Privacy Policy and Accessibility Policy

Privacy Policy
Our Privacy Commitment to You
CONTACT – CONTACT Community Services is committed to keeping your personal information accurate, confidential, secure and private.
When you visit our website, contact us, participate in one of our programs, or make a donation to support our activities, we are committed to protecting your privacy rights and your personal information.
CONTACT’s privacy policy is based upon the 10 Privacy Principles contained within the Canadian Standards Association (CSA) Model Privacy Code for the Protection of Personal Information and reflects the requirements of applicable legislation including the Freedom of Information and Protection of Privacy Act (FIPPA).
This Privacy Policy describes the principles CONTACT will use to protect the privacy of your personal information in its possession. It addresses the reasons why such information is collected, how it is used, how it’s confidentially protected and outlines your rights with respect to this information.
This privacy policy is applicable to our Customers, Community Partners, Donors, Volunteers and Employees.
Personal information is defined as any factual or subjective information, recorded or not, about an identifiable individual. Examples are age, name, source of income, home addresses and telephone numbers. Personal information does not include the name, title, or business address or telephone number of an employee of an organization.
CONTACT’s Privacy Principles
Accountability
- CONTACT is responsible for the protection of personal information collected through offices, program activities and website.
- This policy applies to all staff including employees and volunteers as well as any third- party contractors who may have access to personal information, all of whom sign a confidentiality agreement.
- CONTACT’s Privacy Officer, the Executive Director, leads the implementation of this policy.
Identifying purposes
- Staff explain the purpose(s) for the collection of personal information wherever possible before asking for it.
- Staff collect personal information:
- to assess, develop, improve, evaluate, schedule, deliver and share information about services
- to satisfy legal, government and regulatory obligations
- to assess the suitability of staff and potential staff to fulfil a staff role or take on certain responsibilities
- for fundraising purposes
- CONTACT uses video cameras to promote safety and to document events that could put people, programs, equipment, and facilities at risk. Public signage is displayed at each of the camera’s locations to inform people that cameras are in place. In addition to any contracted organization for IT and programming purposes only, access to camera footage is available only to the Executive Director and designates as required.
- CONTACT does not sell personal information collected.
Consent & disclosure
- CONTACT only collects personal information with people’s knowledge and consent.
People can choose not to disclose any personal information requested. However, a decision to withhold personal information can result in the inability to undertake the intended activity (e.g., providing services).
- People can withdraw consent to the collection, use or disclosure of personal information at any time, subject to any legal requirements and reasonable notice.
Limiting collection
- The amount and type of information that CONTACT collects is limited only to that which is necessary to fulfill the purposes identified.
- CONTACT asks for the information it requires directly from the individual.
- CONTACT collects personal information using procedures which are fair, transparent and lawful.
Limiting use, disclosure and retention
- CONTACT uses personal information only for the purposes for which it was collected, and the person has consented.
- CONTACT may use personal information without the person’s consent, where:
- the organization has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation
- an emergency exists that threatens an individual’s life, health or security
- the information is for statistical study or research
- the information is publicly available
- the use is clearly in the individual’s interest, and consent is not available in a timely way
- knowledge and consent would compromise the availability or accuracy of the information
- collection is required to investigate a breach of an agreement.
- CONTACT may disclose personal information to third parties, without an individual’s
knowledge and consent, to:
- a lawyer representing CONTACT
- collect a debt owed to CONTACT by the individual
- comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction
- a law enforcement agency in the process of a civil or criminal investigation
- a government agency or department requesting the information
- as required by law.
- CONTACT may transfer personal information to a third party, without the individual’s
knowledge or consent, if the transfer is simply for processing purposes and the third party only uses the information for the purposes for which it was transferred. CONTACT will ensure, by contractual or other means, that the third party protects the information and uses it only for the purposes for which it was transferred.
- CONTACT retains personal information only as long as necessary to fulfill the purposes for which it was collected, and in compliance with any laws surrounding information retention. Generally, this means information in inactive files is retained for seven years. When all identified purposes for the use of your personal information have been exhausted, staff destroy the information or render it unidentifiable.
Accuracy
- To ensure the reliable delivery of services and information, CONTACT keeps personal information accurate, complete and up to date.
- Staff assume that the information that people provide is accurate. If at any time people’s personal information changes, staff hope to be informed of it immediately. When requested, staff take appropriate steps to update or correct the personal information.
Safeguards
- CONTACT employs several safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards include administrative, physical and technological measures such as locked filing cabinets, restricted access to offices, limiting access on a “need to know” basis, requiring staff to maintain clean desks and use of passwords and encryption.
- CONTACT provides training on these measures to all staff to ensure compliance with this principle.
Openness
- CONTACT has easily understandable and readily available specific information about its policies relating to the management of personal information. This policy is always available on CONTACT’s website.
- In the event of a policy breach, staff must provide information about the breach and the Privacy Officer’s contact information to the person whose information has been breached.
Individual access
- Upon request, staff inform people of any personal information and what purposes it is used for, if applicable.
Tina de los Santos
Privacy Officer
CONTACT Community Services
39 Victoria Street East
P.O. Box 932 Alliston, Ontario L9R 1W1
The Privacy Officer will respond within thirty (30) days after receipt of your written request or will notify if a longer period is required to fully address the request, provided that an extension of the thirty (30) day period is permitted by applicable privacy laws.
Challenging compliance
- If, for any reason, a person is concerned about CONTACT’s compliance with this Privacy Policy, they may contact the Privacy Officer in writing, by phone or by email:
Tina de los Santos
Privacy Officer
CONTACT Community Services
Community Service Centre South Simcoe
Town Square, 39 Victoria Street East
P.O. Box 932 Alliston, Ontario L9R 1W1
Phone: (705) 435-4900 Email: emily@contactcommunityservices.ca
If they are not satisfied with the way CONTACT has responded to a complaint, they can contact the Privacy Commissioner of Canada.
