PURPOSE

To comply with the Personal Health Information Protection Act, 2004 (PHIPA) and ensure that staff and volunteers have the appropriate understanding of privacy and how to handle private information.

POLICY

BD Hospice is committed to protecting the privacy of the personal information of its employees, volunteers, clients, and other stakeholders.

BD Hospice values the trust of those we deal with.  We recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that individuals choose to share with us.

During the course of our work, BD Hospice frequently gathers and uses personal information.  This information will be carefully protected and any use of or release of this information is subject to consent.

What is Personal Information?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual.  This includes any information in any form, such as:

• Age, name, ID numbers, income, ethnic origin, or blood type
• Opinions, evaluations, comments, social status, or disciplinary actions.
• Employee files, credit records, loan records, medical records, existence of a dispute, or intentions.

Personal information does not include the name, title, business address, or telephone number of an employee of an organization.

Why Do We Collect Personal Information?

We collect, use, and disclose personal information primarily in order to serve our clients.  For our clients, we collect health history, physical condition, and social/cultural status in order to help us assess health needs and best meet those needs.  For our volunteers and student placements, we collect information about their backgrounds, social/cultural status and availability in order to best match them with clients.  Clients and volunteers are also often contacted with information about BD Hospice (e.g., seminars, celebrations, fundraising).  For both clients and volunteers, consent is received to gather personal information for these purposes.

For employees, our primary purpose for collecting personal information is to ensure that we are able to follow all practices related to the Employment Standards Act and Occupational Health and Safety Act (e.g., tax deductions, emergency contacts).

Protecting Personal Information:

BD Hospice will protect personal information by adhering to the following principles:

• Accountability: BD Hospice is responsible for all personal information under its control including any personal information disclosed to third parties for processing. 
• Identifying Purposes: BD Hospice will identify the purposes for collecting personal information prior to or at the time it is being provided.  Personal information will not be used for a purpose not previously identified without further individual consent, unless the new purpose is required by law.
• Consent: The knowledge and consent of the individual is required for the collection, use, or disclosure of personal information, except where inappropriate.
• Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by BD Hospice.
• Limiting Use, Disclosure, and Retention: Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.  Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
• Accuracy: Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
• Safeguarding Personal Information: BD Hospice protects personal information with safeguards appropriate to the sensitivity of the information, using password protocols and encryption software when required. 
• Openness: BD Hospice will make specific information about its personal information management practices readily available to individuals.
• Access: Upon request, BD Hospice will inform individuals of the existence, use, and disclosure of their personal information and provide access to that information.  An individual shall be able to verify the accuracy and completeness of their information and may request that it be amended, as appropriate.
• Handling Complaints and Suggestions: Beth Donovan Hospice has procedures to receive and respond to complaints or inquires about policies and practices relating to the handling of personal information.  These procedures will be easily accessible and simple to use.

Retention and Destruction of Personal Information:

Beth Donovan Hospice will keep all client, volunteer, and employee records for 7 years (post-death/post-discharge/post-discontinuation of volunteering or employment) in the main office.  The records/documentation will be maintained in a secure storage system with limited access.  Paper files containing personal information will be destroyed by shredding.

The Privacy Officer for the Beth Donovan Hospice is the Executive Director.