Reena Privacy Policy

Effective April 2024 

We are committed to you 

Reena and Reena Foundation (“Reena”, “we”, “us”) are non-profit organizations established in Ontario. At Reena we believe in creating a safe environment and building community relationships based on trust. We are committed to protecting the privacy of the individuals we support, employees, volunteers, donors and other stakeholders whom we interact with. We value the trust of those we deal with, and of the public, and recognize that maintaining this requires that we be transparent and accountable in how we treat the information that you choose to share with us.  

During our various activities, we may gather and use your personal and health information (“information”). At Reena, our staff are committed to ensuring that your information is held in the strictest confidence. Reena’s Privacy Officer is responsible for the overall compliance with applicable privacy legislation (including health information legislation) and our privacy practices.  

This Privacy Notice is meant to demonstrate the measures we have taken to protect your information and provide you with transparency about how Reena and Reena Foundation collect, use, and share your information when you interact with our websites https://reena.org/  or https://reenafoundation.org/ (“Website”), our homes, our events, programs and services (“Services”), or when you apply for a job at Reena. 

If you choose not to provide us with your information, you may not be able to fully engage with the Website or our Services.  

We will occasionally update this Privacy Notice. We recommend that you check our Privacy Notice from time to time to keep yourself informed of any changes. If you continue to use our Website or Services at any time after we post our revised Privacy Notice, we will assume you agree to the changes made to the Privacy Notice. If we make significant changes to our Privacy Notice, we will post a notice on our Website and depending on the circumstance, we may communicate those changes with you via email notification. 

COLLECTING INFORMATION 

We only collect the information we need to communicate with you, invite you to events we feel would be beneficial or of interest to you, provide you with funding opportunities, provide you with our Services, discuss financial aid or donations with you, and/or meet any legal obligations we have in terms of the Personal Health Information Protection Act (PHIPA), Part X of the Child, Youth and Family Services Act (CYFSA) or otherwise. We also collect applicable employment-related information when you apply for a job or volunteer with us.  

Personal Information is information that can directly or indirectly identify you. It includes information that relates to or could reasonably be linked directly or indirectly to a particular person. Personal information does not generally include business information, such as your work email address or job title. Furthermore, de-identified or aggregated information is not considered Personal Information.  

Personal Health Information is information about an individual in oral or recorded form that relates to an individual’s physical or mental health (including health history), health care (including the identification of the individual’s health care provider), plan to set out the individual’s home and community care services provided by a health service provider or Ontario Health Team pursuant to the Connecting Care Act, 2019, payments of eligibility for health care, donation of any body part or bodily substance, health number, or substitute decision-maker. 

Reena will only collect the necessary personal or health information as identified below.  

We collect your information as needed directly from you, from a third party (e.g. your circle of care), or through your use of our Website.  

Directly from you 

 Most of the information we collect is directly from you when you: 

• request or require home support, personal support or health services – we collect your information with your consent regarding your general health, medical history and status, your capabilities and ability to perform daily activities, financial information, tax information, and the type of support you require so that we are best able to evaluate how to support you either directly from you or your substitute decision-maker; 

• apply to work or volunteer – we request employment-related information which may include vulnerable sector clearance and/or police or background checks based on the access to individuals and information you may have as well as qualifications required;  

• visit one of our locations – we may require verification of your identity;  

• sign up to receive news and advertising – we collect your email address for our contact list and where appropriate your consent;  

• attend events – we collect your contact information and consent for photography; and/or  

• make a donation – we collect your contact information and other information required by law when receiving a donation.  

If at any time we require more or different information, or your information is required for a purpose other than the purposes outlined in this Privacy Notice, you will be notified, and your consent will be obtained before collecting or disclosing any further Personal or Personal Health Information.  

From a third party: 

 There may be instances when we require certain information from third parties to provide you with the appropriate level of care as part of our Services. This information may be collected from a third party (e.g. a referral organization (with your consent), a family member, your health care provider etc). In this event, we will ask you to sign a consent form giving us your express written consent for all the required information for the purpose of providing you with our Service.  

Automatically:  

Surveillance 

When you enter some of our physical locations, you may be recorded by our video surveillance to protect and provide safety to our individuals and the public. 

 Use of Cookies 

We use cookies on our website to understand how visitors and/or users interact with our website. “Cookies” are small text files which are saved on your computer’s browser when you visit a website. You are able to change your browser settings to refuse, remove, or block cookies. If you disable cookies, it may affect the functionality of the website. Choosing to navigate our website without disabling cookies indicates your consent for us to use cookies in accordance with this Privacy Notice. 

Cookies do not collect personally identifiable information about a user. Through the use of cookies, we may collect your IP address, device ID, browser type, operating system, access time and referring website address. We collect this information from your device or browser. 

 We use cookies to personalize your access and help you navigate our website. Through the use of cookies, we may automatically collect information about your activities on our website such as the pages you visit, the time of your visits, and the links you click.  

 We use the following types of cookies: 

• Strictly Necessary Cookies: These essential cookies are necessary to provide you with functionality and access to the website.  

• Analytics Cookies: These cookies collect anonymous, passive information about how you use the website, including web pages you visit and links you click. We use the information to improve and optimize our offering.  

• Functionality Cookies: These cookies allow us to remember your choices on our website and therefore provide you with enhanced features and personalized content. For example, these cookies help us remember your name or preferences. While functional cookies can be disabled, this may result in less functionality. 

• Targeting Cookies: These cookies are used to serve advertisements to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are correctly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. 

We make use of Google Analytics to monitor and analyze the use of our Website. You can opt out from the use of Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add On. Google’s Privacy Policy is available here: policies.google.com/privacy. 

