Confidentiality Policy

OPERATING STANDARD: C1-1C

 

RATIONALE:

The Club will protect the privacy and maintain the confidentiality of its employees, contract workers, members, clients, donors, volunteers and stakeholders. The Club will comply with the Personal Information Protection Act (PIPA) and the Freedom of Information and Protection of Privacy Act (FOIPPA or FIPPA).

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POLICY:

All confidential information pertaining to Children & Youth and their families will be kept secure at all times. This includes information about medical conditions, family status (including marital, financial and educational status), personal information (including telephone numbers and addresses), personal concerns or issues, or delicate matters regarding a child and their family.

 

PROCEDURE:

1. Employee and volunteers are trained how to handle confidential information and the definition of what constitutes “confidential” information. Training includes reference to Privacy Legislation (PIPA and FOIPPA) and the obligation to protect personal privacy. Procedures for protecting private information are documented and include:

a. Restricting access to confidential filing systems, including computerized data banks through use of security passes and computer user passwords.

b. Securing files, attendance forms, registration binders or any paper records that contain confidential information, so they are not accessible or left unattended in program and public areas.

c. Properly destroying and disposing of paper that contains confidential information through methods such as paper shredding.

d. Refraining from engaging in casual conversations about participants and their families with third parties such as other participants and parents, teachers, personal acquaintances, Employee and volunteers not directly involved in the leadership or supervision of the program.

e. Use of polite discretion when dealing with third parties who may wish to learn about confidential matters.

f. Taking precautions such as moving participants when there is a need to discuss confidential information or a concern about a child or family with an appropriate person as a co-leader.

g. Prohibiting the removal of confidential records from the program premises unless required by the Club or officials with legal entitlement.

h. In special circumstances where a release of confidential information has been formally requested by the Club, a parent/legal guardian or a third party, procedures for releasing information are in place. When appropriate, parents/legal guardians are required to discuss the matter with the program supervisor and sign a “consent for release of confidential information” form which specifies the nature of the information that is to be shared.

i. Supervisors should monitor Employee and volunteer’s ability to handle confidential information appropriately.

 

Confidentiality Agreement

1. All Employee, volunteers, and contract personnel will sign a Confidentiality Agreement (see Confidentiality Agreement Form). By signing, they agree to observe confidentiality related to written records of employee or participant information as well as discussions related to employees, volunteers, or participants.

a. All personal, financial or business information obtained during provision of service shall be treated as confidential.

b. Personal information may be released to third parties only with the written or documented verbal consent of the participant or employee or their parent/guardian if the participant is a minor.

c. Employees and volunteers are expected to use discretion in discussing matters related to the Club’s activities with people outside the Club.

d. Employee members not involved with a participant are not permitted access to information concerning that participant unless permission is granted by the Executive Director.

e. Demands for disclosure by the police, courts or other mandated bodies will require official documentation to be presented by the party requesting the information. Any information released must be approved by the Executive Director.