Counselling and Accessibility Services
Privacy of personal information is an important principle to the Counselling and Accessibility Services. Our professional staff, including regulated health care providers are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies are aligned with Seneca College’s institutional practices related to handling of personal information.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to: an individual’s personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status); health (e.g., health history, health conditions, health services received by them); or, activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is different from business information (e.g., an individual’s business address and telephone number). This is not protected by privacy legislation.
WHO WE ARE
Our department, Counselling and Accessibility Services, includes professional staff from the following areas: counselling services, accessibility services, enhanced services (i.e. learning strategists, assistive technologists), reception (i.e. administrative assistants, service advisors, and support staff (i.e. scheduling support services, data entry). Our management department is staffed by a Director, Senior Manager Counselling Services, Senior Manager Accessibility Services and an Office Manager.
Seneca partners we frequently collaborate with
In order to provide supports and services to Seneca students accessing Counselling and Accessibility Services, the department works collaboratively with internal departments on a frequent basis, including but not limited to the Test Centre, Counsellor within First@Peoples and the Health Centre. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles accessing information in the course of doing business with our department. In situations where more information may be required to support a specific student, an informed consent form will be signed between the student and one of these departments.
Provision of Academic Accommodations –OHRC March 2016
Consistent with the Ontario Human Rights Commission Recommendations (Letter dated March 2016) students are not required to deliver their Academic Accommodation Letters directly to their teaching faculty. Counselling and Accessibility Services works with the academic and program areas to identify the most efficient process or person who can assist with the implementation of Academic Accommodation Letter notification to assigned teaching faculty for the student during their the length of registration with Seneca College. The Academic Accommodation Letter outlines a student’s academic needs within a learning environment (e.g. classroom, testing, assessment, evaluation and in practical settings such as field, coop or clinical settings). Only relevant information related to their functional limitations and resulting needs are disclosed to provide the student increased opportunities for success at Seneca.
We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, part time staff to provide additional support during busy times, website managers, cleaners and lawyers.
WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES
Personal Health Information – Registered Students with our office
Students who register with Counselling and Accessibility Services have acknowledge their agreement to participate in a process to receive services that may include activities such as personal counselling, accessibility services, enhanced services and/or academic accommodations, We collect, use and disclose personal information in order to serve students registered with our office. For our students, the primary purpose for collecting personal information is to provide counselling, accessibility and/or academic accommodations. For example, we collect information about a client’s health history, including their family history, physical condition, social situation and functional limitations in order to help us assess what their educational needs are, to advise them of their options which may include such things as short term supportive counselling, academic accommodations, learning skills or adaptive technology supports or a referral to a community agency or practitioner for longer term clinical supports. A secondary purpose is to obtain a baseline of health and social information so that in providing short term counselling services we aim to identify or detect changes that occur over time that suggests a student may require acute supports. It would be rare for us to collect such information without the student’s express consent, but this might occur in an emergency (e.g., the student is unconscious, medical issue such as a seizure) or where we believe the student would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from the student and we have no reason to believe that the message is not genuine).
Personal Health Information - Students of Seneca College
For students of Seneca College who have not, or are not currently registered with the service, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of Seneca College events in general or within Counselling and Accessibility Services in particular. For example, while we try to use College contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.
Electronic Collection, Usage and Storage of Personal Health Information
Counselling and Accessibility Services is in the process of implementing a number of changes to our electronic system that are designed to improve services to students. These services enhancements impact counselling services and accessibility services. The new paperless system for access to our services includes an online program called ACCOMMODATE. Students will register with the Service and schedule appointments either in person, or through the online Accommodate portal which is accessed through the Counselling and Accessibility Services website. On the Counselling and Accessibility Services website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a service or support, to access adaptive technology and other material resources). Cookies are only used to help students navigate our website and are not used to monitor their activities.
About Contract Staff, Data Entry Staff and Volunteers
For people who are contracted to do work for Counselling and Accessibility Services (e.g., temporary/part time staff, data entry staff), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments, maintaining information in the online system) and for necessary work-related communication (e.g., sending out schedule requests, special assignments clarification of hours worked). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., a SARS outbreak, urgent threat) or to investigate a possible breach of law (e.g., if a theft were to occur in the department). If contract staff, data entry or volunteers wish a letter of reference or an evaluation, the Director or their designate will collect information about their work related performance and provide a report as authorized by them.
