PRIVACY POLICY
Last Modified: August 9, 2017
1. Background
The Public Services Health & Safety Association (the “PSHSA”) is an independent not-for-profit organization and is funded by the Ontario Ministry of Labour. PSHSA works with Ontario’s Public and Broader Public Sector employers and workers, providing training, consulting and resources to reduce workplace risks and prevent occupational injuries and illnesses.
PSHSA owns and operates the Workplace Violence Risk Assessment tool available at https://wvra.pshsa.ca/ the Client Risk Assessment tool available at https://icra.pshsa.ca and Community Care tools available at https://wpvcc.pshsa.ca/#/ (unless otherwise specified, all such electronic information platforms will be referred to collectively as the “Website”). PSHSA supports the prevention and reduction of workplace injuries and occupational diseases in Ontario’s health care sector by assisting organizations to adopt preventive best practices and approaches. The Website is developed for employers and employees in the healthcare and emergency sectors to identify risk factors and levels associated with workplace violence. By conducting the assessment through the Website, such health care providers can apply control interventions that promote both employee and client safety, as well as ensure client-centred care.
This privacy policy (the “Policy”) describes the purposes for which PSHSA collects, uses and discloses “personal information” you elect to provide to PSHSA electronically, through the Website. In the Policy, “Personal information” means information that identifies an individual, including you, but does not include the name, title or business address or telephone number of an employee of an organization.
2. Collection of Personal Information
PSHSA only collects personal information that you voluntarily supply in connection with your use of the Website. Users of the Website may register (“Registered Users”) to have access to the PSHSA assessment tools Registration may be cancelled at any time through PSHSA’s help desk or by contacting our privacy officer as indicated in the “Contact Us” section below.
To become a Registered User, a user may need to provide certain Personal Information (name and e-mail address) to create a “User Profile PSHSA does not collect personal health information from the Registered Users. To the extent that a Registered User uploads or posts information about another individual, the Registered User is representing to PSHSA, and PSHSA will rely on the representation, that he or she has consent or other authority to disclose the other individual’s information to PSHSA.
If you choose to subscribe to our newsletters or electronic updates, you will need to provide your email address (and other information, including your language preference) and by subscribing, we will understand you to consent to our use of your address for the purposes of your subscription. You may unsubscribe from receiving newsletters and electronic updates by using the unsubscribe mechanism provided on the Website or by contacting our privacy officer (see “Contact Us” below).
3. Use of Personal Information
PSHSA will not use or disclose Personal Information other than for the purposes for which it was collected, except with consent, as required by law or indicated in this Policy. PSHSA does not trade, rent or sell any Personal Information to third parties. We use Personal Information for purposes that include:
- in connection with subscriptions, create and administer subscriber accounts and send subscribers newsletters and electronic updates;
- in connection with the Website, enable and administer user registration;
- process requests for access or change to Personal Information;
- respond to inquiries and other correspondence;
- provide technical support through our Customer Service team; and
- Customize and enhance the Website content.
4. Disclosure of Personal Information
PSHSA may disclose your Personal Information and other information as follows:
- as permitted or required by law, including for proceedings or contemplated proceedings;
- where required to protect our staff, directors and officers, other users of the Website or our services, individuals or groups of individuals, or PSHSA’s operations more generally (collectively referred to as the “Community”);
- to a potential or actual successor of PSHSA in the event that PSHSA is considering a reorganization, actually reorganizes its operations, or ceases to operate; and
- where we believe, acting reasonably, that disclosing the information is required to protect the Community, including in circumstances where the disclosure is required to protect the life, health or security of any person.
Registered Users create their own User Profile. The [first name, last name, and email address] in User Profiles will be displayed to all Registered Users participating in the same collaborative community. By using the Website, Registered Users are agreeing to the disclosure of their Personal Information to other Registered Users within their collaborative communities (only those invited by their organizations account administrators).
PSHSA also aggregates the Personal Information of Registered Uses and uses the aggregated information (which does not identify any specific Registered User) for the purpose of planning for the Website.
5. Third Party Suppliers
We give access to Personal Information to employees and external service providers (“Suppliers”) for the purposes described above. Our Suppliers include companies that provide us with information technology services, our insurer and our professional advisors. We contractually bind our Suppliers to complying with privacy practices and security standards we establish. We limit access to Personal Information to employees who require the information for the purposes set out in the Policy.
Some of the Suppliers operate outside of Canada. When Personal Information is transferred to such Suppliers, it becomes subject to the laws of the country in which the Suppliers operate.
6. Security
PSHSA uses reasonable technical, contractual, administrative and physical measures in an effort to protect Personal Information from theft, loss, unauthorized collection, use (including alteration), and disclosure. For example, we limit the use of Personal Information to those members of our personnel who require it to perform their job. We store Personal Information on an encrypted secured server. The Workplace Place Violence Assessment tools ensure the use of digital certificates (TLS1.2, 1.1) for securing all of the information between the user and the server. The databases for these tools are encrypted and hosted via the Relational Database Service (RDS) on Amazon Web Services (AWS) in Montreal, QC, Canada (ca-central-1). PSHSA does not have direct access to view your data.
7. Links to Third-Party Websites
The Website may contain links to other websites that operate independently of PSHSA and are not under our control. We provide links to other websites solely for your convenience and information. Other websites are governed by privacy policies and practices that may differ significantly from those of PSHSA. We strongly recommend that you review the privacy policies and practices applicable to personal information collected through a linked website, before submitting any personal information. PSHSA is not responsible for the privacy practices of the organizations operating linked websites or for the use, disclosure and management of personal information collected through those websites.
8. Retention of Personal Information
PSHSA retains Personal information collected during user registration and when providing technical support to users as well as information posted or uploaded to the Website to ensure the integrity of our business records and service delivery. For clarity, Personal Information is not automatically deleted when a user account is deleted.
9. Use of Cookies, Google Analytics
When you visit the Website, we collect certain information from your browser using “cookies”. Cookies are small files that are stored on your computer. We may use cookies to save user settings and otherwise streamline the user experience, as described below. Your browser software allows you to disable and delete cookies. Disabling or deleting cookies may restrict your use of the Website. We do not link the information we collect through cookies to any other information, including Personal Information.
PSHSA uses “Google Analytics”, a service that provides us with information about the Website and use of the Website that we use to improve the functionality of the Website. Google Analytics may set or read cookies on the browsers of Website users and otherwise receives information from users’ browsers. For information about how Google uses information it collects through our use of Google Analytics, please refer to “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/. You may also want to review Google’s privacy policy, which is available on that webpage. There is also information on that webpage about what you can do if you do not want Google Analytics to be used in your browser.
10. Changes to the Policy
PSHSA may change the Policy from time to time without notice to reflect changes in its operations or the law. The date of the latest update will appear at the top of the Policy. Your continued use of the Website after the effective date of any change to the Policy constitutes your acceptance of all such changes.
11. Contact Us
Any comments, questions, concerns or complaints regarding our management of Personal Information, this Policy and our privacy practices, or regarding to your access and the correction of your Personal Information, should be forwarded to our Privacy Officer in writing as follows: privacyofficer@pshsa.ca