MASTERING MINDS PRIVACY POLICY
The privacy policy applies to personal information about the children in our care, their parents/legal guardians, their siblings, and other individuals who are involved in their care and upbringing. Mastering Minds respects privacy and we have a commitment to protecting the personal information of the children in our care and their families.
For the purposes of this policy, “personal information” is defined as any identifiable information about the children in our care and their families, such as contact details, health information, living arrangements, background information, the child’s personal characteristics and behaviour styles.
Personal information is only collected, used and disclosed in accordance with this Privacy Policy and the legal obligations imposed by the Personal Information Protection and Electronic Documents Act (PIPEDA).
WHY DO WE COLLECT PERSONAL INFORMATION
When enrolling your child/children in our programs, as the parent or legal guardian, you are asked to provide certain pieces of information in order for us to provide you and your child/children with the best possible service. In addition to your contact details and the names and contact information of your family members, your child’s file may include the following information about your child:
• Living arrangements.
• Health information and special needs.
• Personal characteristics, skills and behavioural information.
• Incidents about the child as recorded by our staff.
Personal information is only collected for the following purposes:
• To identify the children in our care and their families;
• To monitor the health and well-being of the children in our care;
• To monitor developmental levels, skill acquisition and special needs of the children. To establish a culturally sensitive and developmentally appropriate program for the children in our care;
• To understand the desires, concerns and opinions of the children in our care and their families;
• To establish and maintain good relationships with the children in our care and their families;
• To provide the responsible child care services expected of a licensed child care program to the children in our care and their families;
• To manage and enhance our business and operations; and to meet legal and regulatory requirements, such as those contained in the Child Care and Early Years Act and its associated Regulations.
Mastering Minds never collects more personal information than is needed to fulfill these purposes, unless you have consented to such collection.
WHEN DO WE DISCLOSE PERSONAL INFORMATION AND TO WHOM
We will make sure that any required disclosures of personal information are made on a “need to know” basis, and where applicable, on a confidential basis, and in accordance with the provisions of the Ontario Child Care and Early Years Act and its associated Regulations. Personal information is never traded, sold or leased by us to any external companies. We may disclose personal information to:
• Public Health
• Ministry of Children & Youth Services
• Mastering Minds’s Board of Directors
• Therapists, volunteers, students on placement with Mastering Minds
• Educational or regulatory observers and other service providers on an as-needed basis in order for them to assist us in managing, providing or evaluating our child care services and program; an agent of a public authority (such as the Children’s Aid Society) if, in our reasonable judgment, it appears that there is imminent danger to life or property which could be avoided or minimized by the disclosure of the information
• A third party with whom we are negotiating in order for them to take over some or all of our services and/or other activities
• A third party where the individual (or his/her parent/legal guardian) has consented to such disclosure; a third party where such disclosure is required or permitted by law.
When sharing personal information we release limited information as required for the function that will be performed by the representative on our behalf. We also ensure that every representative is clear on their obligation to protect personal information and only use the information for the purpose(s) for which it is being provided.
Examples of the Representatives that Mastering Minds may share your limited personal information with include:
• Professionals who may assist us in caring for the physical, emotional, social and/or intellectual well being and/or safety of the children in our care
• Entities that assist us with general administration, including debt collection.
Note that whenever practical, Mastering Minds discloses de-identified information as opposed to personal information.
HAVE YOU CONSENTED
Having read this policy and by enrolling your child in our programs and by providing us with the personal information requested, you consent to the collection, use and disclosure of your personal information as specified herein.
If Mastering Minds will be using or disclosing personal information for purposes that have not been stated in this policy and that we do not feel are obvious to you, we will first obtain your express consent. We may imply your consent if we feel we are using your personal information for purposes that are obvious to you. For example, if you tell us that your child has a food allergy, we may not seek your express consent before providing this information to our kitchen staff. With written notice you may withdraw consent at any time subject to legal or contractual restrictions and reasonable notice. You may contact us for more information regarding the implications of withdrawing consent.
In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual (or his/her parents/legal guardian). For example: If it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated; If seeking the consent might defeat the purpose for collecting the information, such as in the context of an investigation of a breach of an agreement or a contravention of a federal or provincial law; or If there is an emergency where the life, health or security of an individual is threatened.
HOW LONG IS YOUR INFORMATION RETAINED
We retain personal information only as long as it remains necessary or relevant for the identified purposes, and in accordance with legal requirements. Therefore, we will retain your child’s file as long as your child is enrolled in our programs and for a fixed period of time thereafter.
Depending upon the circumstances, where personal information has been used to make a decision about an individual, we will retain the information for a period of time that is reasonably sufficient to allow for access by that individual (or his/her parent/legal guardian).
Mastering Minds retains and securely destroys personal information in accordance with our internal record retention procedure. Our retention procedure takes into account retention requirements for financial and insurance records, the statutes of limitation relevant to injuries that occur while children are in our care, as well as the requirements of the Child Care and Early Years Act and its associated Regulations.
Mastering Minds strives to maintain accurate records of your personal information, however, this cannot be achieved without your help. In this ongoing effort, we ask you to provide us with up-to-date information. Let us know of any personal information you have given to us in the past that is incomplete, inaccurate, or no longer relevant, or of any new issues or information that will help us in caring for your child. If you feel a record in your child’s file is inaccurate or incomplete, and we agree with your assessment, we will promptly correct or complete the information. Any unresolved differences as to accuracy or completeness will be noted in the file.
CONTACT US WITH ANY QUESTIONS OR CONCERNS
Mastering Minds takes full responsibility for the management, confidentiality and protection of the personal information we collect, use and disclose. If you have any concerns about this policy, or feel that Mastering Minds is not abiding by it, please send an e-mail to contactus@masteringminds.org.
