About Your Privacy

Child Witness Centre (CWC) is committed to protecting the privacy of the personal information of its clients, employees, volunteers and other stakeholders. We value the trust of those we deal with, and of the public, and recognize that maintaining this requires that we be transparent and accountable in how we treat the information that you choose to share with us.

During the course of our various activities, we frequently gather and use personal information. Anyone from whom we collect such information should expect that it will be carefully protected and that any use of or other dealing with this information is subject to consent. Our privacy practices are designed to achieve this.

Personal identifying information is any information that can be used to distinguish, identify or contact a specific individual. This information can include an individual’s opinion or beliefs, as well as facts about, or related to, the individual.  There are certain exceptions — business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories — that are not considered personal but rather public information.

Where an individual uses their home contact information as business contact information as well, we consider that the contact information provided is business contact information, and is not therefore subject to protection as personal information.

Personal information gathered by Child Witness Centre is kept in confidence.  Our personnel are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained.  Physical and electronic safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered.  We also take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed.

The Child Witness Centre collects, uses and discloses personal information only for purposes that a reasonable person would consider appropriate in light of the circumstances.

We collect, use and share personal information to:

• Provide services through our Child Witness Program and Child and Youth Advocacy Program;
• Plan and manage services, including making referrals to appropriate services;
• Aid a law enforcement agency in an investigation;
• Seek consent (or consent of a substitute decision-maker) where appropriate;
• Receive payment or process, monitor, verify or reimburse claims for payment as related to our mandate;
• Detect, monitor or prevent fraud or any unauthorized receipt of services or financial benefits;
• Conduct risk management, error management and quality improvement activities;
• Conduct service recipient surveying;
• Conduct research (subject to certain rules);
• Compile statistics;
• Report to the government as required by law;
• Allow for the analysis, administration and management of our programs;
• Comply with legal and regulatory requirements; and
• Fulfill other purposes permitted or required by law.

Our records can also include personal information collected to provide services to you including: your date of birth, contact information, records of meetings with you and/or your family, the services you received, the programs you attended, details of your physical and mental health, medical, psychological or psychiatric reports, school information, financial information, employment history, court documentation, police interventions, criminal history, your views or opinions, the views and opinions of others about you and information about your race, ancestry, place of origin, ethnic origin, citizenship, family diversity, disability, creed, religion, age, sex, sexual orientation, gender identity, gender expression, cultural or linguistic needs, and marital or family status.

We also collect potentially personally identifying information like Internet Protocol (IP) addresses. We do not use IP addresses to identify website visitors, however, and do not disclose such information, other than under the same circumstances that we use and disclose personally identifying information, as described below.

Child Witness Centre utilizes the services of some third-party providers. This may include, but not limited to, internet providers, IT support providers and third-party donor management portals. These service providers are persons or organizations assist in the delivery or support the administrative systems of the agency. We share only the information that is necessary for service providers to deliver and administer these services.

Child Witness Centre holds all third-party contracts and contractors to the same high standards we have for ourselves when it comes to protecting your privacy.

In some situations, we do not need consent to share information.  This may include when we have a duty report to child protection services in order to protect children where we are required by law to collect, use and disclose personal information. For example, we do not need your permission to meet our child protection obligations or to share your personal information to keep you or someone else safe.

In other situations, you have the right to make your own information privacy decisions. When we require and ask for your permission, you may choose to say no. Even if you say yes, you may change your mind at any time. Once you say no, we will no longer share your information unless you say so. Your choice to say no may be subject to some legal limits. Choosing not to share some information may also affect how we can support you or your child.

Sometimes, we receive requests for information from third parties such as the police, government agencies and people involved in court cases with our clients.

We only give personal information about service recipients to third parties if:

• The individual has provided consent; or
• There is a court order, search warrant, or urgent demand for records requiring disclosure; or
• We are legally permitted or required to provide the information.

