Shannex Incorporated Privacy Policy
Overview
Policy: Shannex is committed to respecting and safeguarding the privacy of our stakeholders and to ensure the protection of personal information of our employees, residents, families, and customers. Confidentiality and privacy of information is paramount to the way we do business.
Personal information means information about an identifiable individual, but does not include the name, title, and business address or business telephone number of an employee of an organization.
A record may include the following: Any correspondence, minutes, agenda, contract, memorandum, book, plan, map, drawing, diagram, pictorial or graphic work, photograph, film, microfilm, sound recording, resident file, resident health care record, resident and company financial records, employee files, videotape, machine-readable record and any other documentary material, regardless of physical form or characteristics and any copy of those things.
Examples of personal information include the following: any factual or subjective information, recorded or not, about an identifiable individual. This may include age, ID numbers, SIN number, income, ethnic origin, or blood type, opinions, evaluations, comments, social status, or disciplinary actions, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, and driver’s abstracts.
Personal Health Information is defined as information concerning an individual’s physical or mental health, any health service provided to an individual, the results of testing performed on an individual or information collected, directly or indirectly, while providing health services to an individual.
Our practices conform to the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information (CAN/CSA-Q830-96). Our practices also conform to national health care standards for Information Management as established by the Canadian Council on Health Services Accreditation (CCHSA).
The CSA Model Code for the Protection of Personal Information is a set of interrelated principles:
The Ten Privacy Principles that govern Shannex privacy commitment are:
Accountability
Handling Customer Complaints and Suggestions
Identifying Purpose
Limit Collection, use, and retention
Limit Disclosure
Consent
Openness
Accuracy
Access
Appropriate Safeguards
Shannex has policies in place that address all of the above principles.
Accountability
Shannex has an individual designated as a Privacy Officer and has organizational accountabilities with respect to privacy.
The role of the Privacy Officer is to ensure the organization’s compliance with the principles set out in the National Standard of Canada Entitled Model Code for the Protection of Personal Information, CAN/CSA-Q830-96.
The Privacy Officer has three main accountabilities:
Lead communications to our stakeholders
Proactively manage privacy issues
Resolve complaints and concerns
The name of the Privacy Officer shall be made known upon request to any individual.
Handling Customer Complaints and Suggestions
There is a process for employees, residents and family members to address complaints and concerns, and to make suggestions with respect to the privacy of their personal information. This process ensures complaints, concerns and suggestions are addressed in a timely manner and that corrective action is taken to protect the personal information of employees, residents, volunteers, students and families. You may relay your concerns to a facility manager who will ensure the Divisional Director/Privacy Officer are notified, or you may contact the Privacy Officer directly. Complete contact information is provided at the end of this policy.
Identifying Purpose and Limiting Collection
Shannex identifies the purpose for collecting personal information prior to, or at the time it is being provided, to ensure that personal information will not be used without individual consent, unless a consent exception applies.
Access to Records and Information
All Resident, Employee and Company records shall be confidential and shall not be made available to any person or agency except with the consent or authorization of the person or resident concerned. Shannex may access personal and confidential information as part of its normal course of business.
Shannex makes reasonable efforts to provide the protection of personal information that has been outsourced to a third party for processing. e.g.: pharmacy, resident tax returns, etc.
Openness
Shannex shall ensure reasonable access to its policies and practices relating to the management of personal information. Our privacy policy is available on our website at www.shannex.com, on our intranet, in our Information Services manual, as well as in a brochure designed to communicate our privacy practices to our stakeholders.
Consent
Shannex collects and uses personal information about you with your knowledge and consent. We will not share personal information beyond the use that it was intended.
Reasonable efforts shall be made to ensure the knowledge and consent of employees and residents are obtained for the collection, use, or disclosure of personal information, except where exceptions may apply. Consent can also be given by an authorized representative such as a legal guardian or a person having power of attorney.
There are instances where Shannex may use information without the consent of the resident or employee. For example: In a medical emergency, where the information is used for the purposes of acting in respect of an emergency that threatens the life, health or security of an individual. e.g.: emergency hospital transfer.
