Background
Regional Removal Services is a privately owned sole-proprietorship which is a removal service for deceased persons and transports these deceased persons to funeral homes, to and from hospitals, from homes and scenes. This enterprise works in coordination with the Sudbury Regional Hospital and its related personnel, Lougheed’s Funeral Home, other funeral homes, Office of the Chief Coroner, Regional Coroner, Greater Sudbury Police Department, Ontario Provincial Police, and living and deceased citizens. The service is such that it requires personal information regarding the deceased, next of kin, hospital personnel, coroners, physicians, police officers and Regional Removal Service agents in order to fulfill its mandate. It is imperative that the collection, use and knowledge of private matters be addressed by a privacy policy such as this.
Purpose
Regional Removal Services has developed the Privacy Policy for implementation beginning January 1, 2004. It describes the way it collects, uses, retains, safeguards, discloses and disposes of personal information in its daily management. This service’s goal is to meet the Federal and Provincial legislation and follows the 10 Canadian Standards Association (CSA) principles stated in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). Any posted changes to the afore-mentioned legislations will be made to this document within 7 business days.
1. Accountability
A) The Privacy Officer will be responsible for the service’s compliance with privacy principles. This officer will also be responsible for responding to access requests in accordance with this Policy.
B) The Privacy Officer’s identity will be fully disclosed and accessible to the public in general and to those the service is associated with.
C) Each agent of Regional Removal Services who acts on the behalf of the service will be accountable for the information that they receive and will remit such information to the Privacy Officer for safeguarding.
D) The Privacy Officer will ensure that the service manages all personal information in its possession in accordance with this Policy including that which may be transferred to a third party. Third party organizations who handle information on behalf of the service shall be contractually obligated to adhere to the standards of this Policy and the service.
E) The service will implement internal policies which facilitate adherence to this Policy including but not limited to the following:
i) Security measures at all levels designed to protect personal information in possession.
ii) Implementing procedures designed to respond to complaints and/or inquiries.
iii) Staff training in all facets of information management, including awareness of the service’s Privacy Policy and policies and procedures developed in accordance with the Policy.
2. Identifying Purposes and Type of Information Collected
A) Regional Removal Services shall only collect personal information reasonably necessary to conduct outgoing and incoming calls, coordination of transportation of deceased and work related to its services.
B) Regional Removal Services collects personal information about the deceased including:
- Age
- Gender
- Name
- Date of Birth
- Home Address
- Hospital or scene
- Physician
- Time of Death
- Details of personal effects
- Whether or not an autopsy is to be performed
- DNR
- Next of Kin
- Relationship of Next of Kin
- Phone number of Next of Kin
- Indicated funeral home
- Police Department
- Investigating Officer
- Dispatched time
- Arrival and departure times of Attendants
- Attendants names
C) Agents may access or ascertain information from accompanying hospital documentation while coordinating and transporting deceased including:
- Name
- Age
- Physician A/F/O
- Date of Birth
- Date and Time of Death
- Next of Kin, and information regarding Next of Kin
- Primary Diagnosis
- DNR
- Funeral Home
- Autopsy Indicators
- Organ Donation
- Warnings i.e. MRSA/VRE
- SR Number
- Personal belongings designate
- Who was informed of death and by who
- Allergies
- Coroner if applicable
- Location (i.e. room number, department)
D) The service is affiliated with other organizations as mentioned in the preliminary paragraph (Background) of this Privacy Policy and may disclose personal information described in paragraphs 2b and 2c to these organizations only disclosing necessary information to facilitate the coordination, removal and transportation of the deceased.
E) Regional Removal Services will endeavour to ensure that all collectors of the personal information are familiar with this Privacy Policy and the potential use of the personal data. All personal data will be maintained at Regional Removal Services business location (listed on business cards and paperwork).
F) Regional Removal Services will request individual permission for the use of any personal data collected which is extraneous to that which has been identified above, unless said usage is authorized by law.
