Privacy policy

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Our commitment to privacy and confidentiality

Kids Help Phone is committed to protecting the confidentiality and privacy of the personal information and/or personal health information of its donors, employees, service delivery partners, service users (texting and counselling), service users of our website and Resources Around Me, peer-to-peer service users, trends data website users, volunteers (including Crisis Responders), and board members, collectively referred to as stakeholders. As part of that commitment, we have implemented this Privacy Policy. This policy applies to full/part time permanent or contracted employees, volunteers, contractors, consultants, temporary employees from agencies, and all personnel affiliated with third party service providers; hereandafter referred to as associates.

Personal information and personal health information are highly sensitive, and are collected under implied consent.

Scope

This policy sets out Kids Help Phone’s commitment to privacy. It governs all of its services and interactions with stakeholders: in-person, digital, online, or off-line. Kids Help Phone offers professional counselling, an interactive, personalised web experience, information, referrals, and volunteer-led, text-based support to young people in English and French, and we also facilitate voice translation by third parties. Services are provided for youth of any age living in Canada. Our volunteer-led, text-based service is also available to adults living in Canada, and we comply with all applicable Canadian laws. Kids Help Phone does not offer services outside of Canada.

Kids Help Phone does not require users to identify themselves; however, information collected may include identifying information. Kids Help Phone will deal with all information as private, privileged, and confidential. Kids Help Phone has an Information Security policy, stipulating various protection mechanisms, which governs all information under its custody and control.  Kids Help Phone hosts its own services directly, via third party service providers, or on the cloud. Information may also be stored on mobile devices managed by Kids Help Phone, or on devices owned by associates.  All associates agree to this Privacy Policy, to an internal Terms of Use, and to Kids Help Phone security policies. This Privacy Policy includes application-specific privacy notices, and Terms of Use.

Kids Help Phone Privacy Policy

Accountability

Kids Help Phone is responsible for the personal information and personal health information under its control. We have appointed a Privacy Officer and created a Privacy, Security, and Risk Program to ensure compliance with Canadian fair information principles.

Purposes

Kids Help Phone collects personal information and personal health information to provide users with the above-mentioned services. In addition, Kids Help Phone will use the information for data quality and service delivery improvement, and to share with research partners (row level data). We will disclose aggregate level data for funding reports, thought leadership publications (including, but not limited to, our website), media publicity, conference presentations, and participating in approved research.

Information regarding donors, donors (in-kind and monetary), prospective donors, school staff, and partners (including those that assist in fundraising) is collected for: communications; requesting and managing donations; sending reminders, thank-you letters, and tax receipts; fundraising and gala events management; compliance; and for validating identity. We report back to fundraiser-organizing partners the staff participation count and amounts collected.

Other purposes of information collection and management include creating promotional material, writing of impact reports, formulating user experience stories, delivering motivational speaking presentations, and collecting feedback about these events.

Associates’ data will be used for the purposes of managing our employment relationship with them.

Limiting data collection

Kids Help Phone will limit the collection of personal information and personal health information to the intended purposes covered by this policy.

Kids Help Phone will not ask users for their name (we may ask for location if needed), to provide them with texting or counselling services; however, in the course of interaction, users may choose to provide information that is highly identifiable, such as their age, sex, gender, sexual orientation, or location. Kids Help Phone will treat all user information as personal health information.

Kids Help Phone will collect demographic data including ethnicity to measure our service commitment to diversity and inclusion.

Kids Help Phone works with partners to collect donations. Some partners collect donations on our behalf and provide donor information, amounts, addresses, and names.

Kids Help Phone will limit collection of associate information according to associate role and function.

Information collected by Kids Help Phone may be either personal information or personal health information, which are together referred to in this policy as “information.”

Kids Help Phone may from time to time rent donor lists from not-for-profit organizations. People who do not wish to receive communications can contact Kids Help Phone to be removed from the list.

Limiting data retention, use, and disclosure

Kids Help Phone is committed to the proper classification, secure retention, and timely and secure disposal of any record containing any information.

