Privacy Policy

1. LIFE*SPIN ensures the privacy of people with whom it does business (clients, customers, tenants), members of the Board, staff, and volunteers.

2. LIFE*SPIN has a privacy management plan with rules for the collection, storage, use, and retention of personal information:
   a. as set out in this chapter, and
   b. in compliance with the Personal Information Protection in Electronic Documents Act (PIPEDA).

3. Personal information includes, but is not limited to:
a. name(s) of the individual(s), their partner(s), and children
b. home address(es)
c. telephone number(s) and email address(es)
d. Social Insurance Number(s) and other numerical identifiers
e. financial information
f. records of interventions by LIFE*SPIN in the affairs of these individual(s)

4. LIFE*SPIN collects and uses no more personal information than:
a. it needs to carry out its work, or
b. may be required by law.

5. The consent of the individual(s) concerned is obtained for the collection, use, or disclosure of personal information, except where required by law or is otherwise inappropriate.
6. Parents and legal guardians may give consent on behalf of children or others legally in their care.
7. Before or at the time they are asked to give consent, individual(s) are told:
a. why the information is needed
b. how it will be used
c. to whom it might have to be disclosed
8. A record is made of each instance of consent.

9. LIFESPIN makes all reasonable efforts to get the further consent of the individual(s) concerned when personal information:
a. is used for any purpose except that for which it was originally obtained, and
b. must, for operational reasons, be disclosed to third parties, notably in advocacy, except as may be required by law or for other valid reason.
10. When personal information must, for operational reasons, be shared with a third party, LIFESPIN ensures that this party meets its standards for privacy, confidentiality, and security.

11. Case files ordinarily contain:
a. an intake sheet
b. a record of the consent provided by the individual(s) concerned
c. relevant documentation
d. a record of action taken
e. the date of closure

12. Care is taken to ensure the accuracy of personal information collected by LIFE*SPIN.

13. Members of the Board, staff, and volunteers are:
a. given access by the Executive Director to only such personal information as they need to:
i. carry out their duties, or
ii. comply with the law
b. subject to LIFESPIN’s Confidentiality Policy (Part C, Chapter 5).
14. Personal information, whether on paper or in digital form, is stored in a physically secure manner, with password protection and/or encryption for digital files, to prevent unauthorized access, use, disclosure, or disposal.
15. Confidential documents may not be removed from LIFESPIN’s premises in any form (paper or digital), except as:
a. required for operational reasons (notably when advocacy calls for meetings out of the office), and
b. authorized by the Executive Director.

16. Personal information is retained no longer than needed for its intended use.
17. Personal documents on file, whether paper or electronic, are:
a. returned to the individual(s) concerned, or
b. when this is not possible, destroyed by LIFE*SPIN no less than 60 days after the file is closed.

18. Individual(s) who have provided personal information to LIFE*SPIN are entitled, with reasonable notice, to inspect their files.
19. Access to a record may be subject to payment of a fee.

20. Individuals who have provided personal information may challenge LIFESPIN’s compliance with the rules set out by PIPEDA and in this chapter.
21. A copy of this policy is provided to a complainant at the earliest opportunity.
22. A record is kept of all documents associated with a complaint.
23. A challenge is dealt with by the Executive Committee through the complaints policy set out in Part C, Chapter 1.
24. While a client’s request to amend or remove information or documents on file is given sympathetic consideration, LIFESPIN reserves the right to determine what it needs to carry out its work on the client’s behalf.
25. If no agreement can be reached under Section 24, LIFE*SPIN may close a case.

26. On request, LIFE*SPIN makes this policy available to the public.

27. The Executive Committee of the Board acts as the compliance coordinator for purposes of PIPEDA.