Privacy Policy

Starling Community Services takes privacy very seriously and is committed to protecting the trust and privacy of its employees, clients, residents, donors, volunteers and other stakeholders. We recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that you share with us.

Your Personal Health Information

Starling Community Services and its Front Door program follows the privacy principles outlined in the Personal Health Information Protection Act (PHIPA), as well as the Personal Information Protection and Electronic Documents Act (PIPEDA) where they apply. Many safeguards are in place to protect the information you share with us. If you have any questions about our privacy safeguards, please ask your worker or ask to speak with our Privacy Officer.

Purpose of Information Being Collected and Used

When you come to Front Door, we start an electronic file. We only collect and use information necessary for the purpose of providing the agreed upon service. A more specific purpose statement for collecting and using your information can be found in the Information and Privacy section of the client handbook on this website or provided to you at your appointment.

Starling Community Services is required to report to our funders non-identifiable aggregate data (just numbers) and in some cases personally identifiable data collected about you for the purpose of demonstrating accountability and measuring the effectiveness of services. For more information on funder required data, please refer to the Information and Privacy section of the client handbook on this website or inquire with your worker.

Starling Community Services may use non-identifying data such as total numbers and/or quotes in proposals, research projects and/or social media for the purpose of seeking funding, promoting and making service improvements within our agency, region and beyond. Starling Community Services also uses non-identifying aggregate data for internal purposes of informing risk management, quality improvement and planning.

Direct and Indirect Collection of Information

Information will be collected from you directly as part of your participation in service. There may be circumstances where information is collected indirectly when it reduces risk or when it is not possible to collect it directly from you in an accurate, complete and/or timely manner.

Your Right to Access Your Records

It is your right to have access to your file. You may request to see your file and/or request a copy of information from your file. Certain exceptions apply as outlined in our access to records policy and will be explained to you at the time of request. To access your records as a current client, a request is made for an appointment with the Program Manager. If you are a past client, an appointment request is made with the Program Director.

Your Right and Responsibility to an Accurate File

You are responsible to provide accurate and up-to-date information and changes and have the right to correct information in your files. You may request that staff make corrections to your records where the record is shown to be incomplete or inaccurate. Staff may require that you put the request in writing to ensure accuracy of changes.

Storage of Records

Your file may be in paper and/or electronic format. Paper files are kept in a locked file cabinet within a locked room. Electronic files are part of a web-based client information system that has many security features in place. Your file cannot be accessed without an assigned and secure password.

Your files are kept for as long as required by standards and legislation. You may ask your worker how long records are kept specific to your program area.

Your Informed Consent

A consent is your verbal or written permission allowing us to ask for and/or share information with specific agencies, organizations or individuals. An “informed” consent for collection use and release of information, means that the purpose has been explained to you in language and format that is understandable to you.

Your Implied or Understood Consent

We would like you to be aware that when participating in a Starling program or service, your personal health information may be shared with other relevant Starling staff members and joint service delivery partner staff who are working with you and your care team.

Your Verbal or Written Consent

For staff to either collect information or talk to a third party such as a counsellor, family doctor, school, caseworker, landlord etc., we ask for your verbal and/or written permission or ‘consent’.

Limits to Confidentiality

We will not disclose your information to any third party without consent except where required by law, where failure to do so might result in serious injury or death of self or others, or where there is knowledge or suspicion of child abuse.

Your Right to Withdraw or Withhold Consent

Consent can be withdrawn at any time by informing us verbally or in writing. Once consent is withdrawn, we can no longer seek or share information. Withdrawal of consent cannot reverse any action that was already taken with your previous consent.

Electronic Communication Consent

(as per Service Agreement)

Starling Community Services recognizes that the use of technology can be a timely and friendly way to communicate however before we agree to communicate via email or text, it is important that everyone understands and accepts the risks and guidelines involved.

1. The privacy and security of electronic communication through email and smart phones cannot be guaranteed. To ensure that all confidential information is secure, you are advised to use password protection on all electronic devices.
2. Electronic communication is not always the best way to communicate. At times a face-to-face meeting with staff may be suggested.
3. You are encouraged to always double check where you have addressed an email or text before sending, as it can be misaddressed and sent to unintended or unknown persons.
4. Staff’s email address or contact information is not to be included in any mailing lists. If this occurs, it may result in not being allowed to continue electronic communication with Starling staff.
5. Deleted emails may not be permanently deleted; back-up copies may exist on a computer or in cyberspace.
6. Emails can introduce viruses into a computer system and potentially damage the files. Emails can be viewed by Starling IT staff for security purposes.
7. Emails and text messages will be summarized and entered into your file as part of your record. Client records can be used as evidence in court. All copies of emails will be deleted by Starling.
8. No phone or online video software is entirely secure. Starling computer systems have strong internal security, which helps protect my privacy and confidentiality. Starling will not be responsible for breaches of your confidential information if they are not the direct result of intentional misconduct.
9. There is no guarantee that staff will respond to email or text messages immediately. If you need immediate assistance please do not call your worker, call 911 or seek assistance in other ways appropriate.
10. You are asked to inform your worker of any changes to your email/text address.

Phone & Video Services

(as per Service Agreement)

The use of technology can sometimes be a helpful way to provide service to you and your family, when meeting in person is not possible or suitable. However, before we agree to offer services (such as support or therapy) through phone or video options, it is important that you and your family understand and accept the risks and guidelines involved.

1. To ensure your privacy, you should choose a private and quiet place where our conversation cannot be overheard and free from distraction. When meeting by phone or video, there is a risk of others finding out about you working with Starling Community Services if you did not want them to know.
2. You are asked not to record this session without the direct permission of everyone involved.
3. All individuals present for the phone or video session must be within view of the camera or acknowledge their presence so that everyone is fully aware of who is participating.
4. It is necessary to let staff know of your location and provide an emergency contact, and that in the event of an emergency, emergency services may be called to your location.
5. There could be interruptions in meetings due to technology or connection failures, and we will create a plan in advance for what to do if this happens.
6. Everything outlined in the service agreement that applies to in-person meetings also applies to phone and video meetings. Phone and video meetings will be summarized and entered into your file as part of your record, in the same way as in-person meetings.
7. Phone and video meetings are not always the best way to communicate and staff may decide that they are no longer appropriate. Face-to-face meetings with staff or other alternatives may be suggested if phone or video meetings are no longer suitable.
8. You are requested to use a private internet connection rather than public/free wifi, as this increases confidentiality and security.
9. You are responsible for paying for your own internet costs.
10. You are to use passwords on all your devices as this controls who has access and improves confidentiality and security.
11. No phone or online video software is entirely secure. Starling computer systems have strong internal security, which helps protect your privacy and confidentiality. Starling will not be responsible for breaches of your confidential information if they are not the direct result of intentional misconduct of Starling Community Services.

Who can I contact for more information about this privacy statement?

If you would like to know more about Starling Community Services’ privacy policies or if you have any questions, concerns or complaints relating to Starling’s handling of personal health information, we invite you to contact our Privacy Officer, Rory Goodman, by email.

You have the right to complain to the Information and Privacy Commissioner of Ontario if you think your rights have been violated at https://www.ipc.on.ca/or call 1-800-387-0073. For more information about your rights go to https://www.ipc.on.ca/

Please note:

• We use standard programs which will count and analyze a range of user activities in order to help us improve the website.
• We reserve the right to modify our Privacy Policy from time to time without notice.