WE COLLECT PERSONAL INFORMATION: SECONDARY AND RELATED PURPOSES
Like most organizations, we also collect, use and disclose information for secondary purposes, which are related to our primary purpose of doing business. In these examples a client may be more or more of the following: external business client, a student, supplier, company, or agency. The most common examples of our related and secondary purposes are as follows:
- To advise students and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new resource/technology) that we have available.
- To advise students that a resource/technology or service should be reviewed (e.g., to ensure a resource/technology is still functioning properly and appropriate for their current needs and to consider modifications or replacement).
- Our department reviews student and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our management staff and professional staff. In addition, external consultants (e.g., ministry auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our Services, including reviewing student files and interviewing our professional and administrative staff.
- Counselling and Accessibility Services are regulated by a number of professional Colleges including: College of Psychologists of Ontario, College of Social Workers and Social Service Workers, College of Occupational Therapists Association, and other licensing bodies who may inspect our records and interview our professional staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our students, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Ministry of Training, Colleges and Universities, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
- To invoice students for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
- The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., BSWD, OHIP, WSIB, and private insurance, assistive Devices Program). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate student’s entitlement to this funding.
- Students or other individuals we deal with may have questions about our goods or services after they have been received. We also provide ongoing services for many of our students over a period of months or years for which our previous records are helpful. We retain our student record information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our client records).
- If Seneca College, Counselling and Accessibility Services, or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Service’s records to ensure that it is a viable operation that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING STUDENT PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information is either under supervision or secured in a locked or restricted area.
- Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital as these signals are more difficult to intercept.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable Seneca staff or companies.
- Electronic information is transmitted either through either a secure provider, a direct line or has identifiers removed or is encrypted.
- External consultants and agencies with access to personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF STUDENT PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
We keep our student files for about ten years. Student paper files/records being stored under this provision are held off site, at our third party storage company used by Seneca College. We keep any personal information relating to our general correspondence (i.e., with people who are not students) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Seneca’s Information and Technology Services department provides guidance, and assists in ensuring electronic information is destroyed under their policies and procedures. Alternatively, in some cases in consultation with key stakeholders we may send some or all of the client file to the student or their substitute decision-maker.
STUDENT ACESS TO RECORDS
With only a few exceptions, students have the right to see what personal information the service has on file about you. Students will be asked to make this request in writing to Attention: Director, Counselling and Accessibility Services 1750 Finch Avenue East, Toronto Ontario M2J 2X5. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We reserve the right to charge a nominal fee for such requests. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that the information in the file is wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
DO YOU HAVE A PRIVACY QUESTION RELATED TO YOUR FILE WITHIN COUNSELLING AND ACCESSIBILITY SERVICES?
Counselling and Accessibility Services
1750 Finch Avenue East,
416.491.5050 ext. 22900
f you have more questions after speaking with the Director within Counselling and Accessibility Services office or if you wish to make a formal complaint about the department’s privacy practices, you may make it in writing to our Privacy Information Officer. The privacy information officer will attempt to answer any questions or concerns you might have.
The privacy information officer will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal written decision with reasons.
Privacy Information Officer
1750 Finch Avenue East.
Toronto, Ont. M2J 2X5
416.491.5050 ext. 77846
Concerns About Professionalism/Competence of Professional Staff
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with one of the following persons:
- Senior Manager
You can reach us at 416.491.5050 ext. 22900. If we cannot satisfy or address your concerns, you are entitled to complain to our regulatory body:
The College of Psychologists of Ontario
110 Eglinton Avenue West
Toronto, Ont. M4R 1A3
The College of Social Workers and Social Service Workers
250 Bloor St E,
Suite 1000 Toronto, Ont. M4W 1E6
The College of Occupational Therapists of Ontario
20 Bay St Suite #900,
Toronto, Ont. M5J 2N8
This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street
Ottawa, Ont. K1A 1H3
Phone 613.995.8210 | 800.282.1376