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January 1, 2004
We at the Armstrong Funeral Home know how important your privacy is to you. As funeral home operators we have a professional and legal obligation to keep confidential all personal information we receive from you. Our relationship with you is founded on trust and we are committed to maintaining that trust. For these reasons, we have created the following privacy policy. It confirms our dedication to protecting your privacy and maintaining the trust you have placed in us.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual with the exception of the information typically found on a business card such as their name, title or business address. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address, or telephone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).
WHO WE ARE
Our organization, Armstrong Funeral Home is in the business of providing funeral services to our client families (hereafter known as “clients”). We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include part-time funeral directors, hostesses and funeral assistants, clergy, soloists, hairdressers, coroners, cemetery personnel, florists, and so forth. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
WHY WE COLLECT PERSONAL INFORMATION:
Like all funeral homes, we collect, use and disclose personal information in order to serve our clients. The personal information, which we
collect, is needed to:
identify the purchasers and beneficiaries of prearranged/prepaid and at need arrangements;
provide our services including arrangement of third party service providers such as cemetery requirements, transportation, notices in newspapers, catering etc.
> comply with legislative and regulatory requirements (registering deaths under Vital Statistics Act of 1990, providing families with Proof of Death Certifications, etc.).
The following are examples of the types of personal information we collect for the above stated purposes: last, middle and first names, gender, social insurance number, date of death, city, province and date of birth, age at time of death, place of death with address, name and address of physician who pronounced death, marital or relationship status, last name of the deceased’s spouse or partner, primary work done most of living life, type of business or industry that the deceased worked in for most of his/her life, deceased’s usual residence, father’s place of birth, father’s name, mother’s place of birth, mother’s maiden name, the name, address and relationship to the deceased of the informant (person signing the statement of death). Based on health and Safety regulations we are privy to and do see medical information from the signed medical certificates, which are submitted, to the Ontario government along with the Statement of Death. This information is received without our client’s consent but is required by law to complete the registration of the death.
Like most organizations, we also collect, use and disclose information for purposes related to our primary purposes. The most common examples
of these are as follows:
1. INVOICING ANI) COLLECTION - to invoice clients for goods/services that are not paid for at the time and to collect unpaid accounts.
2. RECALL VISITS — to advise clients that their product or service should be reviewed (e.g., preneed clients may be informed of legislative changes affecting their prepaid services or advise them of new products or services offered).
3. NEW GOODS AND SERVICES, NEWSLETTERS AND INFORMATIONAL BULLETINS —to advise clients and others of new goods and services as well as bereavement newsletters and informative bulletins.
4. QUALITY CONTROL AND RISK MANAGEMENT — our organization reviews client files for the purpose of ensuring that we provide high quality services, including assessment of staff performance. In addition, external consultants (e.g., auditors, lawyers, practice consultants) may, on our behalf, do audits and continuing quality improvement reviews of our organization, including reviewing client files and interviewing our staff.
5. EXTERNAL REGULATIONS — our organization and its professional staff are regulated by the Board of Funeral Services that may inspect our records and interview our staff as part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients or other individuals to support the concem. Also, various government agencies have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers. and accountants) who will investigate the matter and report hack to us.
6, THIRD PARTY HILLING — the cost of some goods/services provided by our organization to clients is paid by third parties (e. g.. private insurance, government funding and/or estate lawyers). These third party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
7. RESPONDING TO QUESTIONS —clients or other individuals with whom we work with may have questions about our goods ser\ cc. after they have been received. We may also provide services to many of our past clients in the future for which previous records arc helpful. We retain our client information in a summarized, permanent form for reference purposes and to enable us to respond to any inquiries. Other than our permanent records, we destroy all information every ten years (as set by legislation for Funeral Services) at the first reasonable opportunity.
By signing our Privacy General Consent Form you may choose not to be part of some of these related or secondary purposes (e.g., by declining t receive newsletters and other information). Due to external regulations, some of these related or secondary purposes cannot be declined and do not require your consent.
Our primary purpose for collecting personal information from contract staff(e.g., part-time Funeral Directors, part-time drivers, parking attendants, hairdressers, soloists, etc.), is to contact them in the future for new assignments and for necessary work-related communications (e.g.. sending out cheques, other funeral correspondences). Examples of the type of personal information areas follows: name, home contact information, drivers license, funeral directors license (if applicable), health conditions, occupation/profession, work hours, transaction history and involvement with Armstrong Funeral Home. The collection of this information is based on an implied consent, as it is a requirement by the funeral home for employment purposes including health and safety reasons.
When we investigate, audit or assess a person on behalf of someone else (e.g., legal investigation, financial and professional audits, medical assessment), our primary purposes for collecting personal information are as follows: based on legal requirements, to investigate a breach of law or to provide emergency information, to ensure compliance with professional rules and guidelines. These types of investigations/assessments can cover both clients and contract staff and would involve the various personal information collected and listed above as well as publicly available information specified in regulation (e.g., telephone directories, professional directories, court or tribunal records and information provided by the individual to newspapers, magazines and books).
We do not sell, barter, trade or give away the personal information you have provided to us.
SAFEGUARDING OF YOUR PERSONAL INFORMATION
We take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modifications or
disclosure.
• Paper information is filed in a restricted area guarded from public access.
• Daily electronic backups are performed and stored in fire proof receptacles
• Electronic hardware is contained in business offices restricted from public access with password protection.
• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• External consultants and agencies with access to personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION:
We need to retain personal information for some time to ensure that we can answer any questions you or your family/executors (estate trustees) might have about the services provided and for our own accountability to external regulatory bodies (Board of Funeral Services). We do maintain permanent information that includes personal information of the deceased. This is currently contained in ledger format in a restricted area. This is required to fulfill certain business requests regarding genealogy, cemetery burial locations and additional Proof of Death Certifications. We destroy paper information containing personal information by shredding and electronic information by deleting it.
ACCESS TO YOUR PERSONAL INFORMATION:
With only a few exceptions, you have the right to see what personal information we hold about you and you many ask that the information be corrected or updated. We do however; reserve the right to confirm the identity of the person seeking access to personal information before complying with any access request.
If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days, if at all possible, and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation to prove that our files are incorrect. Where we agree that we made a mistake, we will make the correction and notify anyone to whom this information was sent. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else ssho received the earlier information.
Any questions or concerns regarding the collection and/or use of personal information: to access you personal information, withdraw a consent previously provided or make a complaint, please write to our privacy officer Brent Quinton at Armstrong Funeral Home, 124 King St. E. Oshawa, ON L1H 1B6.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street, Ottawa, Ontario K1A 1H3
Phone (613) 995-8210, ToIl-free 1-800-282-1376,
Fax (613) 947-6850, TTY (613) 992-9190
www.privcom.ge.ca