User information will not be disclosed except in accordance with Kids Help Phone’s legal obligations to report to child services and policing agencies. In addition, Kids Help Phone will only release aggregate reports and data about its services to agencies such as Canada Health Infoway or to major funders. Any disclosure of aggregate data must be deidentified to include at least 100 people in the data set, thus greatly reducing the potential of re-identification. Even though Kids Help Phone shares data in certain listed circumstances, we will not share data that is stigmatizing or puts a group or individual in a negative light based on our Non-discrimination Policy. For research and publications, we will seek formal research ethics approval as per the Canadian Tri-Council Policy Statement of Ethical Conduct for Research Involving Humans.

We do share row level data with research partners. We will disclose aggregate level data (deidentified to include at least 100 people in the data set) for funding reports, thought leadership publications, media publicity, conference presentations, and participating in approved research.

Donor information will only be disclosed for the purposes of validating identity and collecting donations. However, we may report back to donating partners the number of staff participating in events, and how much was raised at a fundraising event. We will not disclose information pertaining to donors who request anonymity.

We will limit the use of associate information to identity validation, managing payroll, capturing demographic information, next of kin, and emergency contacts.

Ensuring accuracy

Kids Help Phone will ensure that appropriate reviews are executed for donor and system data integrity, will report any data integrity issues to the data quality team (which includes staff from business and information technology), and will correct all data integrity issues in a timely manner. Kids Help Phone will attempt to validate donor payment details and address information to ensure continuity of billing, and to provide tax receipts. Staff transcribe phone conversations if needed for reporting purposes.

For Short Messaging and Chat Services, we will store “text” exchanges to ensure service quality and for training purposes. Kids Help Phone relies on individuals providing accurate data; we will not ascertain its accuracy.

Safeguards

We follow industry standards to safeguard data against loss or theft, as well as unauthorized use, access, disclosure, copying, modification, retention, or disposal. We use a variety of physical, electronic, and procedural safeguards to protect all captured information.

Most texting user information is stored in Canada and the US. Some companies providing services to Kids Help Phone are located outside of Canada (including the USA) and so information may be stored in those jurisdictions. Under the laws of some countries (including the USA) information may be made available to the government, or its agencies, under a court order made in that country. For further information, please contact us at privacy@kidshelpphone.ca. Donor information is stored in Canada.

Openness

Kids Help Phone publishes this policy to include a plain-language description of the services that is appropriate for sharing with individuals whose information is collected, including a general description of the safeguards in place to protect against loss, theft, unauthorized use, access, disclosure, copying, modification, or unauthorized or unsecured disposal, and to protect data integrity.

Upon request, Kids Help Phone may provide to the public any directives, guidelines, and policies that apply to its services.

Individual access

Since Kids Help Phone does not ask users for identifying information, providing access to such information is not feasible.

For donors, Kids Help Phone has a documented procedure, with clear accountabilities, to comply with applicable legislation allowing an individual to access their information. Systems and documented processes are in place, with controls and audit trails, to respond to individual requests for data access.

Governance

In order to meet its obligations under privacy legislation, and to clients and funders, Kids Help Phone has:

  • Created a Privacy, Security, and Risk Program and assigned a Privacy Officer to ensure compliance with obligations related to privacy and security.
  • Used or developed practices and procedures to:
    • Develop key performance indicators to assess and report on privacy or security metrics.
    • Review Kids Help Phone privacy and security policies, practices, and procedures annually to ensure that they comply with applicable legal, industry, and regulatory standards and requirements and to determine whether changes are necessary or appropriate based on changes in laws or significant legal or other developments.

The Privacy, Security, and Risk Program team will form an Incident Response Team to manage incident response. The team will always include the Privacy Officer or delegate, the program/project/executive involved with the breach, and the Director of IT, as well as any other participants decided on by the Privacy Officer.

Human resources

Kids Help Phone uses and develops practices and procedures to ensure that associates who perform services or otherwise have access to confidential information will:

  • Sign a Confidentiality Agreement.
  • Be informed of all privacy- and security-related policies and procedures (these are readily accessible to all personnel).

