Privacy Policy Urban Native Homes Incorporated collects a great deal of personal sensitive information on tenants during the application process and throughout the duration of the tenancy. We also have personal information on staff, board members and volunteers. Urban Native Homes Incorporated must comply with the Federal Privacy Information Protection and Electronic Documents Act (PIPEDA), which applies to the standards for personal information with respect to commercial activity. Urban Native Homes must also comply with the Social Housing Reform Act regulations that set the standards for the collection, use, disclosure and safeguarding privacy of personal information and individual right of access of their own information as it applies to rent-geared to-income tenants. This policy meets the requirement of the Social Housing Reform Act and the Privacy Information Protection and Electronic Documents Act. The collection and storage of personal information should be treated in a manner that is respectful of the individual. PRIVACY OFFICER Rose Antone, Tenant Counselor, is the Privacy Officer. She will be responsible for the organization's compliance with all privacy legislation. The Privacy Officer's duties are to: Review the Urban Native Homes Incorporated policies and practices with regard to personal information. Implement the necessary changes to guarantee that the collection and retrieval of personal information follow the Urban Native Homes Incorporated policy. Inform the tenants and public on how Urban Native Homes treats personal information. To ensure that Confidentiality Agreement is signed on an Annual Basis. Handle complaints. Definition of Personal Information For the application of this policy, personal information means: The personal address, telephone number or email address of the individual Any identifying number assigned to an individual which can lead to their identification (e.g. Social Insurance Number) Information about an individual's income and assets Bank Account and credit card information Information about rent payment history Information relating to the race, nationality or ethnic origin, citizenship status, colour, religion, age, sex sexual orientation, marital or family status of the individual Information relating to the education, medical, psychiatric, psychological, criminal or employment history of the individual Credit and rental history reports Financial information for the purposes of establishing Rent-Geared-to income Assistance An individual blood type or fingerprints Information about an individual's personal or political opinions Correspondence sent to Urban Native Homes that is of a private or confidential nature, and any replies from Urban Native Homes that would reveal contents of the original correspondence The individual's name if it appears with other confidential information (e.g. rental arrears reports) Employee information including resumes, salary and benefits, disciplinary action, bank account information, tenant complaints about the individual, and problems between staff Personal information does NOT include the name, position and business phone number of employees. Personal information does NOT include statistical data, which is summarized in such a way as to not identify any individuals. Business contact information - available information such as name, address and telephone number (as published in telephone directories) are not considered personal information. COLLECTION OF INFORMATION Personal information will be collected only for the following purposes: To approve tenancy and determine appropriate unit type and size To determine income and assets for rent calculation To demonstrate compliance with funding requirement To protect the health and safety of the tenant To ascertain service levels required in special needs housing To conduct reference and employment checks To retain relevant information on employees for government reporting purposes Staff must not seek out personal information of tenants or applicants unless it is relevant to their work. All document used for collection of personal information state the purpose or purposes of the collection; the reasons for collection, including the fact that the information may be shared as necessary for the purpose of making decisions or verifying eligibility for assistance under the Social Housing Reform Act, the Ontario Disability Support Program Act, 1997, the Ontario Works Act, 1997or the Day Nurseries Act; or as authorized by an agreement under section 163 or 164 of the Social Housing Reform Act; the name, title, business address and business telephone number of the Privacy Officer who can answer questions and respond to complaints about the collection, use or disclosure of the information; and will include a consent form to be signed by the applicant or tenant authorizing the collection, use, verification disclosure of the information being collected PROTECTION OF INFORMATION All staff and board members will be required to sign a confidentiality agreement. Applicant, tenant and employee files (including information on databases) must be safeguarded against unauthorized access. Applicant/tenant information and employee information must be stored in a locked filing cabinet. Secure storage facilities must be provided for archived applicant/tenant/employee and accounting information. Staff and member of the board, where appropriate, should have access to records containing personal information only if required in order to fulfil their duties When communicating tenant issues to the Board, staff should use non-identifying information as much as possible. For example, arrears report should use codes in place of the actual names of tenants. Databases containing files with personal information, and other confidential electronic files must be password protected against unauthorized access. Screen-savers or other protective action will be used to protect confidentiality of personal information on computer monitors. All staff have a responsibility to ensure that unauthorized individuals do not have unsupervised access to areas where files are kept and used. Personal information will be disposed of at the end of the required storage period for tenant records of 5 years after the tenant has moved out, and for financial records of 7 years after the end of the fiscal year. Paper-based personal information must be shredded prior to disposal. Electronic media must be purged prior to disposal. RELEASE OF INFORMATION No personal information will be released to third parties without the written consent of the individual (for example: credit references, tenant or personal references). When responding to enquiries for references, staff should limit information provided to the questioner and confirm only the information already provided by the individual making the inquiry. It is not necessary to have a signed consent to release information to collect