At SMD, as we go about working with people with disabilities and providing products and services in accordance with our mandate, we need to access and use certain personal information.[NOTE: Not all personal information collected and used by SMD is consumer information, but may belong to other third parties, for example, parents, emergency contacts etc.]
SMD's privacy practices reflect obligations under the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”) and the Freedom of Information and Protection of Privacy Act of Manitoba (‘FIPPA”) as well as the Personal Health Information Act of Manitoba (“PHIA”) regarding the collection, use and disclosure of personal information in all of our activities.
SMD has developed this Privacy Statement in order to explain our best practices in the management of your personal information. We want to share with you the purposes for which we collect personal information and we want to ensure that we continue to have your consent to collect, use and disclose your personal information for these purposes.
The following is a brief summary of our privacy practices.
WHAT is personal information?
Personal information is any information that can be used to identify, distinguish or contact a specific individual. Personal information can include any information or facts about, or related to, an individual, as well as, for example, an individual's opinions or beliefs. Personal information does not include publicly available information (for example, names, addresses and telephone numbers which are published in telephone directories, or professional or business directories, such directories being available to the public) or business contact information (for example, the name, title, business address or telephone number of an employee of an organization.
The type of personal information that SMD must collect and use will depend on the products or services requested by a consumer. We may collect, to varying degrees, the personal information listed below:
- name, address, telephone number, e-mail address, fax number;
- other contact information of the individual, his or her parents or legal guardian(s), if necessary, as well as emergency contact information;
- birth date;
- health care identification numbers;
- nature and onset of disability;
- height, weight, medical diagnosis, and relevant medical history;
- income and employment status and history;
- education, training, job skills;
- health and social service related reports from medical professionals, social workers, therapists, schools, daycare, employers, government agencies, funding sources;
- information about ability levels along with support requirements and current and past support systems; and/or
- national or racial origin.
WHY do we collect personal information, and how do we use it (purpose)?
At or prior to the time of collection of personal information, SMD shall specify the purposes for which personal information will be collected, used and disclosed. Your privacy is very important to us, which is why we collect and use personal information solely for the following purposes:
- To identify our consumers, donors, sponsors, volunteers and other stakeholders for administrative purposes;
- To establish and maintain responsible relationships with our consumers, donors, sponsors, volunteers and other stakeholders;
- To understand, develop and/or enhance the needs, desires, concerns or opinions of our consumers, donors, sponsors, volunteers and other stakeholders;
- To provide products and/or services and to carry out organizational activities, all with a view to advancing the goals of our Mission Statement;
- To manage and develop our programs and operations;
- To maintain and update a database of consumers donors, sponsors, volunteers, the general public and other stakeholders for the purpose of
a) maintaining a membership list;
b) soliciting public opinion;
c) testing and distributing products and services;
d) meeting funder requirements and compiling statistics;
e) to solicit individuals for focus group participation; and
f) to be used for fundraising efforts and special event announcements.
- To meet legal and regulatory requirements.
Our organizational activities consist of:
- rehabilitation services;
- fundraising activities;
- self-help services;
- information services; and
- public education and awareness.
- We collect information only by lawful and fair means. Wherever possible, we try to collect your personal information directly from you, except where required or permitted by law.
WHEN and to whom do we disclose personal information?
SMD will disclose personal information only with your consent, unless required or permitted by law. There are a variety of circumstances in which we may need to disclose some personal information about our consumers, donors, sponsors, volunteers and other stakeholders. For example, we may disclose an individual’s personal information:
- To a third party that is involved in supplying that individual with our products or services – family doctor, other doctors, specialists such as therapists in physiology, occupational, speech and audiology;
- To a third party that we have engaged to perform functions on our behalf, such as direct mail processing, therapy services, information technology support;
- To an authorized agent or representative of a consumer;
- To a public authority who has lawful authority to receive the personal information requested, such as the Workers Compensation Board, Family Services and Housing, Manitoba Public Insurance Corporation, Child Development Clinic, as well as to daycares or schools.
- To a public authority or agent of a public authority if, in our reasonable judgment, it appears that there is imminent danger to life, health or security of an individual;
- To third party that is affiliated with or otherwise related to or part of our organizational group such as SMD Foundation, SMD Information Services, SMD Alliance; and
- To a third party where that individual has consented to such disclosure (eg. family doctor), or where such disclosure is required or permitted by law.
In all cases, any disclosure of an individual’s personal information will be made on a confidential basis, and SMD will only disclose the minimum amount of information required.
HOW do we protect your personal information?
In order to protect your personal information, we will:
- Not collect, use or disclose your personal information for any purpose other than those identified at or prior to the time information is collected, except with your further consent. Consent for any of the identified purposes or for any additional purpose can be provided in writing, orally or electronically. Consent can be express or it may be implied in appropriate circumstances;
a) Express consent is when we ask you directly if you will allow us to use your personal information (the purposes for such collection and use having been explained in a manner that is clear and understandable).
b) Implied consent occurs when you seek out our services, and your consent for us to collect and use your personal information is obvious in the circumstances.
- Protect your personal information with security safeguards that are appropriate to the sensitivity of the information;
- Protect the confidentiality of your personal information when dealing with other organizations and seek your consent for disclosure in all cases except where required or permitted by law;
- Use reasonable efforts to keep your personal information as accurate and up-to-date as is necessary for the purposes for which it is to be used and/or disclosed. Your assistance in keeping your personal information up to date is greatly appreciated;
- Respond to any request you may make for access to your personal information. We will need specific information from you to verify your identity before we can respond to your request. In addition, there may be instances where we will not be able to provide you with the personal information that you have requested. If we deny your request for access to your personal information, we will provide you with an explanation in writing.
WHAT are your choices:
- You may consent to have us continue to collect, use, disclose or store your personal information for the purposes identified above.
- You may refuse to provide your personal information to us. You may also withdraw your consent for us to collect, use or disclose your personal information at any time, subject to legal or contractual restrictions and reasonable notice. However, in either case, this may limit or eliminate altogether our ability to provide products and/or services to you or to communicate with you.
- You may have your name removed from our telephone, mail or e-mail lists. We use these lists to inform you of relevant activities or initiatives that we are contemplating or undertaking that we think may be of interest to you.
If you have any questions or concerns about our privacy practices, please contact our Privacy Officer by:
- Mail: 825 Sherbrook Street, Winnipeg, Manitoba R3A 1M4
- E-mail: firstname.lastname@example.org