Statement and Purpose
ENCOMPASS Benefits respects and upholds an individual’s right to privacy and to protection of his or her personal information. ENCOMPASS Benefits is committed to collecting, using and disclosing personal information in a manner which complies with applicable privacy legislations.
The Policy sets out the principles, which will be observed by ENCOMPASS Benefits with respect to the collection and use, and disclosure of information about any identifiable individual who is a client of ENCOMPASS Benefits. If personal information is made anonymous by removing details so that an individual is not identifiable, it is not governed by this Policy but will still be treated with appropriate safeguards.
Definition of a “Client” is a person who uses, or applies to use any services of ENCOMPASS Benefits.
Principles and Implementation
ENCOMPASS Benefits is responsible for all personal information under its control. Its Privacy Officer is accountable for ENCOMPASS Benefits’s compliance with the principles described in this Policy.
Upon request, ENCOMPASS Benefits will disclose the name of the current Privacy Officer.
Under this principle, ENCOMPASS Benefits is responsible not only for personal information in its physical possession or custody, but also for personal information that is transferred by ENCOMPASS Benefits to a third party for processing. ENCOMPASS Benefits will use contracts with such third parties to require them to give an appropriate level of protection to the personal information while it is being processed.
ENCOMPASS Benefits has established and implemented:
a) Procedures to protect personal information;
b) Procedures to receive and respond to complaints and inquiries;
c) Staff training and information programs to explain this Policy and related privacy policies and practices;
d) Practices to ensure that clients who contact ENCOMPASS Benefits have access to this Policy.
2. Purposes for Collection, Use, and Disclosure
The purposes for which personal information is collected will be identified and documented by ENCOMPASS Benefits at or before the time the information is collected.
Personal information will be collected on a “need to know ”basis for the operation of ENCOMPASS Benefits.
Depending on the specific circumstances, ENCOMPASS Benefits may collect personal information concerning clients for one or more of the following purposes:
1. to evaluate the eligibility and suitability of a client to receive ENCOMPASS Benefits CCRR Program services
2. to communicate with clients concerning ENCOMPASS Benefits’s programs and services
3. to comply with legal and regulatory requirements
In the event that ENCOMPASS Benefits wishes to collect personal information for a new purpose, ENCOMPASS Benefits will take reasonable steps to insure that the individual concerned is informed of the new purpose and gives his or her consent to the collection of personal information for the purpose.
The knowledge and consent of the individual, express or implied, are required for the collection, use or disclosure of personal information by ENCOMPASS Benefits, except where inappropriate by law or circumstance. Implied consent may arise through action or inaction on the part of the individual.
ENCOMPASS Benefits will ensure that the client is entitled to easy-to-understand methods for consent. Check off boxes will be used on ENCOMPASS Benefits’s forms for client’s convenience in receiving future Kelowna Child Care communications. If the check off box is not marked by the individual, ENCOMPASS Benefits will be entitled to assume that he or she has consented. When special attention to the issue of consent is required, express consent will be employed.
An individual client may withdraw his or her consent to collection, use or disclosure. ENCOMPASS Benefits shall inform the individual of the likely consequences to the individual of such withdrawal of consent for the continued provision of Kelowna Child Care services.
4. Limited Collection
ENCOMPASS Benefits will limit the amount and type of personal information collected to that which is necessary for the purposes identified by ENCOMPASS Benefits.
5. Limiting Use, Disclosure and Retention
ENCOMPASS Benefits will not use or disclose personal information for purposes other than those for which it was collected, except with consent of the individual or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. Any personal information will be stored in a locked office or cabinet at ENCOMPASS Benefits and will be accessed only on a “need to know” basis.
ENCOMPASS Benefits will make every reasonable effort to ensure that personal information collected by Kelowna Child Care or on its behalf is as accurate and complete as is necessary for the purpose for which it is to be used.
The Kelowna Child Car Society will not routinely update personal information, unless such updating is necessary to fulfill the purposes for which the information is collected.
ENCOMPASS Benefits will generall rely on clients to provide updated information, such as changes to addresses and other contact information.
ENCOMPASS Benefits will make resonable security arrangements to protect personal information.
Safeguard arrangements are employed to protect persoanl information against loss or theft, as well as authroized access, disclosure, copying, use, modification, or disposal. ENCOMPASS Benefits shall protect personal information regardless of the format in which it is held.
The methods of protection employed by ENCOMPASS Benefits will include:
- physical measures, including locked filing cabinets and restirected access to offices;
- organization measures, such as a "clean desk" policy and limiting access on a "need to know" basis;
- technological measures, such as use of passwords and access to electronic files.
ENCOMPASS Benefits will ensure that any individual is able to acquire information about ENCOMPASS Benefits policies and procedures on privacy protection without unreasonable effort. ENCOMPASS Benefits will make this information available in a form that is generally understandable.
9. Individual Access
When requested in writing, ENCOMPASS Benefits shall inform the individual of the existence, use, and disclosure of his or her personal information and the individual shall be given access to that information, except where law requires or permits ENCOMPASS Benefits to deny access.
ENCOMPASS Benefits shall respond to a request in writing as accurately and completely as resonably possible within 30 days after receipt of the request.
10. Challenging Compliance
Any individual can direct complaints concerning ENCOMPASS Benefits compliance with privacy protection to the Privacy Officer. ENCOMPASS Benefits procedures to respond to complaints or inquiries, about ENCOMPASS Benefits handling of personal information, is as follows:
- A complaint must be in writing attention to the Privacy Officer;
- ENCOMPASS Benefits will acknowledge reciept of the complaint in writing promptly;
- ENCOMPASS Benefits will contact the client to clarify the complaint, if necessary;
- ENCOMPASS Benefits will investigate all complaints received;
- ENCOMPASS Benefits will notify the client of the outcome of investigations clearly and promptly, informing them of any relevant steps taken;
- ENCOMPASS Benefits will correct any inaccurate personal information or modify policies and procedures based on the outcome of complaints.
ENCOMPASS Benefits and HR Solutions Inc. is committed to respecting the privacy rights of users accessing and using the website.
It is our policy to obtain clear consent from all persons or organizations who would like to receive our quarterly newsletter and other communique. This subscription is completely voluntary and can be viewed here http://www.encompassbenefits.com/newsletter.php. We may ask organizations if they are interested and give them the option to sign up, but strive not send messages without their consent.
Included in every electronic message sent out to a wide audience will be an option to "opt out" of our communication. An unsubscribe feature is added to each communique we publish, and the recipient is removed from our list immediately.
Our communication is also correctly labeled and advertised with our company name and mailing address. This ensures the honesty and integrity of our messages as we continue to communicate with our clients and other parties.
Our commitment to our clients and our industry is to operate our business in agreement with all Canadian legislation. We are implementing these practices to ensure ENCOMPASS Benefits and HR Solutions fulfills each requirement involved in the Canadian Anti-Spam Legislation, and to have the protection and privacy of clients and customers be a priority in our business.