a debt, for example to a collection agency, or for an Ontario Rental Housing Tribunal or Small Claims action. Staff will take reasonable care to confirm the identity of the people to whom information is released. Personal information will be released to the following: Funders and Auditor: Urban Native Homes in order to be in compliance with funding program requirements, must release information to funders and auditors. People doing these jobs have their own professional code of ethics and are required to maintain confidentiality. Staff should confirm that the person concerned is seeking access legitimately. Access Centre: As part of its responsibilities to the Co-ordinated Access System, Urban Native Homes will provide the Access system with information about tenants who have left in arrears. This information will be used by the Co-ordinated Access System as part of their screening process for applicants for non-profit housing. Researchers: Occasionally, Urban Native Homes may be asked to assist a researcher who may be from an academic institution or who may be independent. Authorization for such people to have access to files will depend on their credentials and the nature of their research. The Board of Directors must approve all such requests for personal information. Credit Bureau: Information on orders or judgements for money owing will be provided to any credit bureau of which Urban Native Homes is a member. Law Enforcement: While Urban Native Homes has a responsibility to protect the rights of applicants and tenants to privacy, this responsibility must be balanced with an obligation to the broader community. Law enforcement agencies requesting personal information about applicants, tenant, employees, board members or volunteers, will be required to provide a written request or "warrant" before information will be released. Personal information may be released to the police: In the context of reporting criminal activity, staff with personal knowledge should report theft, damage or fraud. With respect crimes against persons, witnesses are obligated to report and provide appropriate information to the police so that charges can be laid. Domestic violence is a criminal offence and should be reported to the police. To report suspected criminal activity. If there is a good reason to believe that there is a drug problem or other illegal activity in the building, this should be reported to the police. Victims of crimes are responsible for reporting the crime directly to the police. However, if the victim is a child or a person with a disability that renders them incapable of making the decision to report, the legal responsibility lies with Urban Native Homes to report the crime to the Police or Children's Aid Society, if it has relevant information. In the case of suspected child abuse, information will be provided to the Children's Aid Society. (This duty to report is required under the Child and Family Services Act, Section 72) Health and Safety Officials: Personal information will be provided to outside agencies, individuals and institutions when it can be clearly identified as contributing to the applicant or tenant's benefit, for example, information about an individual's medical condition to the fire department. Next of Kin or Emergency Contacts: It may be appropriate to use personal information to contact a community service agency or a designated relative in exceptional circumstances, such as, when using an emergency contact provided by a tenant and held on file, or contacting medical support services when a tenant is unable to function and maintain his/her tenancy. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION The Privacy Officer will respond to all requests for access to or correction of personal information. An individual who provides satisfactory identification will be informed of the existence, use and disclosure of his or her personal information and will be given access to the information. The privacy of others' personal information must be protected when giving an individual access to his or her own personal information. If the Privacy Officer believes that releasing personal information to an individual would prejudice the mental or physical health or security of any person, he or she will not release the information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. If the Privacy Officer is not in agreement with the individuals request for correction, a counter-statement will be filed with the original information. PROCEDURE FOR HANDLING COMPLAINTS The Privacy Officer will respond to all complaints about collection, use, disclosure, storage and disposal of personal information within thirty day of the request being made, and advise the complainant as to the action that has been taken. Each complaint will be assessed to determine whether: Correction of personal information is necessary. Information was collected, used, released or disposed of inappropriately. Urban Native Homes policies and procedures need to be strengthened. Disciplinary or other action needs to be taken with respect to a breach of a confidentiality agreement. Where necessary, the Privacy Officer will make the necessary recommendations to the Board of Directors in connection with resolution of the complaint. BREACH OF CONFIDENTIALITY It is a breach of confidentiality to: Discuss any confidential information within or outside the organization where it may be heard by individuals who are not authorized to have access to that information. Provide confidential information or records to unauthorized individuals. Leave confidential information in written form or displayed on a computer terminal in a location where it may be viewed by unauthorized individuals. A breach of confidentiality may be grounds for staff to be disciplined or terminated. A breach of his or her confidentiality obligation may be grounds for a board member to be removed as a director of the corporation. A board member who breached confidentiality may not be covered by Urban Native Homes insurance if he or she is sued for libel. Urban Native Homes, Inc. 795 King Street East, 2nd Floor Hamilton, Ontario L8M 1A8 Phone: (905) 548-6974 Fax: (905) 548-6808 Privacy Policy E-mail Contacts: lewisj@on.aibn.com Janice Lewis, Executive Director Ext. 27 bomberryp@on.aibn.com Penny Bomberry, Financial Administrator, Ext 25 trudeaut@on.aibn.com Tammy Trudeau, Administrative Assistant, Ext 23 williamsv@on.aibn.com Valerie Williams, Tenant Counsellor, Manager, Ext 29 antoner@on.aibn.com Rose Antone, Tenant Counsellor, Ext 30 alessims@on.aibn.com Mary Sue Alessi, Maintenance Office Administrator, Ext 31 beckerr@on.aibn.com Ryan Becker, Maintenance Coordinator, Ext 24 workmanl@on.aibn.com Laura Workman, Tenant Counsellor Assistant, Ext 28 josephk@on.aibn.com Kitty Joseph, Receptionist, Ext 21 Office Hours: Monday - Friday 8:30 am - 4:30 pm. 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