Access2ID Privacy Policy

Effective as of May 4, 2022
Last updated: May 4, 2022 

 

1. GENERAL

Northern Village Inc. (“Northern Village”, “we”, “us” and “our”) is committed to protecting the privacy and confidentiality of any personal information which you, as a social service worker or an authorized representative of a social service organization (“you” or “User”), may receive from your Client and provide to us through our web-based software application Access2ID, made available on our Access2ID website (the “Website”, available at https://access2id.ca/).

The Website and the associated Access2ID services (collectively, the “Services”) we provide are made available to registered Users to help recover, store and keep track of Clients’ identification. “Client” refers to an unhoused individual obtaining assistance from a social service organization, including but not limited to applying for and storing of government-issued identification documents (“IDs”), such as health card, passport and driver’s license.

Our Privacy Policy (the “Policy”) governs how personal information entrusted to us is collected, used, disclosed, or retained; and reflects the principles set forth in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). Accordingly, personal information is defined as any information about an identifiable individual.

Information including business contact information and certain publicly available information such as names, addresses and telephone numbers as published in telephone directories are not considered personal information. If you use your home contact information as business contact information, we consider that the contact information provided is business contact information that is not subject to protection as personal information.

In order to use our Services, you must agree to this Policy and our Terms of Service.

We are committed to regularly reviewing our privacy practices and reserve the right to update this Policy from time to time. The most current version of this Policy will govern our privacy practices.  It is your responsibility to check this Policy from time to time to ensure that you are up to date with any changes. By continuing to use the Services after changes are made to this Policy, you agree to be bound by the revised terms.

We also reserve the right to contact any User of the Services at any time to forward information, respond to questions, or provide notification of any changes to the Services or our policies. 

 

2. CONSENT

YOU MUST BE 18 YEARS OF AGE TO REGISTER OR USE THE SERVICES.

BY USING THE SERVICES, YOU CONFIRM THAT:

  • YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF ANY PERSONAL INFORMATION YOU PROVIDE TO US IN ACCORDANCE WITH THIS PRIVACY POLICY; AND
  • YOU ATTEST THAT:
    1. YOUR CLIENT IS AT LEAST 16 YEARS OLD;
    2. YOUR CLIENT, BEING OF SOUND MIND AND COMPETENT TO PROVIDE CONSENT, HAS PROVIDED YOU WITH THE NECESSARY AND REQUIRED INFORMED CONSENT , PURSUANT TO PIPEDA AND ANY OTHER APPLICABLE CANADIAN LEGISLATION, FOR THE COLLECTION, STORAGE, USE AND DISCLOSURE OF YOUR CLIENT’S PERSONAL INFORMATION BY US IN ACCORDANCE WITH THIS PRIVACY POLICY; AND
    3. YOU HAVE PROPER DOCUMENTATION AND PROOF OF SUCH CONSENT PROVIDED BY YOUR CLIENT.

IF YOU DO NOT AGREE WITH THIS POLICY, YOUR CLIENT IS UNDER 16 YEARS OF AGE AND/OR YOU DID NOT OBTAIN THEIR INFORMED CONSENT, YOU MUST NOT ACCESS OR USE THE SERVICES WITH RESPECT TO SUCH CLIENT.

YOU AND/OR YOUR CLIENT MAY WITHDRAW CONSENT OR OPT-OUT AT ANY TIME BY CONTACTING US DIRECTLY USING THE INFORMATION PROVIDED BELOW IN SECTION 11.

  

3. OVERVIEW OF OUR PRIVACY PRACTICES

The purpose of this Policy is to inform you of our privacy practices, including:

  • what personal information we collect;
  • how we use the collected personal information;
  • who we share the personal information with;
  • the choices you have to access, update, and remove personal information from our Services; and
  • who you can contact should you have questions or concerns about our privacy practices.

