Copyright 2009 Catholic Family Services of Durham

Privacy Compliance Program

Policy

It is the policy of Catholic Family Services of Durham to fully comply with provincial
and/or federal legislation pertaining to the protection of personal health information
through the implementation and maintenance of a privacy compliance program.

Standard

A chief privacy officer shall be appointed and shall be responsible for overseeing
the agencyís privacy compliance program and ensuring the organizationís
compliance with its privacy obligations in accordance with the act.

Guidelines and Procedures

The Chief Privacy Officer shall be the Executive Director or designate and be
responsible for:

a. ensuring that the organization has policies and procedures which address the
requirements as regulated in the Ontario Personal Health Information Protection
Act (PHIPA, 2004), and any applicable regulations that may serve as best
practices in the Personal Information Protection and Electronics Documents Act
(PIPEDA, 2004);

b. conducting an audit at least every four years, or more often if required, of the
personal information policies and practices of the organization;

c. reviewing and analyzing the organizationís policies and practices for collecting,
using and disclosing personal information regarding staff, volunteers, clients,
users of Family Life Education and Wellness services and donors;

d. implementing procedures to safeguard personal information;

e. taking appropriate action in response to any breach of privacy, in accordance
with the Personal Information Protection Action (PIPA) 2004, as outlined in
detail in the Board Policy on Secure Storage of Client Records (5.13);

f. ensuring individuals have the right to access and correct any personal
information about themselves held by the organization;

g. implementing a retention and destruction of information policy;

h. acting as a contact person for inquiries from the public or clients and ensuring
that public access obligations are met regarding privacy (confidentiality)
policies;

i. ensuring that there is an established process of handling complaints about the
organizationís information practices and/or alleged violations;

j. training the organizationís staff, students on field placement and volunteers.
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