Privacy
Purpose
The Renfrew County District School Board (RCDSB) privacy policy (Administrative Procedure 181) provides a set of minimum requirements to help maintain a culture of privacy across the district. The needs and circumstances of specific departments may require additional and more detailed guidelines, which would also be consistent with this school board privacy procedure.
It is the practice of the RCDSB to collect, use, retain and disclose personal information in the course of meeting its statutory duties and responsibilities. The district is committed to the protection of privacy and complies with all applicable provisions in the Education Act, the Municipal Freedom of Information and Protection of Privacy Act, the Personal Health Information Protection Act, and any other applicable legislation.
Rationale
The RCDSB only collects personal information when it is necessary for providing for the education for students and/or the employment of school board employees or as required and authorized by law. The school board operates under the authority of the Education Act and its associated regulations.
The management of personal information collected by the school board for these purposes is in accordance with the provisions of the Education Act, the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA), and the Personal Health Information Protection Act (PHIPA).
Guidelines
The protection of personal information held by the school board is guided by the principles contained in the Ontario School Board/Authorities Privacy Standard.
Accountability and Responsibility
Under MFIPPA, the school board is responsible for personal information under its control and may designate, in writing, an individual(s) within the school board who is accountable for compliance with privacy legislation.
Under PHIPA, health information custodians are responsible for personal health information in their custody and control and may designate an individual within their school board as an agent to assist with compliance to privacy legislation.
Specified Purpose
The school board shall identify the purpose(s) for which personal information is collected, and individuals shall be notified of the purposes and any other information required by law at or before the time personal information is collected.
Consent
Personal information is collected for the provision of educational services to students. The knowledge and, in some cases, the consent of an individual is required for the collection, use, retention, and disclosure of personal information, except where otherwise permitted by law.
Limiting Collection
The school board shall limit the collection of personal information to which is necessary for its specified purposes in accordance with its statutory duties and responsibilities.
Limiting Use, Retention, and Disclosure
The RCDSB shall not use, retain, or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as authorized or required by law. The school board shall retain personal information in accordance with the Table of Laws and Citations with Records Retention Requirements for School Boards. The Classification and Retention Scheme for the Renfrew County District School Board will also serve as a guideline in limiting use and retention of records.
Accuracy
The RCDSB shall ensure that personal information is accurate, complete, and up-to-date in order to fulfil the specified purposes for its collection, use, disclosure, and retention.
Safeguards
The school board shall ensure that personal information is secured and protected from unauthorized access, use, disclosure, and inadvertent destruction by adhering to safeguards appropriate to the sensitivity of the information.
Openness and Transparency
The RCDSB shall make available to the public specific information about its policies and practices relating to the management of personal information.
Access and Correction
Upon request, the school board shall allow an individual to access his/her personal information and will be given access to that information in accordance with privacy legislation, subject to any mandatory or discretionary exceptions. An individual has the right to challenge the accuracy and completeness of the information and to request that it be amended as appropriate or to have a letter/statement of disagreement retained on file. Any individual to whom the disclosure of the personal information has been granted in the year preceding a correction has the right to be notified of the correction/statement. An individual is advised of any third party service provider requests for his/her personal information in accordance with privacy legislation.
Compliance
An affected individual shall have the ability to address or challenge compliance with these principles.
Legal References
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Education Act, s 265(1); s 266; s 171(38)
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Municipal Freedom of Information and Protection of Privacy Act