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The Canadian Hard of Hearing Association-Newfoundland and Labrador (CHHA-NL) (also known in this document as CHHA-NL or the association), is committed to safeguarding the personal information entrusted to the association by its clients. Your personal information is managed in accordance with the Federal Privacy Act for private entities called the Personal Information Protection and Electronic Documents Act (PIPEDA), the Provincial Privacy Act for public entities called the Access To Information and Personal Privacy Act (ATIPPA), and other applicable laws. This policy outlines the principles and practices CHHA-NL follows in protecting your personal information.

This policy applies to the Canadian Hard of Hearing Association-Newfoundland and Labrador (CHHA-NL) and to any persons providing services on behalf of the association.

What is personal information?

Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, educational history, etc.

What personal information does CHHA-NL collect?

CHHA-NL collects only the personal information that is need for the purposes of providing services to clients, including personal information needed to:

  • deliver requested products and services
  • enroll a client in a program
  • send out association membership information

The association normally collects client personal information directly from its clients, but may collect your information from other persons with your consent or as authorized by law.

The association informs its clients, before or at the time of collecting personal information, of the purposes for which such information is being collected. The only time this notification isn’t provided is when a client volunteers information for an obvious purpose (for example, producing a credit card to pay a membership fee when the information will be used only to process the payment).

Consent

The association asks for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. The association may assume your consent in cases where you volunteer information for an obvious purpose.

The association will assume your consent to continue to use and, where applicable, disclose personal information that we have already collected, for the purpose for which the information was collected.

The association will ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, clients will normally be asked to provide their consent orally (in person, by telephone), or in writing (by signing a consent form).

In cases that do not involve sensitive personal information, the association may rely on “opt-out” consent. For example, the association may disclose your contact information to other organizations that it believes may be of interest to you, unless you request that the association not disclose your information. You can do this by checking the appropriate box on the client information form or by telephoning the associaiton’s local number/toll-free number which is 709-753-3224.

A client may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for the association to fulfill its legal obligations. The association will respect your decision, but may not be able to provide you with certain products and services if it does not have the necessary personal information.

The association may collect, use or disclose client personal information without consent only as authorized by law; for example, the association may not request consent when the collection, use or disclosure is to determine suitability for an honour or award, or in an emergency that threatens life, health or safety.

How does CHHA-NL use and disclose personal information?

The association uses and discloses client personal information only for the purpose for which the information was collected, except as authorized by law; for example, it may use client contact information to deliver goods.

If the association wishes to use or disclose your personal information for any new business purpose, it will ask for your consent, however, it may not seek consent if the law allows this (e.g. the law allows organizations to use personal information without consent for the purpose of collecting a debt).

What is personal employee information?

Personal employee information is personal information about an employee or volunteer which is collected, used or disclosed solely for the purposes of establishing, managing or terminating an employment relationship or a volunteer work relationship. Personal employee information may, in some circumstances, include a Social Insurance Number, a performance review, etc.

The association can collect, use and disclose your personal employee information without your consent only for the purposes of establishing, managing or ending the employment or volunteer relationship. The association will provide current employees and volunteers with prior notice about what information it will collect, use or disclose and the purpose for doing so.

What personal employee information does CHHA-NL collect, use and disclose?

The association will collect, use and disclose personal employee information to meet the following purposes:

  • Determining eligibility for employment or volunteer work, including verifying qualifications and references
  • Establishing training and development requirements
  • Assessing performance and managing performance issues if they arise
  • Administering pay and benefits (paid employees only)
  • Processing employee work-related claims (e.g. benefits, workers’ compensation, insurance claims) (paid employees only)
  • Complying with requirements of funding bodies (e.g. lottery grants)
  • Complying with applicable laws (e.g. Canada Income Tax Act, Alberta Employment Standards Code)

The association will only collect, use and disclose the amount and type of personal employee information that is reasonable to meet the above stated purposes. The following is a list of personal employee information that it may collect, use and disclose to meet those purposes.

  • Contact information such as your name, home address, telephone number
  • Criminal background checks
  • Employment or volunteer information such as your resume (including educational background, work history and references), reference      information and interview notes, letters of offer and acceptance of      employment, policy acknowledgement forms, background verification information, workplace performance evaluations, emergency contacts, etc.
  • Benefit information such as forms relating to applications or      changes to health and insurance benefits including medical and dental care, life insurance, short and long term disability, etc. (paid employees only)
  • Financial information, such as pay cheque deposit information and      tax-related information, including Social Insurance Numbers (paid      employees only)
  • Other personal information required for the purposes of our employment or volunteer relationship

The association will inform its employees and volunteers of any new purpose for which it will collect, use, or disclose personal employee information, or it will obtain your consent, before or at the time the information is collected. It will also obtain your consent to collect, use and disclose your personal information for purposes unrelated to the employment or volunteer relationship (e.g. such as providing you with information about a workplace charity or similar program).

What information does CHHA-NL provide for employment/volunteer references?

In some cases, after your employment or volunteer relationship with the association ends, it will be contacted by other organizations and asked to provide a reference for you.  It is the association’s policy not to disclose personal information about its employees and volunteers to other organizations who request references without consent. The personal information that it will normally provide in a reference includes:

  • Confirmation that an individual was an employee or volunteer, including the position, and date range of the employment or volunteering
  • General information about an individual’s job duties and information about the employee or volunteer’s ability to perform job duties and success in the employment or volunteer relationship

How does CHHA-NL safeguard personal information?

The association will make every reasonable effort to ensure that personal information is accurate and complete. It will rely on individuals to notify the association if there is a change to their personal information that may affect their relationship with the association. If you are aware of an error in the information the association holds about you, please make it known, and it will correct the information on request wherever possible. In some cases the associaiton may ask for a written request for correction.

The association will protect personal information in a manner appropriate for the sensitivity of the information and will make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.

The association will use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records and will retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.

Access to records containing personal information

Individuals have a right to access their own personal information in a record that is in the custody or under the control of the Canadian Hard of Hearing Association-Newfoundland and Labrador (CHHA-NL), subject to some exceptions. For example, organizations are required under PIPEDA and ATIPPA to refuse to provide access to information that would reveal personal information about another individual.

If the association refuses an information request in whole or in part, it will provide the reasons for the refusal. In some cases where exceptions to access apply, it may withhold that information and provide you with the remainder of the record.

You may make a request for access to your personal information by writing to the Executive Director of CHHA-NL. You must provide sufficient information in your request to allow the association to identify the information you are seeking.

The association will respond to your request within 45 calendar days, unless an extension is granted and may charge a reasonable fee to provide information, but not to make a correction. The association does not charge fees when the request is for personal employee information and you will be advised of any fees that may apply before beginning to process your request.

Questions and Complaints

If you have a question or concern about any collection, use or disclosure of personal information by Canadian Hard of Hearing Association-Newfoundland and Labrador (CHHA-NL), or about a request for access to your own personal information, please contact the Executive Director of CHHA-NL, the person who is designated to ensure compliance with PIPEDA and ATIPPA.

If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Newfoundland and Labrador at:

Mailing Address:

2nd Floor, 34 Pippy Place

P.O. Box 13004, Station A

St. John’s, NL

A1B 3V8

Contact Numbers:

Telephone: (709) 729-6309

Facsimile:  (709) 729-6500

Toll Free in Newfoundland and Labrador: 1-877-729-6309

E-mail: commissioner@oipc.nl.ca

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