 

Overview of Our Privacy Practices

Our privacy practices are summarized here. Under this Policy, we:

(1)   collect the personal information about your Client that you provide through our Website, for the purposes outlined in Section 4 of this Policy;

(2)   collect non-identifiable information regarding Users and activity on the Website;

(3)   share the information we collect with authorized employees, volunteers, agents, partners, service providers and legal representatives, and may also share this information with third parties engaged to provide products and services on our behalf.  Such persons may only use the personal information you provide to us in accordance with this Policy;

(4)   may use, share and disclose the information collected by us, in accordance with this Policy;

(5)   except as set out in Section 4 of this Policy, we do not share the personal information you provide to us with third parties without having the requisite consent;

(6)   retain personal information in compliance with our legal obligations and only as long as necessary for the purposes of which it was collected; and

(7)   may share personal information you provide to us with our partners or service providers located within Canada in accordance with this Policy.

We mitigate the risk and impact of potential harms involved in the disclosure of personal information through the adoption of reasonable physical, technical and organizational procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide to us. 

Even with physical, technical and organizational measures adopted by us, there is a residual risk of the loss of, unauthorized access to or unauthorized disclosure of information that you provide to us, which could result in financial or other harm to you and your Client. In addition, there is a risk that personal information you provide to us may be accessible to law enforcement and national security authorities within Canada. 

Your Client may withdraw consent to the collection, storage, use or disclosure of the personal information you provide to us at any time.

You may withdraw your consent to the collection, storage, use or disclosure of the personal information you provide to us at any time. It is your responsibility to promptly notify us of such withdrawals of consent.

Further information with respect to our privacy practices is set out below.

 

  

4. WHAT PERSONAL INFORMATION  WE COLLECT

We collect personal information about your Client to provide the Services to you in order to better assist you with your Client’ identification needs.

We may collect the following personal information about your Client:

  • Full name and former name;
  • Present and past home addresses;
  • Email address;
  • Phone number;
  • Date and place of birth;
  • Sex;
  • Photograph;
  • Eye colour and height;
  • Government-issued ID, such as health card*, driver’s license, citizenship card, passport and other valid photo card;
  • Canadian residency status and supporting documentation; 
  • Birth certificate;
  • Personal information about the Client’s family members or guarantors, including but not limited to, full names, place of birth and addresses; and
  • Other personal information required to provide identification services that your Client has requested from you.

* We may collect your Client’s health card number to assist for purposes related to the provision of health resources only. You understand and acknowledge that persons or organizations not directly involved in the delivery of health care are not permitted to record, collect or use a health card number for identification purposes.

We may also automatically collect certain information about the devices you use when you interact with the Services, including information about your web browser and IP address. As you use the Website, we may collect information about the individual web pages viewed, browser history and information about interactions with the Website including clicks, mouse position, scroll or keystroke logging.

 

5. HOW  WE COLLECT PERSONAL INFORMATION

We collect data related to Users, their Clients and other individuals that have contacted us regarding the Services through the following methods: 

  • Direct Interactions. You may provide us with personal information relating to your Client by filling in forms, uploading documents to the Website, and corresponding with us by mail, phone, email, or otherwise. This includes, but is not limited to, personal information relating to your Client that you provide when you use our Services or email us and request an email back.
  • Automated Technologies or Interactions. As you use the Website, we may automatically collect technical data by using the following technologies:
  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. Our Cookie Policy is described in Section 9 below.
  • “Log files” track actions occurring on the Website and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

 

6. OUR USE AND DISCLOSURE OF PERSONAL INFORMATION

We collect, use and disclose personal information in accordance with this Policy and only for purposes that a reasonable person would consider appropriate in light of the circumstances. We routinely offer to individuals we deal with the opportunity to opt not to have their information shared for purposes beyond those for which it was explicitly collected. We will not sell, exchange, loan or make available to other organizations any personal information that has been provided to us except as accounted for in this Policy or with appropriate consent.