3. Consent
A) Regional Removal Services will use the personal information for the uses specified above in Section 2. By consenting to provide the information to Regional Removal Services, you are deemed to consent to the service’s use of the information for the purposes listed in Section 2 and to disclosure of the information to other associated organizations and third parties for the same purpose.
B) Regional Removal Services does not request, collect or have access to complete medical records or complete medical histories of the deceased. This information is not necessary for the fulfillment of Regional Removal Services mandate.
C) If at any time, any party wishes to withdraw their consent to the use of the information collected for any of the purposes, they may do so by contacting the Privacy Officer. Regional Removal Services will do its best to accommodate the request without hindering the service provided. An explanation of the impact of information withdrawal from Regional Removal Services will be given to those requesting to have information removed from paperwork or the computer system.
D)
Regional Removal Services may collect personal information without consent where reasonable to do so and where permitted by law.
4. Limiting Collection
A) All information shall be collected fairly and lawfully within the criteria as set forth in our Privacy Policy.
B) Regional Removal Services shall not indiscriminately collect information. The amount and type of information collected shall be limited to that which is required to fulfill our identified purposes.
C)
Regional Removal Services will not use any form of deception in gaining personal information from its associates or its agents.
5. Limiting Use, Disclosure and Retention
A) Subject to applicable legislation, Regional Removal Services shall limit the use of personal information it collects to purposes identified in Sections 2 and 3.
B) Regional Removal Services shall maintain documents for certain periods of time dependent upon necessity. More specifically:
C) Regional Removal Services will keep paper records indefinitely and electronic documents indefinitely.
D) Should Regional Removal Services enlist the services of a third party, it will contractually commit them to treat personal information consistent with this Privacy Policy.
E) Regional Removal Services may be involved in the transfer or reorganization of its activities. It may disclose personal information consistent with the Privacy Policy of Regional Removal Services.
F) Regional Removal Services may disclose personal information to a government authority that has asserted authority to obtain the information or if the information may be useful in the investigation of an unlawful activity or to comply with a subpoena or warrant or an order made by the court, person, or body with jurisdiction to compel the production of the information or otherwise as permitted by applicable law.
G) Regional Removal Services may at its discretion release personal information for the purposes of collecting debts which may be owed to Regional Removal Services.
H) Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by Regional Removal Services.
6. Accuracy
A) Regional Removal Services shall strive to ensure to the extent that it can that the information entrusted to it is maintained in an accurate manner. It will try to maintain the interests of the individual and attempt to ensure that decisions are not made for or about an individual based on personal information that is flawed.
B) Regional Removal Services may from time-to-time update information to ensure accuracy.
7. Safeguards
A) Security safeguards have been implemented to ensure that personal information is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.
B) The level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected.
C) Methods of protection and safeguards to be employed shall include but will not be limited to locked files, locked office, and passwords.
8. Openness
A) Removal Services will disclose its method by which the personal information is handled when requested and is addressing it by the creation and issuance of this document.
B) Information available includes:
* The name, address and phone number of Regional Removal Services Privacy Officer.
* The forms which are used to access information or change information.
* A description of the type of personal information held by Regional Removal Services and general uses thereof.
9. Individual Access
A) Subject to applicable legislation, upon request by the individual concerned, Regional Removal Services shall disclose whether or not it actually holds personal information on an individual. It shall disclose the source of this information (if known) when requested and provide an account of third parties to whom the information may have been disclosed.
B) Regional Removal Services may request information to confirm the identity of the enquirer before releasing personal information to them.
C) Subject to applicable legislation, Regional Removal Services shall endeavour to provide this information within 30 days of receipt of the information requested and will be presented in an understandable format.
10. Challenging Compliance
A) Regional Removal Services has procedures in place for the resolution of complaints in the administration of its Privacy Policy.
B) Upon receipt of a complaint , Regional Removal Services shall make available the complaint procedures which will be simple and easy to access.
c) Regional Removal Services shall investigate all complaints. If the complaint is deemed justified, Regional Removal Services will take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.
D) All complaints shall be addressed to Regional Removal Services Privacy Officer.
|
