Privacy policy - Responsive Group Inc.

Overview

Responsive Group Inc. and our affiliates, parents and subsidiaries (collectively “Responsive”, “us” or “we”) are committed to protecting personal information in our custody and control, including through the development of appropriate information practices, as set out in this Privacy Policy (the “Policy”).

As part of this commitment, we strive to comply with all federal and provincial privacy legislation and meet or exceed all industry standards in respect of the protection of personal information.

We have also appointed a Privacy Officer to oversee our compliance with all privacy-related matters and to serve as the main contact person regarding privacy issues.

This Policy will set out how we collect, use, disclose and otherwise manage personal information.

What is Personal Information?

“Personal information” is any personally identifiable information about you, such as your name, home address, banking/credit card information and personal health information, such as health conditions, health history, health care treatments received, etc.

Personal information is to be interpreted broadly and includes subjective information about you, such as your preferences, opinions and interests.

Business contact information is not considered personal information, provided that the information is collected, used, or disclosed solely for the purpose of communicating with a person in relation to their employment, business or profession.

Consent

We rely on your informed consent to collect, use and disclose your personal information, which may be provided orally, in writing or by any other method. Your consent may be expressed or implied, but in certain limited circumstances, the law requires it to be expressed.

By providing us with your personal information, you are consenting to its collection, use and disclosure, in accordance with this Policy.

If you are not capable of providing your consent to the collection, use and disclosure of your personal information, consent may be provided by a person authorized to act on your behalf. We will presume that you are capable, unless it would be unreasonable to do so.

We will not refuse to provide you with services if you do not provide us with your personal information, unless your failure to provide such information precludes us from providing the service.

You may withdraw consent regarding the collection, use or disclosure of your personal information at any time, subject to legal or contractual restrictions and the provision of reasonable notice.

Collection and Use of Personal Information

We do not collect personal information indiscriminately. We limit both the amount and type of personal information we collect to that which is necessary to fulfill the purposes that we have identified to you, or as otherwise permitted or required by law.

We collect and use personal information for the following purposes:

communicating with members of the public about the services that we provide, including the services provided by our retirement home and long-term care home facilities (the “Homes”). This may involve the collection of a person’s name and contact information, including address, telephone number and/or email address and other information;
organizing tours of our Homes, which may involve the collection of a person’s name, contact information, interests and preferences;
providing housing and care services to the residents that live in our Homes, which may involve the collection of their contact information, financial information, marital status, health conditions, religious beliefs, interests and preferences, etc.
entering into residency agreements with prospective residents, which may include the collection of their contact information, identity of their roommates and/or authorized representative, vehicle information, etc.;
providing and coordinating the delivery of health care to our residents, including communicating with healthcare providers. This will involve the collection of various types of personal health information, including but not limited to current health conditions, health history, medications utilized, identification of health care providers, health card number, drug plan information and eligibility for health care coverage;
communicating with our residents and identifying and communicating with their substitute decision-makers and other authorized representatives;
determining the most appropriate type of facility and level of care for an individual, which may include a review of their current health conditions and/or expressed preferences;
accommodating the needs of residents with disabilities, which may include a review of their current health conditions, health history and devices/aids utilized by the resident;
assessing the ability of a prospective resident to provide payment for housing and care services, which may include a review of their income information, rental history, credit history and credit checks;
obtaining payment for services rendered, including but not limited to housing and care services. This will involve the collection of contact information, as well as banking and/or credit card information;
educating and training our employees, volunteers and other agents;
improving quality of care, including in respect of services and programs offered at our Homes;
maintaining security at our Homes and other premises, including through the use of video surveillance, sign-in/sign-out sheets and other methods;
conducting health screening at our Homes and other premises, as indicated, including collecting and reviewing various types of personal health information, which may include current symptoms, laboratory test results and temperature testing; as well as travel history and contact with other persons;
developing and maintaining infection prevention and control (IPAC) practices at our Homes and other premises, including communication of IPAC practices and expectations to residents, staff and visitors;
conducting research, analysis and modeling to improve our services;
understanding the preferences, opinions and interests of residents and prospective residents;
planning, administering and managing our internal operations;
risk management activities, including identifying, assessing and controlling risk;
assessing and responding to applications for employment, including the collection and review of contact information; work eligibility information; criminal and other background checks; educational and work qualifications; work history; references; etc.
complying with our obligations as an employer, including administering payroll (i.e. rates of pay, salary, hours worked, tax and other source deductions); managing employee benefit plans, such as extended health insurance and registered retirement savings plans; administering parental and sick leaves; assisting with employee relocation; responding to workplace accidents or injuries; and making reports as required by law;
performing behavioral and/or cognitive assessments of employees to assess fit with specific roles and requirements;
marketing purposes, including using employee/resident names and likenesses in various media, such as websites and social media, and in printed communications such as brochures, newsletters, etc.;
verifying identity of employees to confirm permission to access premises, computer networks, telephone systems and other corporate resources;
marketing purposes, including using employee/resident names and likenesses in various media, such as websites and social media, and in printed communications such as brochures, newsletters, etc.;
complying with applicable laws and the requirements of regulators.

We may also collect personal information about you for other purposes. We will always identify any additional purpose prior to or at the time of collection.

