The Adoption Council of Ontario (ACO), respects the privacy concerns of all users, its services, and programs, and is committed to protecting the personal and sensitive information (Information) of its users, children and families involved in adoption matters.
In addition to the ACO’s commitment to deal with Information in a sensitive manner, it is required by law to ensure that all collection, use, retention, disclosure and disposals of Information are carried out in accordance with mandated privacy principles.
Protection of Personal Information
“ACO” refers to the Adoption Council of Ontario
“Collect” or “Collection” means the act of Information from users, children or families featured or third parties by any means allowable under Canadian law.
“Consent” means voluntary agreement with what is being Disclosed or proposed. Consent can be either express or implied. Express consent is given explicitly, whether orally, electronically, or in writing. In allowable circumstances, consent may be implied from a person’s conduct. Consent can also be given by an authorized representative, such as a legal guardian or a person having power of attorney as defined by Canadian law.
“Disclose” or “Disclosure” means providing Information to anyone other than to that individual or that individual’s authorized agent(s).
“Health and Sensitive Information” means health information as defined under the ‘Personal Health Information Protection Act’
“Information” means Personal Information, Health and Sensitive information of individuals (including, but not limited to, children, families, and guardians) using the ACOs programs and services.
“Parent Agency” means the Children’s Aid Society or Licensed private agency or individual having legal responsibility for a particular child.
“Personal Information” means information about an identifiable individual as defined under ‘Canada’s Personal Information Protection and Electronic Documents Act’.
“Personnel” refers to employees, consultants, contractors and board members of the ACO
The Privacy Officer or other ACO Personnel may be responsible for the day-to-day Collection and processing of Information or for acting on behalf of the Privacy Officer from time to time. The ACO is responsible for the Information under its control, including any Information that may be transferred to a third party service provider for processing. Any service provider contracted to process, manage, maintain or deal with Information on its behalf is not permitted to use, retain or Disclose Information transferred to it except in accordance with the terms of its service agreement
2) Identifying Purposes
ACO will Collect Information on individuals, which may be used for one or more of the following purposes:
Before Collecting, using or Disclosing any Information the ACO will ensure that Consent is received and will maintain in an appropriate form.
4) Limiting Collection
The ACO will Collect only the amount of Information that is required to achieve the purposes identified in section (2).
5) Limiting Use, Disclosure and Retention
Information is used by a limited number of Personnel or Parent Agency employees in Ontario on a ‘need to know’ basis, while performing their duties outlined in section (2).
Information that has been used to make a decision regarding an individual shall be retained for a reasonable time to permit the individual access the Information after a decision has been made.
Information that has been transferred to the ACO by a Parent Agency on an individual’s behalf, will be retained and/or disposed of in accordance with applicable law. Subject to this, Information that is no longer required for our identified and legitimate purposes will be destroyed, erased, or otherwise made permanently anonymous in accordance with the ACOs Personal Information, Retention and Disposal Policy.
The ACO will endeavour to ensure that Information under its control or possession is accurate, complete and up-to-date as possible; in order to minimize inaccurate Information used during the execution of the purposes outlined in section (2). It is the responsibility of individuals utilizing the programs and services to ensure that the ACO is updated on changes to their Information
Information will be protected in accordance with the ACOs Terms and Conditions that are appropriate to the level of regulatory requirement. These practices are designed to protect Information in all formats against loss or theft, as well as against unauthorized access, disclosure, copying, use, or modification.
Additional Information about the ACOs privacy-related policies and procedures is available upon request by contacting the Privacy Officer.
Subject to legal rights and obligations, upon receipt of a written request for access by the Privacy Officer including sufficient identification. The ACO will provide copies to the requestor about their Information, if any. Information provided by the ACO to an individual as a result of a request for access shall be in generally understandable form.
Response to a request will be within a reasonable time, usually 30 business days of receipt. Extension to this response time of an additional 30 business days may be required, if responding within the first time period would unreasonably interfere with operations, or the time required to undertake any consultations necessary to respond to the request would make it impractical to meet that time limit. When necessary, an extension to the response deadline for as long a period as is necessary to permit conversion of the Information at issue into an alternative format that would allow a person with a sensory disability to read or listen to that Information. Written notice will be provided of any response period extension within 30 business days of the request. Responses to a request for access will be provided at minimal or no cost. If a person demonstrates to the ACOs satisfaction that Information that is held or controlled by the ACO is inaccurate or incomplete, appropriate amendments (correction, deletion or addition) will be processed. Where appropriate, the amended Information will be transmitted to other parties that have previously received the inaccurate or incomplete Information.
Adoption Council of Ontario
ATTN: Pat Convery, Privacy Officer
36 Eglinton Avenue West, Suite 503
Toronto, Ontario, M4R 1A1
Following investigation should a complaint be justified, all reasonable steps will be made to amend the relevant privacy-related policy or procedure.
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