, text, email calendars and emails do not reference highly sensitive or confidential information.

Clients who request that information be kept confidential are informed of the Organisation’s confidentiality policy as it applies to their situation. There are no secrets between staff and clients.

Procedures - 7) Destroying Information

The following information will be deleted and / or destroyed when clients have not accessed services, volunteered or contacted the Organisation for a period of seven years:

• • Phone number(s)
• • Email(s)
• • Unit, Street Number, and Street Name
• • Immigration Number
• • Copies of immigration and identity documents
• • Immigration and other service applications

All other client information shall be kept indefinitely.

All paper documentation is shredded. Electronic copies are deleted. Electronic copies contained in system-backup media are maintained in confidence and are not readily accessible to users.