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The Association firmly believes in the individual’s right to privacy.  At the same time, the Association has a legitimate need for retaining employee information.  A balance must be struck between the employee’s right to privacy and the Association’s need to keep current employee files.  This balance can be attained through the establishment of guidelines relative to the collection, use, access, dissemination, retention and confidentiality of employee and applicant information.

For each employee of EDCL, pertinent information will be collected in order to establish that person as a Staff Member and for the administration of payroll and benefits where applicable. Information will be retained in the Administration Office and personal information collected will be kept for the time necessary to fulfill the purposes for which it was collected.



Personal Information is defined as information (data) – oral, written or electronic – about an identifiable individual. This Association has adopted the ten privacy principles established by the Canadian Standards Association’s Model Code for the Protection of Personal Information.

These ten principles form part of the Personal Information Protection and Electronic Documents Act.

  1. Accountability: EDCL is responsible for personal information under its control and has designated the Human Resources Director as the Privacy Officer who is accountable for the organization’s compliance with the following principles.
  2. Identifying Purposes: We will identify the purposes for which your personal information is being collected either before or at the time of collection.
  1. Consent: The knowledge and consent of the individual are required for the collection, use or disclosure of personal information.
  1. Limiting Collection: The collection of personal information shall be limited to that which is necessary to facilitate an employee relationship for the purposes identified by this organization.
  1. Limiting Use, Disclosure and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by the law. Personal information will be retained only for the time necessary to fulfill the purposes for which it was collected. Inactive personnel files will be retained in the Administrative office for a period of Seven (7) years. Thereafter, the personnel file will be shredded.
  2. Accuracy: Personal information will be kept as accurate, complete and up-to-date as possible to fulfill the purposes for which it was collected. People are responsible to provide us with any changes to their personal information, such as address changes, etc. Employees have the right to challenge the completeness of their personal information and amend it as necessary.
  1. Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information
  2. Openness: EDCL will make readily available to its employees specific information about its policies and practices relating to the management of their personal information
  3. Individual Access: Employees are informed of the existence, use and disclosure of their personal information and shall be given access to that information according to the procedures outlined in Policy #3.05.12
  4. Challenging Compliance: Employees may address a question or concern regarding compliance with the above privacy principles to the Privacy Officer.


Employee Records

The Association requires all employees to adhere to these principles and guidelines and to the relevant provincial and federal legislation as established by PIPEDA. Violations are subject to disciplinary action up to and including dismissal.  The Human Resources Director/Administration office is the primary authority to control the release of employee information, provide guidelines to those maintaining employee personnel files, and assure compliance with these principles.

A personnel file will be retained by the Administration office.  The information will be requested and retained only on a “need to know” basis.  The confidentiality of all personal information retained in Association records and files will be protected at all times. “Supervision” files may be kept by the immediate Manager/Supervisor in a secured work location.

The Human Resources Director, in co-operation with the program Manager, will ensure the necessary documentation is completed when Staff are hired or transferred.

The Personnel File and its contents are the property of the Association and are considered confidential.  No documents, reports, etc., may be removed by any employee.

However, photocopies may be made of appropriate information by the Administration office at the request of an employee.  The administration office will be responsible for reactivating inactive personnel files when an employee resumes employment with Elmira District Community Living.

Collection and Access of Employee Records


The Association will gather all necessary information for its employee record files directly from the employee, except for:

  1. a) References (with employee’s consent) at the time of application
  2. b) Criminal record check (with employee’s consent)
  3. c) Performance reviews
  4. d) Disciplinary documentation and related notations
  5. e) Third party correspondence and requisitions, for example, court orders
  6. f) Garnishments

Internal Access

Access to employee personal information records is prohibited to other employees, with the following exceptions:

  1. a) Authorized representatives of the Administration Office on a “need to know” basis.
  2. b) Appropriate Management Staff.
  3. c) The Association legal counsellors or audit Staff when specifically approved in advance.
  4. d) Executive Director/Services Director /Human Resources Director.
  5. e) Ministry of Children, Community and Social Services.

External Disclosure

All requests for information about current, retired or terminated employees must be referred to the Administration office.  Signed consent will be obtained at the time of hiring for authorizing disclosure of personal information to third parties for the purposes of establishing that person as an employee of EDCL and providing benefits or other services.

Exceptions to this include:

  1. Responses to written or telephone requests for verification of employment. The information will be released only, and will be limited to:
  2. a) Confirming current or previous employment
  3. b) The position title
  4. c) The employment dates
  5. Duly authorized and served requests from law enforcement agencies, and Provincial or Federal regulatory agencies, in which case the employee will be notified.
  6. Outside organizations performing services, such as legal representation, for the Association. Any release of information to these organizations must be approved by the Executive Director.

Employee Access

To review their own personnel file, employees must submit a written request to the Human Resources Director. Employees will be able to view the contents of their personnel file in the presence of a designated Association Management employee at a time convenient to both parties. Employees may not remove material from their files.

At the Employee’s request, discipline notices shall be removed from the Employee’s file after a period free of related discipline as per the terms of the Collective Agreement.

Record of people supported and Association Financial Reports handling of people’ records and EDCL’s financial records are governed by different MCSS standards.  For information pertaining to people supported, see the EDCL Supports Services Program Manual. For information pertaining to financial records, see the Financial Policy Manual and Support Services Manual.