The Information Protection Officer is the contact person within our organization who is responsible for information privacy.
The following information may be collected in the course of MoveSafe® duties:
- Contact information: Required in order to get in touch with personnel to schedule meetings or site visits. MoveSafe is not specifically requesting personal information, but workers may give personal information and MoveSafe may not necessarily know this. Therefore, all contact information will be kept private and used only for making contact related to work activity.
- Relevant Medical Information: Required in order to help implement appropriate interventions/offer appropriate assistance and/or to make sure personnel are healthy enough to participate in MoveSafe® programs and initiatives.
- MoveSafe will collect only this required information and use it only for the specified purposes described above.
- MoveSafe will verbally or in writing explain to each person the purpose for collecting the personal information.
- If asked by the worker, MoveSafe will provide the contact information for our information protection officer.
- MoveSafe will avoid noting personal information in written documentation, unless required to justify a recommendation and will only be included if consent has been obtained from the worker ahead of time.
- Knowledge & Consent are required to collect and use personal information. Written or verbal consent is preferred.
- MoveSafe will include appropriate written notification regarding collection, use and disclosure of personal information on MoveSafe data collection forms.
- If there is a reasonable expectation that the personal information may be disclosed in a report or some other manner, MoveSafe staff will ask the worker at the time of information collection if the information may be disclosed as needed.
Retention of Information
- Within a reasonable period of time after MoveSafe no longer reasonably requires personal information for legal or business purposes it will be destroyed.
- Information no longer required to fulfill the documented purpose will be erased or destroyed.
- When collecting personal information, MoveSafe needs to be ‘sufficiently accurate’ to minimize the possibility of making an inappropriate decision about a person whose information was collected.
The nature of the safeguards depends on the sensitivity of the information.
- Physical measures, for example, locked filing cabinets and restricted access to offices.
- Organizational measures, for example, security clearances and limiting access on a “need-to-know” basis.
- Technological measures, for example, the use of passwords and encryption.
- The means of gaining access to personal information held by the organization; is to make an appropriate request in writing, electronic documentation is also sufficient.
- Personal information obtained by MoveSafe is, but not limited to, an individual’s demographics (name, job title, workplace location and/or supervisor), discomfort/injury, assessment findings, recommendations and treatment methods.
- An individual can request access to their personal information and MoveSafe will provide it in a reasonable time and at no cost to the individual, unless there are extenuating circumstances like the information also includes confidential info related to someone else, or if it’s too costly to access it, or if there are legal reasons to keep it private, etc.
- If asked MoveSafe will also provide an account of the use that has been made of the information and any 3rd parties to whom the information has been disclosed
- A person can challenge the accuracy of that information and MoveSafe must respond clarifying or correcting the information.
- When a challenge to compliance of personal information protection is received in writing, the Information Privacy Office will investigate and will resolve any identified non-compliance.
Disclosing Personal Information
- MoveSafe will not disclose personal information without worker consent unless there are extenuating circumstances.
Loss of Personal Information
- MoveSafe will provide notice to the Information and Privacy Commissioner of any incident involving the loss of or unauthorized access to or disclosure of the personal information where a reasonable person would consider that there exists a real risk of significant harm to an individual as a result of the loss or unauthorized access or disclosure.
- The risk of significant harm to an individual as a result of the loss or unauthorized access or disclosure of information collected by MoveSafe is minimal; however, if such a circumstance were to arise, MoveSafe will report the loss to the Information and Privacy Commissioner without delay.
Update April 1st 2020.