SHARING YOUR PERSONAL INFORMATION: 

 Only necessary information is shared with (i) individuals at Reena involved in your care; or (ii) individuals we are permitted to share information with based on privacy legislation. Upon intake, where appropriate, your disclosure preferences are recorded and stored in your personal file. Client names are never shared with any individual or organization for the purposes of commercial activity, such as selling, trading and/or renting your Personal and Personal Health Information. We do not sell or distribute your Personal or Personal Health Information. We only share your information in limited circumstances and we take measures to limit who we share your Personal or Personal Health Information with, how much information we share, and how your Personal or Personal Health Information will be used.  

In regard to Personal Health Information retained by Reena, we will seek your express consent to disclose Personal and/or Health Personal Information outside the circle of care when appropriate access requests are received. In this instance, Reena documents Personal and Personal Health Information disclosures that are made to third parties which would not require your information for routine, day-to-day purposes.
 

We will only share your Personal Health Information under the following circumstances: 

• Your circle of care: various health care providers may require information from us regarding the Services we provide to you. This disclosure is made strictly in accordance with PHIPA or with consent, where required;   
• With other third parties: only with your consent or where required by or permitted by law; 
• With law enforcement or governmental authorities: as required or permitted by law.​​​  

HOW WE PROTECT YOUR INFORMATION: 

Reena considers your Personal and Personal Health Information extremely confidential. To keep your trust we have implemented security safeguards, including organizational, technical, and physical measures, to protect your information from unauthorized access or loss. The safeguards we implement, such as firewalls and password protection systems are in line with the sensitivity of the information we collect and store. We use role-based access rights because we believe that only those who need to know, should know. While we have taken steps to protect your information, there is no guarantee that computer systems or online communications, such as email, are secure. We encourage you to be vigilant about the information you provide to us and how you secure your own environment. All our staff are trained on the confidentiality requirements.  

We may include links to other third-party websites on our website. When you click on these links, you will be directed to a website operated by another entity which may have its own privacy policy. We encourage you to read their policy. We are not responsible for the privacy practices of those websites.  

HOW LONG DO WE KEEP YOUR INFORMATION: 

 Reena will continue to have access to your information even after your Services come to an end and we no longer have a relationship with you either as a supported individual or employee or volunteer. We retain all discontinued client records for a minimum of 10 years, or longer if required by provincial regulation. We retain children’s records until the child reaches the age of majority plus 10 years. These records, whether at our offices or at our off-site facility, are stored in a manner that ensures ongoing security. At the end of the 10-year period, all information that we have, regardless of format, is destroyed in a confidential manner, unless we are required by law to retain it.  

MINORS 

We do not intentionally target or collect information from anyone under the age of 13 (thirteen). We do, however, in the course of providing our Services to parents/ guardians and their children, collect the minor’s information with the parent/guardian consent.  

YOUR CHOICES REGARDING YOUR INFORMATION: 

Providing and withdrawing consent 

In directly communicating with us, attending our events, or applying to work or volunteer with us, we assume you provide us with consent to collect, use and disclose your Personal Information in accordance with this Privacy Notice (“implied consent”). At times we may require your express consent (such as when we collect your Personal Health Information to provide you with our Services, when you sign up to receive news and advertising; and in some instances when you attend events). We assume we have your consent to continue to collect, use or disclose your personal information unless you tell us otherwise. 

For those individuals who are unable to provide express consent where required, e.g., minors, those who are seriously ill or people developmental disabilities or experiencing mental health challenges, consent will be obtained by an authorized authority, e.g., legal guardian, substitute decision maker, power of attorney or the executor of your estate. 

In the instances where we rely on your consent (implied or express), you have the option to withdraw your consent at any time, subject to legal or contractual restrictions. For example, you may withdraw your consent to disclose certain information to a family member. You may also unsubscribe to our newsletter or other correspondence we send you by clicking the “unsubscribe” link or contacting us.  

If you withhold or withdraw your consent, we will explain the consequences of doing so and how it may affect you. Withdrawing your consent will not affect the lawfulness of any processing conducted before your withdrawal. However, even if you opt out of receiving any communications from Reena, we reserve the right to contact you regarding financial commitments already made and any other matter that might affect our Service to you and/or our records on you. 

Updating your Information.  

 To provide you with the best possible care and Services, we must have the most up-to-date and accurate information about you. If any of your information changes or if you are aware that the information we have about you is inaccurate, please let us know so we can make the necessary changes.  

Accessing your Personal and Personal Health Information.  

Upon written request, we will acknowledge and confirm the existence, use, and disclosure of your information. You have the right to access and/or correct your information. To assist us with an accurate and prompt response, please provide us with adequate details in your request so that we can provide you with the requested information.  

If you need access to your information which you cannot readily access on your own, please don’t hesitate to contact us. We will provide you with access to your information within a reasonable time and at a minimal or no cost in accordance with applicable law. 

In certain circumstances, we may not be able to provide you with access to your information such as if doing so would be extremely impractical, reveal personal information about another individual or a third party, or the information is protected by solicitor-client privilege or court order. In these instances we will let you know.  

To make a request for access or correction of your information, please write to us at privacy@Reena.org. 

If you are unsatisfied with our response to your access and/or correction request, you may bring it to the attention of the Information and Privacy Commissioner of Ontario (IPC).  

Information and Privacy Commissioner of Ontario 

2 Bloor Street East, Suite 1400 Toronto, ON M4W 1A8 

Contact: (Toronto Area): 416-326-3333 

Email: info@ipc.on.ca 

DO YOU HAVE QUESTIONS? 

We want to answer your questions, so you feel comfortable with the personal information you entrust us with.  

Questions, concerns or complaints relating to Reena’s Privacy Notice or on the treatment of your information should be e-mailed to: privacy@Reena.org.