Our Privacy Policy

Pathways To Independence, and Pathways Foundation, recognize the importance of privacy and the sensitivity of personal information. We are committed to protecting any personal information that we hold. Obligations relating to the protection of the privacy of personal information also apply to all employees, contractors, and agents who provide service to Pathways. Applicable laws and Pathways policies govern the protection of Pathways' employees' personal information.

Pathways is responsible for the personal information it collects and holds. We have developed this Privacy Code to explain the measures that Pathways has implemented to protect the personal information you provide to us. We have also developed internal privacy policies and educated our staff about our privacy policies and procedures.

Why does Pathways need personal information?

Pathways requires personal information to:

• Provide ongoing and future services
• Establish and maintain communication with employees, contractors,   and agents
• Administer the benefit and pension plan
• Meet legal, regulatory, and professional requirements

What is personal information?

Personal information is any information, recorded in any form, about an identifiable individual, or information from which an individual's identity may be inferred or determined. This Privacy Code does not apply to information that is publicly available, anonymous, or aggregated (information about more than one individual where the identity of the individuals is not known and cannot be inferred from the information).

Collection, use, disclosure, and retention of personal information

We collect, use. or disclose your personal information with your permission. Normally, we will ask for your consent in writing but, in some circumstances, we may accept your verbal consent, electronic consent, or consent through your authorized representative. Pathways does not barter, trade, sell, or exchange for any consideration any personal information it has obtained.

Pathways may be required or permitted to disclose your personal information in certain circumstances, for example, when:

• Required or authorized by law (e.g. legislation, subpoena, or court   order);
• You consent;
• Third party service providers require the information to provide   administrative services such as technology, financial, legal, and   insurance coverage to Pathways and the third party is bound by our   Privacy Code;
• The information is publicly known

In any of these circumstances, except when you consent, Pathways will only disclose the minimum information required.

Pathways retains your personal information only for the time it is required for the purposes described. When personal information is no longer required, we have procedures in place to destroy, delete, erase, or convert the information into an anonymous form.

Updating personal information

To provide you with professional liability services, it is important that your information is accurate and up-to-date. If your information changes, please inform Pathways so we may make any necessary changes to our records.

Security

Pathways takes precautions to protect your personal information from loss, unauthorized access, modification, disposal, or disclosure. Steps that we have taken include: premises and internal office security; restricted access to personal information; use of technological safeguards such as security software and firewalls, internal passwords, and security policies.

Access and amendment

You may ask for access to any personal information we have about you, information about how your personal information has been and is being used, and the name of individuals or organizations to whom your personal information has been disclosed by Pathways (except where disclosure was to a Pathways service provider for routine administrative purposes.) We will respond to your requests as accurately and completely as possible. If Pathways has information about you that is not accurate, complete, or up-to-date, we will take steps to correct it.

The right to access your personal information is not absolute. Reasons for denying access include: prohibitive costs; information that includes references to other individuals; security or proprietary reasons; information collected during the investigation of a legal matter; or information that cannot be disclosed for other legal reasons.

Changes to Privacy Code and Policies

Pathways regularly reviews all of it's policies and procedures; we may change our Privacy Code and policies from time to time. When amendments to the Privacy Code are made, a revised policy will be shared with all employees and a notice posted on our website.

Request for access or questions

If you have any questions concerning our handling of your personal information, or you wish to request access to, or correction of, your personal information held by Pathways, please contact:

Barbara Frederick
Privacy Officer
Pathways To Independence
25 Dundas St. W., Unit 5
Belleville, Ontario K8P 3M7
(613) 962-5085 ext. 224
This e-mail address is being protected from spambots. You need JavaScript enabled to view it