We use personal information:

  • To provide you with the Services, in accordance with our Terms of Service;
  • To manage our customer relationship with you
  • For internal business purposes such as complying with our internal policies, administering the Website or improving our Services, including to compile aggregated non-personally identifiable information for research, marketing and analytics purposes;
  • For marketing purposes, which includes providing you with information regarding Northern Village and our initiatives;
  • As necessary to comply with legal requirements, to enforce our Terms of Serviceto prevent fraud, co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities; and
  • For any other purpose for which you have provided your consent (or you have obtained the requisite consent(s) from your Client).

We may use third party service providers in connection with providing our Services. Such third party service providers perform services on our behalf and/or provide support relating to hosting services and website operations. To the extent that any personal information is provided to these third parties, we require them to be bound by obligations consistent with this Policy and that such third parties only collect, use, or disclose personal information for the purposes set out in this Policy.

Other than as noted above, we will disclose personal information only if consent is given by you (or you have obtained the requisite consent(s) from your Client), or:

  • if personal information is in an aggregated or anonymized format that does not identify any specific person;
  • when permitted or required by law, such as in response to a subpoena or other legal process;
  • to a transferee of all or part of our business; or
  • to meet legal obligations, including but not limited to regulatory reporting obligations.

 

7.  ACCESS AND CORRECTION OF PERSONAL INFORMATION

Individuals that provide personal information to us may request details of their personal information which we hold by contacting us using the information provided in Section 11 below.

An individual can request from us information about:

  • the personal information we hold about them;
  • the categories of personal information concerned;
  • the purposes of the processing;
  • details to whom their personal information has been/will be disclosed;
  • how long we retain their personal information; and
  • how to lodge a complaint with the correct supervisory authority.

An individual may also request from us the following:

  • that we update any incomplete or inaccurate information about them; and
  • that we delete their personal information in accordance with applicable laws.

Under certain circumstances, it is possible that we may not be able to provide all of the requested information. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Fees may be applied to any copy of the requested personal information. We will provide the reasons for denying access upon request.

It is the individual’s responsibility to notify us of any changes to their personal information, including contact information, so we can contact them with respect to any use of the Services. If any information is incorrect, please contact us as soon as possible using the information provided in Section 11 and we will promptly correct any information found to be incorrect. Failure to inform us of such changes is a breach of our Terms of Service and may result in suspension or termination of the Services.

 

8. STORAGE AND RETENTION

We will store and retain your personal information in compliance with this Policy. Personal information is stored within Canada on servers belonging to our trusted third party cloud provider.

Our goal is to provide you with ongoing Services. We retain personal information only as long as necessary for the purposes for which it was collected. Personal information that is no longer required will be securely destroyed, erased or made anonymous according to our guidelines and procedures.   

If you require more details on data storage or retention periods, please contact us directly. Our contact information can be found in Section 11 of this Privacy Policy.

 

9. SECURITY SAFEGUARDS

We are committed to ensuring that the information we collect is secure and kept in confidence. Our personnel are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent it from being lost or destroyed.

In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the collected information. We use password protocols and encryption software to protect personal and other information we receive. When we work with an external provider, we will ensure they utilize similar safeguards.

 

10.  COOKIE POLICY

Our website and Services use cookies to collect and store certain information in accordance with this Policy. A ‘cookie’ is a small text file sent from a website and stored on the user’s computer by the user’s web browser. Upon visiting a site that uses cookies, a cookie is downloaded onto your computer or mobile device.  The next time you visit that site, your device will remember useful information such as preferences, visited pages, or logging in options.

Cookies are widely used to add functionality to websites, or to ensure they work more efficiently. Our website relies on cookies to optimize the user experience and ensure the Services function properly.

Most web browsers allow some control to restrict or block cookies through the browser settings; however, if you disable cookies you may find this affects your ability to use certain parts of our website or Services. For more information about cookies please visit https://www.aboutcookies.org/   

 

11.  CONTACT INFORMATION

If you and/or your Client have any questions or concerns about this Policy, then please contact us at privacy@access2id.ca.

To review or update the personal information in our possession or to withdraw consent for the collection, use, and/or disclosure of personal information, please contact us at the above email or  by mail at the following address:

Northern Village Inc.
PO Box 4, Guelph, Ontario N1H 6J6