In most cases, we will collect personal information either directly from you or from a person authorized to act on your behalf. On occasion, we will collect personal information about you from other sources, where we have obtained your consent to do so or where it is permitted by law.

Sharing of Personal Health Information

We may share your personal information in the following circumstances:

to a person who, in our reasonable judgment is seeking information as your authorized representative;
to a service provider that is performing administrative functions for us, such as storing or processing personal information;
to a service provider that is providing education and training services to our employees and other staff;
to a health care provider who is providing health care services to you, such as a physician or pharmacist, for the purpose of providing healthcare to you or assisting in the provision of health care;
to a bank or credit card company to process payments for services provided by us;
to our legal advisors, in respect of a legal matter or potential legal matter;
to one of our affiliates or partners;
to a third party that may be interested in purchasing one or more of our Homes and personal information is to be shared in order to assess the business transaction;
to meet requests for information from regulators to satisfy regulatory requirements applicable to us; and
as otherwise permitted or required by law, such as complying with applicable legislation or a subpoena or court order.

You have the right to instruct us not to share your personal information with specific third parties, subject to legal or contractual restrictions and the provision of reasonable notice.

Accuracy

We take reasonable steps to ensure that personal information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

The extent to which personal information shall be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.

We do not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.

Personal information that is used on an ongoing basis, including information that is disclosed to third parties, will generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.

Information About our Website

Please feel free to visit our website, https://responsivegroup.ca (the “Website”) to obtain more information about us, including the services that we offer.

If you would like to be contacted by us, our Website provides you with the opportunity to submit your name and contact information, such as your email address and telephone number.

Our Website uses “cookies” and other similar technologies. Cookies are text files containing small amounts of information, which are downloaded onto the browser of your computer, smartphone or other device, when you visit our Website. We use cookies to track your use of the Website, including how you access and engage with the Website (i.e. type of device utilized, how you arrived at the Website, duration of visit, pages reviewed, etc.), so that we can improve functionality, increase the relevance of content and enhance your browsing experience.

We also utilize Google Analytics, which is a service offered by Google that uses cookies to track and analyze how visitors use our Website, including as described in the preceding paragraph. We can access this information in various reports prepared by Google Analytics. For more information about Google Analytics, please refer to https://analytics.google.com/analytics/web/provision/#/provision.

You can prevent the installation of cookies, delete existing cookies, and otherwise manage cookies, by selecting the appropriate settings on your browser. To obtain more information about adjusting cookie preferences, please refer to http://files.investis.com/info/disabling-cookies.html.

If you would like to opt out of Google Analytics, please refer to http://tools.google.com/dlpage/gaoptout.

Location of Personal Information

In accordance with current law, your personal information may be stored or processed in Canada or in another jurisdiction.

Please note that although we always strive to protect your personal information, it remains subject to the laws of the jurisdiction in which it is held.

Retention of Personal Information

We will only retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected.

In certain circumstances, however, we are required by law to keep information for longer periods. For example, in most cases, provincial legislation requires us to retain records of personal health information for a minimum of 10 years after the last date of service.

We dispose of personal information that is no longer required by permanently destroying or deleting the information, in accordance with prevailing industry standards.

Safeguards

We utilize various safeguards to protect your personal information from theft, loss, unauthorized access, use, copying, modification, disclosure and disposal.

These safeguards include physical measures (i.e. alarms, locked filing cabinets and restricted access); administrative measures (i.e. policies and procedures, security clearances and limiting access on a need-to know basis); and technological measures (i.e. use of passwords, firewalls and encryption). The safeguards utilized may vary depending on the sensitivity of the personal information and the risk of harm to the individual. For example, financial information and personal health information are considered highly sensitive and necessitate a higher level of protection.

We protect personal information regardless of the format in which is stored (i.e. paper record, electronic, etc.).

All of our employees and volunteers receive privacy training, including in respect of this Policy, at the time of hire and on an ongoing basis. Our employees and volunteers are also required to enter into a confidentiality agreement to confirm their commitment to maintain the confidentiality of personal information.

If personal information is provided to a third party organization, we will use contractual or other means to ensure that a comparable level of protection is being provided.

We review our security safeguards on an regular basis, including through the performance of privacy audits, to ensure that they are up to date and effective. Wherever indicated, we will make changes to our safeguards, including in response to changing technologies and the emergence of new risks.

Access and Correction to Your Personal Information

You have a right to request access to your personal information and to request corrections to your personal information. Such requests are to be made in writing to our Privacy Officer, who will respond within 30 days. We may require you to provide information/documentation to verify your identity and authority to make an access or correction request.

Subject to certain limited exceptions, as set out in law, we will provide you with access to your personal information and correct personal information that is not accurate or complete.

If we do not comply with an access or correction request, we will ensure that we provide you with the legal justification for our decision.

Changes to this Policy

We review this Policy on a regular basis and will make amendments to it from time to time to reflect changes in our information practices and/or changes in law.

A current version of this Policy is posted on our Website, https://responsivegroup.ca, and is also available upon request.

Questions or Comments

If you have any questions, comments, or concerns about this Policy, or any privacy-related issue relating to Responsive Group Inc., please feel free to contact our Privacy Officer, who can be reached at the following coordinates:

Privacy Officer
Responsive Group Inc.
3760 14th Avenue
Suite 402
Markham, Ontario
L3R 3T7
privacy.officer@responsivegroup.ca

October 2020