Training and awareness

Kids Help Phone believes that a culture of privacy and security is necessary to meet the individual and collective responsibilities of the organization, and delivers comprehensive privacy training and ongoing privacy awareness initiatives to all associates as required.

Auditing policy and procedures

Kids Help Phone is establishing an overarching audit policy. Until such a policy is developed, we will audit access on an as-needed basis.

Breach response protocol

Kids Help Phone affirms its ability to promptly and appropriately respond to, contain, and mitigate the impact of a privacy or security breach or incident. Accordingly, Kids Help Phone has a documented breach response protocol to identify, manage, and resolve privacy and security breaches. Systems and documented processes are in place, with controls and audit trails, to respond to privacy and security breaches which occur as the result of loss, theft, unauthorized use, access, disclosure, copying, modification, or unauthorized or unsecured disposal of collected information.

The following Prevention Strategies should be followed to minimize the possibility of a breach, and to ensure preparedness in the event that a breach does occur.

Prevention Strategies

Security

  • Make sure that all physical, logical, and IT controls are appropriate for the type of information collected and stored.
  • All patches and updates must be installed system-wide on release. Many breaches occur because a security patch was not installed in a timely manner.
  • Wherever possible, personal information and personal heath information are to be encrypted.

Auditing

  • All new programs that will collect or manage personal information should be evaluated; Privacy Impact Assessments and Threat and Risk Assessments should be conducted before any new processes are implemented.

Training

  • Training and awareness programs will include specific guidance on detection of potential security hazards, allowing them to be fixed before an issue escalates.

Third-party vendors

  • Review all contracts as well as the security measures used by data processors to ensure that they have all appropriate physical, logical, and IT controls.

Complaint management

Kids Help Phone responds to privacy and policy complaints within twenty eight calendar days of initial receipt. The public is asked to send their privacy-related complaints to privacy@kidshelpphone.ca or via letter addressed to: Privacy Officer, Kids Help Phone, National Office, 300‐439 University Avenue, Toronto, ON M5G 1Y8.

Donors can send complaints or requests for changes via email, telephone, regular mail addressed to: Privacy Officer, Kids Help Phone, National Office, 300‐439 University Avenue, Toronto, ON M5G 1Y8, or through the online form at Contact us.

Service-related complaints are addressed in our complaints policy, available at Kids Help Phone’s complaints policy.

Operating procedures

Kids Help Phone has practices and procedures in place to ensure that it meets all provincial and federal privacy regulations. The Privacy, Security, and Risk Program at Kids Help Phone administers and manages privacy, security, and risk processes.

Web-tracking disclosure statement

Using Google Analytics

We use Google Analytics to collect information about the use of our website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

Google Analytics employs cookies to define user sessions, which allows for the collection of data about how visitors are using the websites. Google Analytics uses only first-party cookies for data analysis. This means that the cookies are linked to a specific website domain, and Google Analytics will only use that cookie data for statistical analysis related to your browsing behaviour on that specific website. According to Google, the data collected cannot be altered or retrieved by services from other domains.

If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit Google Analytics.

Google Analytics cookie usage on websites:

https://developers.google.com/cookie-usage

Your web consent

By communicating with us through our website, you are providing us, our agents or partners, or other third parties (e.g., Google Analytics) with your information, and are thus consenting to the collection, use, and disclosure of your information in accordance with this Privacy Policy. The terms of use of the website are posted at Terms of service.

If you have questions about your personal data

If you want to view your personal information or personal health information, or have any concerns about the way in which your personal data is used or disclosed, please contact the Kids Help Phone Privacy Officer at:

Privacy Officer, Kids Help Phone, National Office, 300‐439 University Avenue, Toronto, ON M5G 1Y8

Toll Free Number: 1-800-268-3062

Email: privacy@kidshelpphone.ca

We will make every effort to address your concerns. Concerns and complaints may also be addressed to the Information and Privacy Commissioner of Ontario.