Privacy of personal information is important to Kompass Life Care Group Inc. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We strive to be open and transparent regarding the handling of personal information. This document describes our privacy policies.
What is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information that relates to: an individual's personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status); health (e.g., health history, health conditions, health services received by them); or, activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is different from business information (e.g., an individual's business address and telephone number). This is not protected by the privacy legislation.
Who We Are
Our organization, Kompass Life Care Group includesMs. Monique Besz. 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 consultants, bookkeepers, accountants and lawyers. 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.
We Collect Personal Information: Primary Purposes
Like all service providers in the Life Care field, we collect, use and disclose personal information in order to serve our clients.
For our clients, the primary purposes for collecting personal information is to prepare a life care plan or a review of a life care plan that has already been prepared. Examples of the type of personal information we collect for those purposes include the following: information about a client's health history, including their family history, physical condition and function and social situation, in order to assess what their healthcare needs are; and to advise them of their options. A second primary purpose is to obtain a baseline of health and social information in order to identify changes that may occur over time.
When we prepare a life care plan for someone (e.g., in a legal case or for an insurer), our primary purposes for collecting personal information are as follows: to prepare a life care plan or a review of a life care plan that has already been prepared.
We Collect Personal Information: Related and Secondary Purposes
Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
- To invoice clients for goods and services.
- The costs of the services provided by the organization to clients that are paid for by third parties such as insurers or legal community.
- Clients or other individuals we deal with may have questions about our services after they have received the Life Care Plan. We retain our client information for ten years after the last contact to enable us to respond to those questions.
- Various government agencies (e.g., Canada customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staf,f as a part of their mandates. In these circumstances, we may consult with professionals such as lawyers, accountants who will investigate the matter and report back to us.
- If Kompass Life Care Group Inc. or its assets were to be sold, the purchaser would want to conduct a "due diligence" review of the company's records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization's business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information is either under supervision or secured in a locked or restricted area.
- Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital, as these signals are more difficult to intercept.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted either through a direct line or has identifiers removed or is encrypted.
- 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 might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
We keep client files for ten years. We keep any personal information, relating to our general correspondence with people who are not our clients, newsletters, seminars and marketing activities for 1 year after the newsletter, seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.
You Can Look at Your Information
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
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 that our files are wrong. Where we agree that we made a mistake, we will make the correction and, where appropriate, notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will agree to include in our file a brief statement from you on the point and, as appropriate, we will forward that statement to anyone else who received the earlier information.
Do You Have a Concern?
Our Information Officer, Ms. Monique Besz, can be reached at 613-249-0219, for further information or to address any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. She will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal written decision with reasons.
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 a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street
Ottawa, Ontario K1A 1H3
Phone: (613) 995-8210
Toll Free: (800) 282-1376
TTY: (613) 922-9190
Fax: (613) 947-6850