ADMINISTRATION
PRIVACY PROTECTION
AND INFORMATION ACCESS
315
POLICY
It is the policy of the Upper Grand District School Board to protect all personal
information under its custody and control while providing right of access to information
in accordance with the Municipal Freedom of Information and Protection of Privacy Act
(MFIPPA).
Administrative Detail
1.
It is the responsibility of the Director of Education to administer this policy.
2.
It is the responsibility of the Freedom of Information and Protection of
Privacy Coordinator (FOI Coordinator) to implement this policy and any
administrative procedures and practices developed in support of
compliance.
3.
It is the responsibility of all Board staff and volunteers to comply with this
policy and inform, as soon as possible, their principal or supervisor and/or
the FOI Coordinator of any breeches of privacy.
4.
It is the responsibility of senior administrators to implement training for
staff on this policy and procedures and Board practices.
5.
The Board shall make available to the public specific information about its
privacy policy and procedures.
6.
When a new project or initiative is undertaken, and when a Board policy is
created or revised, Privacy Management shall be considered.
7.
This policy will be reviewed and revised as required.
8.
This policy operates in conjunction with the Education Act, the Municipal
Freedom of Information and Protection of Privacy Act (MFIPPA), the
Personal Health Information Protection Act (PHIPA), Personal Information
and Protection of Electronic Documents Act (PIPEDA), the Ontario School
Board/Authorities Privacy Standard, and other applicable legislation, the
Ontario Student Record Guideline, (OSR Guideline) Privacy and
Information Access Handbook, and all Board Policies, Procedures and
Protocols.
Adopted 2010 09
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ADMINISTRATION
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PRIVACY PROTECTION
AND INFORMATION ACCESS
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Resources to support the implementation of this policy can be found in the
Privacy Protection and Information Access Handbook.
Adopted 2010 09
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ADMINISTRATION
A.
PRIVACY PROTECTION
AND INFORMATION ACCESS
PROCEDURES MANUAL
315-A
GENERAL
The Upper Grand District School Board only collects personal information when it
is necessary for providing for the education of its students and/or the
employment of Board employees, or as required by the law.
B.
PERSONAL INFORMATION
Recorded information is information about an individual that renders that
individual identifiable, including: name, address, phone number, race, ethnic
origin or religious or political beliefs or associations, age, date of birth, sex,
sexual orientation, mental status, or family status; and identifying number or
symbol; fingerprints, blood type or inheritable characteristics; medical history;
educational, financial, criminal, or employment history; personal views or
opinions, except if they are about someone else; or anyone’s opinion about that
individual.
C.
PRIVACY STANDARD
The Board has adopted the Privacy Standard that was developed by the Privacy
Information
Management
Taskforce
for
use
by
Ontario
school
boards/authorities. The ten commitments which make up the Privacy Standard
have been adapted from the Canadian Standards Association (CSA) Fair
Information Privacy Principles.
The commitments are intended to foster a culture of privacy with respect to how
a Board, collects, uses, discloses, secures, retains and disposes of personal
information and confidential records. It also ensures the right of individuals to
have access to personal information about them and as appropriate, to have it
corrected.
The commitments are as follows:
1.
Accountability and Responsibility
a)
Adopted 2010 09
Under the Municipal Freedom of Information and Protection of
Privacy Act, Boards of Trustees of Ontario School
Boards/authorities are responsible for personal information under
their control and may designate an individual within their
Board/authority who is accountable for compliance with privacy
legislation.
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ADMINISTRATION
2.
PRIVACY PROTECTION
AND INFORMATION ACCESS
PROCEDURES MANUAL
315-A
b)
Under the
information
information
Board as
legislation.
Personal Health Information Protection Act, health
custodians are responsible for personal health
and may designate an individual within their school
an agent to assist with compliance with privacy
c)
The Board’s Health Information Custodians are the Chief
Psychologist, the Co-ordinator of Speech and Language Services,
Psychology Consultants, Social Workers, and Speech-Language
Pathologists.
d)
The Board’s Privacy Protocol for Child and Youth Counsellors,
Counselling and Attendance Services, Psychological Services and
Speech and Language, provides direction for its staff in these areas
on safeguarding student personal information under PHIPA.
Specified Purposes
The purposes for which personal information is collected are specified,
and individuals are notified of the purposes at or before the time personal
information is collected.
3.
Consent
An individual’s informed consent is required for the collection, use, and
disclosure of personal information, except where otherwise permitted by
law.
4.
Limiting Collection
The collection of personal information is fair, lawful, and limited to that
which is necessary for the specified purposes.
5.
Limiting Use, Retention, and Disclosure
The use, retention, and disclosure of personal information are limited to
the specified purposes identified to the individual, except where otherwise
permitted by law.
Adopted 2010 09
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ADMINISTRATION
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PRIVACY PROTECTION
AND INFORMATION ACCESS
PROCEDURES MANUAL
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Accuracy
Ontario school Boards/authorities ensure that personal information is
accurate, complete, and up-to-date in order to fulfill the specified purposes
for its collection, use, disclosure and retention.
7.
Security Safeguards
Personal information is secured and protected from unauthorized access,
disclosure, and inadvertent destruction by adhering to safeguards
appropriate to the sensitivity of the information.
8.
Openness and Transparency
Policies and practices relating to the management of personal information
are made readily available to the public.
9.
10.
Access and Correction
a)
An individual has the right to access his/her personal information
and will be given access to that information in accordance with
privacy legislation, subject to any restriction.
b)
An individual has the right to challenge the accuracy and
completeness of the information and request that it be amended, as
appropriate, or to have a letter/statement of disagreement retained
on file.
c)
Any individual to whom the disclosure has been granted in the year
preceding a correction has the right to be notified of the
correction/statement.
d)
An individual is to be advised of any third party service provider
requests for his/her personal information in accordance with privacy
legislation.
Compliance
An individual may address or challenge compliance with the above
principles to designated individual(s) accountable in each of the Ontario
school Boards/authorities.
Adopted 2010 09
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