Introduction
This policy applies to the collection, use, disclosure and management of the personal information of clients of Canadian Credit Counsellors Society (CCCNS).
1. Accountability
The Program Director of CCCNS is accountable for compliance with these policies and procedures regarding the manner in which CCCNS collects, uses, discloses and otherwise manages personal information.
The Program Director is appointed as the Privacy Officer for CCCNS.
CCCNS is responsible for personal information in its custody and control.
2. Identifying the Purposes for Collecting and Using Personal Information
CCCNS collects and uses personal information to provide advice and information on personal money management issues and to provide advice, information and options for debt repayment to CCCNS clients by dealing with their various creditors. The personal information collected by CCCNS includes information on clients’ debts, income, assets, living expenses, employment situation, general financial status and their relationships with various creditors.
CCCNS also uses the aggregate demographic information from the personal information collected to identify services and programs that may benefit the communities we serve; to target our marketing and awareness programs; and to maintain the ongoing financial support and cooperation of our stakeholders. No individual can be identified through this information.
CCCNS personnel are trained to explain the purposes of collecting the information to any client who asks for an explanation. The purpose for which personal information is collected and used by CCCNS personnel is communicated to each client at or prior to the time of collection.
3. Getting the Client’s Consent
CCCNS will not collect, use or disclose a client’s personal information without the express consent of the client.
4. Limits for Collecting Personal Information
CCCNS personnel collect personal information about individuals only where such individual is a client or potential client of CCCNS. Our clients’ personal information is not used or disclosed for purposes other than those for which it was collected, except with the consent of the client or as required by law.
5. Limits for Disclosing and Retaining Personal Information
CCCNS discloses personal information only for the purposes for which it was collected. It keeps information for as long as it is required for the stated purposes.
CCCNS retention policy provides that files regarding debt mangement programs (DMP) are retained for a maximum of 7 years from the date the DMP is closed, after which time the files are permanently destroyed.
CCCNS retention policy provides that files regarding financial counselling only sessions are retained for a maximum of 7 years from the date of the last counselling session, after which time the files are permanently destroyed.
Personal information that is no longer required to fulfill the identified purposes or that is not required to be retained pursuant to any applicable law is destroyed, erased or made anonymous. CCCNS reviews the personal information in its custody and control on a periodic basis in order to ensure that personal information no longer required to be retained has been destroyed, erased or made anonymous.
6. Keeping Personal Information Accurate
CCCNS ensures, to the best of its ability, that the information it holds is accurate, complete, current and relevant to the identified purposes.
CCCNS maintains strict confidentiality agreement with those who have access to the personal information being held by CCCNS. Any corrections to the information can be given to those parties. CCCNS recognizes that it is crucial that creditors of its clients have current and accurate information in order to make important decisions regarding the acceptance of our client debt management programs as well as other credit decisions.
7. Safeguarding Personal Information
CCCNS ensures that personal information is stored in electronic and physical files that are physically secure. Security measures include storage of files in locked filing facilities when not in use; secure locks on the offices of CCCNS and its satellite offices. Electronic files are protected by encryption software. Staff passwords to access such electronic files are controlled and employ high level encryption practices.
Distribution of personal information regarding clients is restricted to the employees of CCCNS and any creditors for whom a debt management program is entered into in respect of CCCNS clients.
The employees of CCCNS sign a Confidentiality Agreement and will abide by these privacy policies and procedures.
Physical CCCNS files containing personal information are shredded under the supervision of CCCNS employees. Deleted electronic files will be permanently removed from the system, as discussed in section five (5).
8. Individual Access to Personal Information
Upon written request, CCCNS will provide an individual with confirmation as to whether CCCNS has personal information about them, what the information is, what it is being used for and to whom the information has been disclosed.
Individuals should send their written request for access, with contact information and enough information about themselves to identify them to the Executive Director of CCCNS.
CCCNS will respond within thirty (30) days of receiving any access request at no cost to the individual.
If the individual can provide proof of an error in the personal information held by CCCNS, then CCCNS will amend the information and where appropriate, send the corrected information to others who have used the incorrect information.
If CCCNS denies the individual’s request for access, it will state the reasons for denial.
9. Handling Individual Complaints and Questions
Individuals may send any complaints regarding CCCNS’s compliance with its own privacy policies and procedures to the Program Director of CCCNS. The Program Director or designated staff will investigate the complaint and respond to the individual.
If the individual’s complaint is justified, CCCNS will change its policies and procedures related to the matter so that other individuals will not experience the same problem.