Privacy Policy
Childhood Connections respects the privacy of the children, youth, families, caregivers, staff, volunteers, donors, members and community partners who engage with us. This policy explains how we collect, use, disclose, protect and retain personal information, and how people can ask questions or request access or correction. We handle personal information in accordance with British Columbia’s Personal Information Protection Act (PIPA) and other applicable legal obligations.
1 Scope and responsibility
This policy applies to personal information in our custody or control across our programs, childcare and childminding services, counselling and youth supports, events, fundraising, employment and volunteer activities, membership services, and website communications. Personal information means information about an identifiable individual; it does not include ordinary business contact information used to contact someone in their professional role.
Childhood Connections is responsible for the information it controls, including information processed for us by service providers. We designate a Privacy Officer to oversee this policy, respond to requests and complaints, and coordinate privacy training and incident response. Staff, volunteers and contractors may access information only as needed for authorized duties.
2 Information we collect
Depending on the service or relationship, we may collect names and contact details; a child’s age, attendance, registration and authorized pickup information; emergency contacts; information needed for safe participation, such as allergies, accessibility needs or relevant health information; referrals, assessments, service plans and case notes; consent and communication preferences; payment, donation and tax receipt details; and information relevant to staff or volunteer recruitment and screening. We may also receive information a person provides through a website form, email, telephone call or event registration.
We ask only for information reasonably needed for an identified purpose. We explain the purpose at or before collection and, where appropriate, indicate which information is optional. A separate form or program notice may give more specific information about a service.
3 How we use information and obtain consent
We use information to assess eligibility and needs, provide and coordinate services, protect participant safety, contact families and emergency contacts, administer programs and memberships, manage staff and volunteers, process payments and donations, issue receipts, meet funder and legal requirements, evaluate services using appropriately limited data, and respond to inquiries.
We seek meaningful consent when required by PIPA. The form of consent depends on the sensitivity of the information and the circumstances. For children and youth, we consider the young person’s ability to understand the decision, the role and legal authority of a parent or guardian, the nature of the service, and applicable confidentiality and safety obligations. We explain information practices in language suited to the person involved. Consent for photographs, public stories, testimonials and promotional use is requested separately and may be declined without affecting access to core services.
A person may withdraw consent on reasonable notice, subject to legal and service obligations. We will explain any likely effect on service delivery. We do not use information for a new, unrelated purpose without a lawful basis and any additional consent required.
4 When we share information
We disclose personal information only as reasonably needed for the identified purpose, with consent, or as permitted or required by law. This can include authorized service providers that host records or process payments, a referral or care partner where an appropriate consent or legal basis exists, and funders or regulators where reporting is required. We limit disclosures to the information needed. Reports to funders ordinarily use aggregate or de-identified information unless identifiable reporting is authorized or required.
We may disclose information without consent where the law permits or requires it, including reporting a child protection concern, responding to a lawful order, or addressing an urgent risk to health or safety. We do not promise absolute confidentiality. Youth and family information is shared with parents or guardians only after considering legal authority, the young person’s interests, confidentiality commitments, third-party information and applicable law.
SMS consent is not shared with third parties. Some service providers may process or store information outside British Columbia or Canada. When we use them, we remain responsible for information under our control and use appropriate contractual and security protections. Information in another jurisdiction may be subject to lawful access there.
5 Safeguards and privacy incidents
We use safeguards appropriate to the sensitivity of the information, including restricted access, secure storage, staff and volunteer confidentiality expectations, and secure disposal. Sensitive program and counselling information receives additional care. We review our practices and address access or security concerns as they arise.
Anyone working with Childhood Connections must promptly report a suspected loss, unauthorized access or disclosure to the Privacy Officer. We will contain and assess the incident, take corrective steps, and notify affected people, regulators or other parties when required by law or appropriate in the circumstances.
6 Accuracy, retention and disposal
We make reasonable efforts to keep information accurate and complete when it is used to make a decision about a person or disclosed to another organization. Please tell us when your information changes.
We retain personal information only as long as needed for the purposes for which it was collected and for applicable legal or business requirements. Where information is used to make a decision that directly affects an individual, PIPA generally requires us to retain it for at least one year after that use. Program-specific retention schedules may require longer periods. When retention is no longer justified, we securely destroy or de-identify the information.
7 Access, correction and complaints
You may ask to access personal information we hold about you and learn how it has been used or disclosed, subject to legal exceptions. You may also ask us to correct inaccurate information. We may need to verify identity or legal authority before responding, particularly for records about a child or youth. We respond within the time required by PIPA, ordinarily within 30 days, unless a lawful extension applies. If we cannot grant a request in full, we will explain the reason and available review options. Any permitted fee will be explained in advance.
Questions, access or correction requests, and privacy complaints can be directed to the Privacy Officer, Childhood Connections Okanagan Family and Childcare Society, #101 – 1505 Harvey Avenue, Kelowna, BC V1Y 6G1; phone 250-762-3536. Please do not include sensitive case details in an initial web contact form. We will investigate complaints and communicate our response. If you remain dissatisfied, you may contact the Office of the Information and Privacy Commissioner for British Columbia.
8 Updates
We review this policy periodically and update it when our practices or legal requirements change. The current version will be available on request and, if posted, through our website. Material changes will be communicated as appropriate.