Privacy Policy

1. Introduction and Scope

Shield Family Care Services ("SFCS," "we," "us," or "our") is committed to protecting the privacy and confidentiality of personal information and personal health information collected, used, and disclosed in the course of providing healthcare staffing and support services in Ontario, Canada.

This Privacy Policy explains how SFCS collects, uses, discloses, retains, and protects personal information in compliance with:

• The Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5;
• Ontario's Personal Health Information Protection Act, 2004 (PHIPA), S.O. 2004, c. 3, Sched. A; and
• Canada's Anti-Spam Legislation (CASL), S.C. 2010, c. 23.

This policy applies to all personal information collected through our website at www.shieldfamilycare.com, by telephone, by email, and in the course of delivering services. It does not apply to employee personal information collected and used solely for employment purposes, which is governed by a separate internal policy.

2. Definitions

Personal Information means any information about an identifiable individual, as defined in PIPEDA, including name, contact information, date of birth, and financial information.

Personal Health Information (PHI) means identifying information about an individual's physical or mental health, health care history, health care providers, or payments for health care, as defined in PHIPA.

Custodian refers to healthcare providers and health information custodians as defined under PHIPA, which may include SFCS where applicable to the provision of health services.

3. Information We Collect

We collect personal information only for purposes that a reasonable person would consider appropriate in the circumstances. The types of information we may collect include:

3.1 From Families and Individuals Seeking Services

• Full name, address, phone number, and email address
• Information about the person requiring support, including age, health conditions, disabilities, and care needs
• Financial information for billing and funding verification purposes
• Emergency contact information

3.2 From Healthcare Facilities

• Organization name, contact names, telephone and email information
• Staffing requirements and shift preferences
• Billing and accounts payable information

3.3 From Job Applicants

• Resume/CV, educational credentials, and professional certifications
• Contact details and work eligibility information
• References and employment history
• Results of criminal background and Vulnerable Sector Checks

3.4 From Website Use

• IP address, browser type and version, and referring URLs (collected automatically via server logs and analytics)
• Cookie data as described in our Cookie Notice
• Information submitted through website forms

4. Purposes of Collection

We collect personal information for the following purposes:

• To assess service eligibility and match clients with appropriate support workers
• To develop, implement, and monitor personalized care plans
• To fill staffing requests from healthcare facilities
• To recruit, screen, and onboard support workers and healthcare staff
• To communicate with clients, families, facilities, and staff regarding service delivery
• To process payments and manage accounts
• To comply with legal and regulatory obligations, including mandatory reporting requirements
• To improve the quality of our services and website
• With express consent, to send electronic communications including newsletters (in accordance with CASL)

We will not use personal information for a purpose other than those identified above without first obtaining consent, or as permitted or required by law.

5. Consent

SFCS obtains meaningful consent from individuals before or at the time of collecting personal information, except where collection without consent is permitted or required by law.

Consent may be express (e.g., signing a service agreement, checking a consent box on a form) or implied (e.g., providing contact information for the purpose of receiving a call-back). You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide services.

For personal health information, we rely on implied consent where collecting and using PHI is reasonably necessary for providing or assisting in the provision of health care to the individual, in accordance with PHIPA. Where broader use or disclosure is required, express consent is obtained.

6. Disclosure of Personal Information

We do not sell, rent, or trade personal information to third parties. We may disclose personal information in the following limited circumstances:

• Service delivery: To support workers, supervisors, and coordinators who need the information to provide agreed-upon services
• Third-party service providers: To vendors providing IT, cloud storage, payroll, or other operational services on our behalf, under written agreements that require equivalent privacy protections
• Legal compliance: Where required by applicable law, regulation, court order, or lawful authority (e.g., mandatory reporting of abuse or neglect under Ontario legislation)
• Emergency situations: Where disclosure is necessary to protect the health or safety of an individual
• With consent: For any other purpose with your express consent

7. Retention and Disposal

We retain personal information only as long as necessary to fulfill the purposes for which it was collected or as required by applicable law:

• Client service records: minimum 7 years from last date of service, or as required by applicable health records legislation
• Staff and applicant records: up to 24 months following termination of employment or rejection of application, unless a longer period is required by law
• Website inquiry and consultation request data: up to 2 years from date of submission

When personal information is no longer required, it is destroyed or de-identified in a secure manner.

8. Safeguards

SFCS employs administrative, technical, and physical safeguards appropriate to the sensitivity of the personal information held, including:

• Access controls limiting information to staff who need it to perform their duties
• Password protection, encryption, and secure transmission protocols for electronic information
• Locked storage for physical documents containing personal information
• Staff training on privacy obligations and confidentiality
• Confidentiality agreements with all staff and contractors

We cannot guarantee the security of information transmitted over the internet, but we take reasonable steps to protect all information under our control.

9. Your Rights

Subject to applicable law, you have the right to:

• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete information
• Withdraw consent to certain uses of your personal information
• Request that we cease use or disclosure of your information in certain circumstances
• Lodge a complaint with the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario

To exercise any of these rights, contact our Privacy Officer using the information in Section 12 below. We will respond within 30 days.

10. Electronic Communications and CASL

SFCS will only send commercial electronic messages (including newsletters, promotional materials, and marketing emails) to individuals who have given express or implied consent as required by CASL. Every commercial electronic message we send will include:

• Identification of SFCS as the sender
• Contact information for SFCS
• A clear and simple mechanism to unsubscribe

Unsubscribe requests will be processed within 10 business days.

11. Cookies and Web Analytics

Our website uses cookies and similar tracking technologies for functional and analytical purposes. For detailed information on the types of cookies we use, how to control them, and your opt-out options, please see our Cookie Notice.

We use aggregated, anonymized analytics data to understand how visitors use our website and to improve its functionality and content. This data does not identify individual visitors.

12. Privacy Officer and Contact Information

SFCS has designated a Privacy Officer who is responsible for overseeing compliance with this policy and applicable privacy legislation. To ask a question, make a request, or file a complaint regarding privacy, contact:

Privacy Officer
Shield Family Care Services
2030 Bristol Circle, Suite 210, Oakville, Ontario
Email: privacy@shieldfamilycare.com
Phone: (905) 484-0470 / +1 (866) 242-3577

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or the Information and Privacy Commissioner of Ontario at www.ipc.on.ca.

13. Changes to This Policy

SFCS may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. We will post the updated policy on this page with a revised effective date. For significant changes, we will provide additional notice as appropriate. We encourage you to review this policy periodically.