In situations when you have a right to make your own information privacy decisions, you may make your decisions if you are capable. You may be capable of making some information privacy decisions and not others. If you are not capable – you will have a substitute decision-maker who will make your information decisions for you. The rules about who can act as a substitute decision-maker and what they have to do is also set out in law. For example, a substitute-decision maker can be a person named under the Health Care Consent Act, a guardian of the person or property, an attorney for personal care or property, a representative appointed by the Consent and Capacity Board, such as a spouse.

For children, there is no legal age when you become able to make your own decisions about your personal information. If you are capable, you can make your own decisions. However, if you are under the age of 16, there are some additional rules to know.

• If you are not capable, your parent (s) or other official guardian will make decisions for you as your substitute decision-maker.
• If you are capable, you will make your own decisions.
• If you are capable, your parent(s) or guardian will also be allowed to make some decision about your personal information service records. They will not be able to make decisions about any records regarding services to which you alone consented.

Child Witness Centre client database systems is the primary tool for storing information needed by our agency to deliver services. In addition, we also maintain a donor database and utilize the services of CanadaHelps for processing donations.

Our client databases contain information about children and their families who receive services. It also contains information about caregivers and their relations, as well as specific information about services provided and court matters as applicable. We only collect and retain information for the purpose that is consented to and for a limited period of time.

Our destruction timeline policy is as follows:

Client Services and Records

• Inactive client records: Seven (7) years after the last entry or, if the client was less than eighteen years of age at the date of the last entry, or at least seven years from the day the client became or would have become eighteen.
• Deceased client records: Two (2) years from the time of death.
• Client Complaints: Seven (7) years from the expiry of Ministry of Attorney General agreement.

Research

• Inactive research grantee records: Seven (7) years from the time of the last grant.

Fundraising, Marketing and Communications

• Inactive donors: Seven (7) years from the time of last donation.
• Inactive event participants: Seven (7) years from time of last participation.
• Planned giving – expectancies: Until notification that gift has been received.
• Planned giving – realized: Seven (7) years after final gift in donor’s will received.
• Fundraising strategy documents and plans (final versions): Indefinite.
• Do not call lists: Indefinite.
• Do not mail lists: Indefinite.
• Official newsletters: Indefinite.
• Annual Reports: Indefinite.

Our donor databases and CanadaHelps contain information about donors such as names, addresses and in some cases credit card information. Child Witness Centre retains credit card and/or banking information only for as long as needed to process a donation.

Your personal information must be kept private and secure. Everyone at the Child Witness Centre is bound by an oath of confidentiality. We protect your information from loss or theft and ensure no one looks at your information or does something with it if they are not involved in providing services to you or allowed as part of their job. If there is a privacy breach, we will tell you and we will share with you what has been done to address the privacy breach.

Safeguards equally apply to what personal information we enter into our databases and other electronic information systems, as well as paper, or electronic copied of records, reports, financial records, administrative notes, voice messages, text messages, and emails (including on laptops and cell phones) and any other ways personal information can be recorded.

With limited exceptions, you have the right to access the personal information we hold about you that relates to a service provided to you. You also have a right to correct information about yourself.

In rare situations, you may be denied access to some or all of your personal information regarding your service (with any such denial being in accordance with the law).

We try to keep your personal information accurate and up to date. Please let us know if you disagree with what is recorded, and we will make the change or otherwise we will ask you to write a statement of disagreement and we will attach that statement to the relevant service record.

If you need a copy of your service records, please contact our Chief Privacy Officer, Robin Heald, at robin.heald@childwitness.com or 519-744-0904 ext 212.

For further information or concerns about our information practices, to ask a question or make a formal complaint we invite you to contact our Chief Privacy Officer, Robin Heald, at robin.heald@childwitness.com or 519-744-0904 ext 212.

If after contacting us, you feel that your concerns have not been addressed to your satisfaction, you have the right to complain to the Information and Privacy Commissioner of Ontario. The Information and Privacy Commissioner of Ontario is responsible for making sure that privacy laws are followed in Ontario.

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400 Toronto, Ontario M4W 1A8
Tel: 416-326-3333
Toll-free: 1-800-387-0073
TDD/TTY: 416-325-7539
Email: info@ipc.on.ca
www.ipc.on.ca