•Where it is reasonable to expect that the collection or use of the information with the knowledge or consent of the individual would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of a law. e.g.: fraud investigation.
•If the information is required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with the rules of the court relating to the production of records. e.g.: warrant to search, College of Registered Nurses of Nova Scotia.
•If the information is provided to a government institution that has made a request for the information, and identified its lawful authority to obtain the information, e.g.: CCRA, HRDC.
Front line employees do not have the ability to dispense with consent under the examples noted above. Any exceptions to the principle of consent must be granted by the Divisional Director or Privacy Officer.
A resident or employee can withdraw consent at any time. The way in which Shannex seeks consent may vary depending upon the circumstances and the type of information collected.
Accuracy
Shannex will take reasonable efforts to ensure personal information, as provided by the employee, is as accurate, complete and up to date as is necessary for the purposes for which it is to be used. It is the responsibility of employees, residents and family members to ensure that personal information supplied to organization is accurate and up to date ,e.g.: emergency contact names and numbers.
Access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. In certain situations, Shannex may not be able to provide access to all the personal information it holds about an individual. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. Request forms are available for resident and employees to access their information.
Shannex allows only authorized staff, contractors and students to access and use specific data holdings or personal information when required to perform their duties. All Shannex employees are required to report all attempts at unauthorized access to the records to the Privacy Officer.
All requests for information from external parties must be in writing and forwarded to the attention of the Privacy Officer.
Retention
Personal information shall be retained and stored as long as necessary for the fulfillment of the intended purposes, or as long as required by legislation. Shannex has defined retention periods, storage, and specifies methods of disposal once that information is no longer required.
Confidentiality
Confidentiality is the non-disclosure of certain information except to an authorized person with the appropriate consent. Upon employment with Shannex, every employee is required to sign an Employee Statement of Understanding with Respect to Confidentiality. Every employee also receives the Shannex Standards of Employee conduct booklet. Education on Shannex Standards of Employee Conduct is mandatory.
If you contact us on line, the following may be important to you:
Employment Application
Shannex Health Care collects personal information from you when you make a job application.
Employment applications may be made on line. When you make an application, required personal information collected about you includes:
•position applied for,
•shift availability,
•your full name and address,
•whether or not you are bondable,
•whether or not you are legally eligible to work in Canada.
Other information that may be provided by you is:
•Availability to begin work
•Desired salary
•Contact phone numbers
•General employment and education history
•Driving record
•Activities/interests
•References
Any information you provide us with will be used for our recruitment process. If you are hired, your application will form part of your personnel file.
E-Mail
When you send us an e-mail, you provide us with your name and e-mail address along with any other information you provide in the body of the e-mail. This information may be shared with other people in Shannex when they are required to receive this information in order to respond effectively to your query.
Cookies
Cookies are small text files that are transferred to your hard drive by a web server. Cookies only contain text and therefore cannot transmit a virus or damage your system. They are commonly used to determine return visitors to a site, pages viewed, etc. Shannex does not use cookies on www.shannex.com. Shannex offers links to other health related web sites. These sites may use cookies. Users are strongly urged to review the privacy policies of linked web sites.
Links
The Shannex web site contains links to other sites. Please be aware that Shannex is not responsible for the privacy practices of such other sites. We encourage our users to be aware of privacy issues and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by the Shannex web site.
Log Files
Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. IP addresses are tied to personally identifiable information to enable our Web-based service.
Limitation of Liability
If you are providing information on line, complete confidentiality and security is not yet possible over the Internet. Internet use and communication is subject to interception, loss and alteration. On whichever site you provide personal information, it is possible for a third party to view that information. You acknowledge that Shannex Health Care shall not be responsible for any damages you may suffer as a result of transmission of confidential or sensitive information over the internet, and as such, all communications will be at your own risk.
Contact Us
We hope that this statement is clear and informative. Please write, phone, fax or e-mail us regarding any questions or further information you may in interest in.
Privacy Officer
156 Parkland Drive
Halifax, NS
B3S 1N9
Phone: 1-877-SHANNEX
Fax: (902) 453-5412
E-mail: privacyofficer@shannex.com
