The Ontario Brain Injury Association (OBIA) is a charitable organization whose mission is to enhance the lives of Ontarians living with the effects of an acquired brain injury through education, awareness, and support. OBIA is committed to individual privacy and to protecting the confidentiality of the personal information it holds.
In fulfilling its mandate, OBIA is engaged in several activities in which personal and/or confidential information is collected, used and disclosed. This Privacy Policy applies to all activities of OBIA involving the collection, use and disclosure of personal information. OBIA’s privacy statement has been developed based on the federal Personal Information and Electronic Documents Act (PIPEDA) and Ontario’s Personal Health Information Protection Act, 2004 (PHIPA). It also reflects the Canadian Standards Association Model Code principles for fair information practices.
1. Accountability
OBIA takes its responsibility to protect the personal information in its custody or control very seriously. While all OBIA staff and volunteers share this responsibility, accountability for the organization’s compliance with this privacy statement and related policies rests with the OBIA’s Chief Privacy Officer (CPO). In addition, other individuals within the organization may be delegated to act on behalf of the CPO.
2. Why does OBIA collect your Personal Information?
Personal information is collected for the purpose of providing services to members and the public; conducting research (both internal and external to OBIA); to assist in general or specific advocacy; and to support OBIA’s members. Any collection of personal information not set out in this policy will be done with the individual’s consent, and their purposes will be further explained to the individual upon request.
3. What Personal Information does OBIA Keep?
OBIA collects personal information through the ongoing activities of its numerous programs and projects. OBIA will limit its collection to information that is necessary for purposes it identifies or that are obvious in the circumstances (for example, collecting the individual’s contact information if a book order cannot be processed). OBIA will collect the information in a manner that does not coerce or deceive the individual.
OBIA collects and keeps:
- Your contact information, including name, phone number, email, and mailing address
- Information about your brain injury and services you have received from external providers where the information providers us with a better understanding of your needs
- Information about participation in OBIA programs, including clinical notes.
4. How does OBIA collect your Personal Information?
The knowledge and consent of the individual (or legal representative, such as a substitute decision-maker) are required for the collection, use, and/or disclosure of personal information, except in limited circumstances. An example would be where the law permits or requires the disclosure of the information, e.g., a court order. All information collected by OBIA is carefully protected.
The purposes for which personal information is collected will be identified at or before the time the information is collected. OBIA’s methods of collection can include:
- Correspondence by Telephone, Email, and Mail
- Case Files for Support Services
- Registration for OBIA’s Support Programs, including Online Support Groups, the Peer Support Program, and the Brief Intensive Case Management Program
- Employment Application Forms
- Benefit Application Forms
- Purchase of Memberships
- The Brain Injury Impact Study
- Registration for Brain Injury Speaks
- Applications for Funding through the Hospital Clinician Education Bursary, Elements Support Services Scholarship Fund, Compassionate Justice Fund, Headway Homes Fund, and Jane Hayman Endowment Fund
- Donations and Sponsorships
- Registrations for the Brock University Certificate and Brain Basics Training Programs
- Resource Purchases
- Library Utilization
5. How is your Personal Information stored and secured?
OBIA will take steps to protect the personal information in its custody or control against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. It will protect the information regardless of the format in which it is held, and with security safeguards appropriate to its sensitivity. These include:
- Physical measures, for example, locked filing cabinets and restricted access to offices
- Organizational measures, including security clearances and limiting access on a “need-to-know” basis
- Technological measures, such as the use of passwords and encryption.
To reinforce a culture of privacy protection, OBIA staff and volunteers are required to sign a confidentiality agreement as a requirement of employment or volunteerism. Any material which contains personal or confidential information will be destroyed in accordance with industry standards prior to its disposal. Furthermore, all information stored electronically, is located on secure servers hosted in Canada.
Additionally, when working remotely, all staff are required to abide by OBIA’s Privacy, Cybersecurity and Technical Requirements for Remote Access Policy.
6. Limiting Use, Disclosure and Retention
OBIA will not use or disclose personal information for purposes other than for which it was collected, except with consent or as permitted or required by law. It does not rent, sell, or trade its mailing or other member lists. OBIA’s anticipated uses and disclosures of personal information include:
- Delivering goods and services
- Advocacy on behalf of our members, for which written consent will be obtained. For example, when making community referrals, applying for financial aid, or speaking with providers in the individual’s circle of care.
- Keeping members and the public informed about OBIA activities, including programs, services, special events, funding needs, opportunities to volunteer or to give, and open houses
- Contacting prize winners in the event of a raffle or other contest
- Research
Personal information will be retained only as long as necessary to fulfill these purposes.
OBIA may disclose your personal information without your consent if we are required or authorized to do so by law. For example:
- When you are at risk of serious harm, or your actions place someone else at risk of harm.
- To meet government, regulatory and legal reporting requirements.
7. Openness
OBIA is open about its information practices. Its Chief Privacy Officer is available to answer any questions, and its privacy statement is available on its web site as well as through its office.
8. Individual Access
Upon request, an individual will be informed of the existence, use, and disclosure of his or her personal information held by OBIA and may request access to that information. An individual may challenge the accuracy and completeness of the information and request that it be corrected. Further, any person may request to withdraw their consent for OBIA to retain their personal information. All requests must be made in writing to the Chief Privacy Officer of OBIA. The CPO will respond to the individual’s request within a reasonable time and at a reasonable or no cost to the individual.
9. Challenging Compliance
OBIA will investigate all complaints or challenges concerning compliance with this privacy statement. If a complaint is found to be justified through either the internal or external complaint review process, OBIA will take appropriate measures, including, if necessary, amending this privacy statement and any related policies and procedures.
Any questions about this privacy statement should be directed to the Chief Privacy Officer by phone at (905) 641-8877 or via e-mail at [email protected].