The Privacy Commissioner of Canada Website: www.priv.gc.ca
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario K1A 1H3
Toll Free 1-800-282-1376
Email notification@priv.gc.ca
CONTACT’s Accessibility Policy
Purpose
- To ensure that people with disabilities can fully participate in and contribute to CONTACT’s activities
Areas of risk
- Equity
- Legal
- Safety
Legislative / regulatory compliance
- Accessibility for Ontarians with Disabilities Act
- “Every obligated organization shall develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements referred to in this Regulation.”
- Blind Persons’ Rights Act
- Canadian Charter of Rights and Freedoms
- Ontario Human Rights Code
Policy
- CONTACT is committed to ensuring equal access and participation for people with disabilities and to treating people with disabilities in a way that allows them to maintain their dignity and independence. CONTACT believes in integration and is committed to meeting the needs of people with disabilities in a timely manner by removing and preventing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act (AODA).
- CONTACT is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code (OHRC) respecting non-discrimination (also see Policy M: Equity and diversity).
- CONTACT understands that obligations under the AODA and its accessibility standards do not substitute or limit its obligations under the OHRC or obligations to people with disabilities under any other law.
- CONTACT is committed to excellence in serving and providing goods, services or facilities to all clients including people with disabilities. This policy is consistent with the principles of independence, dignity, integration and equality of opportunity for people with disabilities.
- CONTACT is committed to training all staff in accessible customer service, Ontario’s accessibility standards and aspects of the Ontario Human Rights Code that relate to persons with disabilities. In addition, CONTACT trains:
- all persons who participate in developing the organization’s policies
- all other persons who provide goods, services or facilities on behalf of the organization.
- Training of our staff on accessibility relates to their specific roles. Training includes:
- purpose of the AODA and the requirements of the Customer Service Standards
- policies related to the Customer Service Standards
- how to interact and communicate with people with various types of disabilities
- how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
- how to use any equipment or devices available onsite or otherwise that may help with providing goods, services or facilities to people with disabilities
- what to do if a person with a disability is having difficulty in accessing our organization’s goods, services or facilities.
- CONTACT trains every staff member as soon as practicable after being hired/retained and provides training in respect of any changes to the policies.
- CONTACT maintains records of the training provided including the dates on which the training was provided and the names of individuals to whom it was provided (also see Policy W: Required training).
- People with disabilities may use their personal assistive devices when accessing goods, services, or facilities. In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures are used to ensure the person with a disability can access goods, services, or facilities.
- Staff communicate with people with disabilities in ways that account for their disability. Staff work with the person with disabilities to determine what method of communication works for them.
- CONTACT welcomes people with disabilities and their service animals. Service animals are allowed on the parts of the premises that are open to the public and third parties. When staff cannot easily identify that an animal is a service animal, they may ask for documentation (template, letter, or form) from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability. If service animals are prohibited by another law, staff do the following to ensure people with disabilities can access our goods, services, or facilities:
- explain why the animal is excluded
- discuss with the client another way of providing goods, services or facilities.
- A person with a disability who is accompanied by a support person is allowed to have that person accompany them on premises or whenever receiving services or otherwise participating in CONTACT activities at no cost. In situations where confidential information might be discussed, staff obtain consent from the client that the support person can be privy to such information.
- In certain cases, this organization might require a person with a disability to be accompanied by a support person for the health or safety reasons of:
- the person with a disability
- others on the premises.
- Before deciding, staff:
- consult with the person with a disability to understand their needs
- consider health or safety reasons based on available evidence
- determine if there is no other reasonable way to protect the health or safety of the person or others on the premises.
- In the event of a planned or unexpected disruption to services or facilities for clients with disabilities, staff notify clients promptly. This clearly posted notice includes information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available. The notice is made available on the CONTACT website, Facebook, Instagram, LinkedIn and Twitter accounts as well as on outgoing telephone messages and signage at the entrances to all In addition, staff attempt to contact clients with appointments who may require this information.
- CONTACT considers accessibility for people with disabilities when acquiring self-service kiosks.
- When asked, staff provide information about CONTACT Community Servies and its services and facilities, including public safety information, in accessible formats or with communication supports:
- in a timely manner, considering the person’s accessibility needs due to disability
- at no cost.
- Staff consult with the person making the request in determining the suitability of an accessible format or communication support. If the organization determines that information or communications are unconvertible, staff provide the requestor with
- an explanation as to why the information or communications are unconvertible
- a summary of the unconvertible information or communications.
- CONTACT’s website meets internationally recognized Web Content Accessibility Guidelines (WCAG) 2.0 Level AA website requirements in accordance with Ontario’s accessibility laws.
- CONTACT meets accessibility laws when building or making major changes to public spaces (e.g., parking, service counters, waiting areas)
- CONTACT posts this policy on its website and provides this policy to clients in an accessible format or with communication support on request. Staff consult with the person making the request to determine the suitability of the format or communication support. Staff provide the accessible format in a timely manner and at no cost.
- CONTACT welcomes feedback on how staff provide accessible customer service. Client feedback helps to identify barriers and respond to concerns. Clients may provide feedback by writing Executive Director, CONTACT, 39 Victoria Street South, Alliston ON L9R 1W1 or by calling (705) 435-4900 ext. 202 or by emailing contact@contactcommunityservices.ca. (See also Policy E: Complaints). The Executive Director reviews all feedback including complaints. Clients can expect to hear back in 15 days. CONTACT ensures the feedback process is accessible to people with disabilities by providing or arranging for accessible formats and communication supports, on request.