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PRIVACY POLICY

Credit Counselling of Simcoe County has been serving the area since 1973. In providing you with counselling services, we are sensitive to the nature of the information that you provide and diligent with respect to the protection of that information. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services that we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.

WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. It includes information that relates to personal characteristics, health, history, activities and views. Personal information does not include business information, which is not protected by current privacy legislation.

PRIMARY PURPOSES
All personal information you give us is kept strictly confidential and is protected in accordance with the standards set out in the Personal Information Protection and Electronic Documents Act (PIPEDA). Information about clients is collected, used and disclosed for the primary purposes of providing credit counselling services to that client and to contact the client. We may also collect information about people who are not clients, in conjunction with interviewing a client and obtaining particulars about his or her family, history, creditors, etc. or in obtaining information about a prospective client. This sort of information might be used to mediate a dispute between a client and a creditor or for the purposes of third party mediations. Contract Staff that we hire may also provide us with personal information which is collected primarily in order to communicate on work-related issues and in order to contact them when they are not in the office.

SECONDARY PURPOSES
Like many organizations, we may also collect, use and disclose personal information for purposes related to or secondary to our primary purposes. Some examples might to comply with regulatory requirements or if required to disclose information by law or in an emergency situation. We may communicate with The Ontario Association of Credit Counselling Services for general research and reporting requirements. We may also access information in order to ensure high quality services (ie) assessing performance of our counsellors. Various government agencies have the authority to review our files and interview our staff as part of their mandates. Clients may have questions about the services that we have provided after their file has been closed. Finally, we may from time to time retain the services of contractors who may have limited access to personal information that we hold. These consultants or contractors may include computer consultants, office security and maintenance advisors, bookkeepers, accountants, storage companies, temporary workers or volunteers, cleaners, etc. We restrict their access to any personal information that we hold as much as is reasonably possible. We also have their assurance that they will follow appropriate privacy principles. We do not sell information to other organizations.

PROTECTION OF PERSONAL INFORMATION
Our relationship with our clients is based upon trust and confidence. We endeavor at all times to protect the personal information that we collect by, first of all, collecting only relevant and necessary information. We then store that information in locked filing cabinets, restricting access to the information to only those individuals who require it. We utilize security clearances, and shred unnecessary documentation. We delete unneeded computer files and our computers are password protected. We also utilize encryption for any electronic messaging. Our staff is made aware of our commitment to your privacy and our policies in this regard.

AUTHORITY
Wherever possible, we attempt to obtain our clients’ written consent for the collection, use and disclosure of personal information. We utilize the consent form (attached) for this purpose. A client’s personal information may, from time to time, be delivered to third parties as part of our program. In such a case the Agency will request that the client sign specific consents that outline the purposes for passing his/her personal information along to third parties. We also may obtain your verbal consent and document that consent in your file, if written consent is not practical. When you provide your consent to the collection, use and disclosure of your personal information, it is subject to the provisions of this Privacy Policy. Sometimes, your consent will be implied. For instance, when you retain our services and provide us with personal information, your consent to the use of that information in order to supply those services may be implied. If you disclose personal information to us about others, it is your responsibility to ensure that you have consent to do so.

ACCESS TO YOUR PERSONAL INFORMATION
Our clients have the right to review their file in the presence of their Counselor or the Agency’s Privacy Officer (the Executive Director) and request that any incorrect information be corrected. Clients also have the right to file a complaint about the services rendered by the Agency, or to appeal a decision that they consider unsatisfactory. Further information regarding our appeal process is available from our staff. Other individuals may have a right to access certain information that we retain about them, subject to issues of client confidentiality. The Privacy Officer should be contacted to obtain further particulars on the process, including the costs involved.

STILL HAVE QUESTIONS?
Please feel free to email our Privacy Officer or send correspondence to:

Privacy Officer
c/o Credit Counselling
4 Cedar Pointe Dr., Unit R
Barrie ON  L4N 5R7

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of Ontario privacy legislation. The Commissioner also acts as an ombudsman for privacy disputes.