At the Ontario Nurses’ Association (ONA), the privacy of your personal information has always been an important aspect of how we operate.
The Ontario Nurses’ Association is a membership focused, proactive union, sensitive and responsive to the ever-changing needs in an evolving health-care system. We are also strongly committed to protecting the personal information of members and employees, providing the necessary safeguards to secure it, and ensuring its accuracy.
The federal Personal Information Protection and Electronic Documents Act (PIPEDA) came into effect January 1, 2004 and applies to provincially regulated organizations that collect, use and disclose personal information in the course of commercial activity. As a union ONA does not generally participate in commercial activity, therefore is not covered by this Act.
Maintaining appropriate confidentiality in collecting, using and disclosing member and employee personal information is extremely important to ONA. As such, ONA has developed the following Privacy Policy using the guidelines set out in the PIPEDA, as well as to inform members and employees of our continuing commitment to the protection of their personal information.
What personal information do we collect?
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. We collect the following personal information:
- Name.
- Address.
- Telephone/fax numbers.
- Email address.
- Birth date.
- Sex/Gender.
- Marital/Family status.
- Employment information.
- College registration number for regulated Health-Care Professionals.
- Social insurance number.
- Medical, benefits, Workplace Safety and Insurance information.
- Employment information related to collective bargaining, administration of collective agreements and the employment relationship (including but not limited to employer, application material/resumes, transcripts, job/position/classification, wages, benefits, duties performed performance evaluations, discipline, grievance and other legal complaint-related information, correspondence, investigation, records.)
Who is responsible for protecting the personal information collected, used and disclosed by ONA?
The Chief Executive Officer of ONA, the Board of Directors, Local Executive members, the Privacy Officer, Human Resources, and ONA employees, are responsible for ensuring compliance with this Privacy Policy.
Why does ONA collect, use or disclose personal information?
ONA is committed to providing labour relations and other services to members, educational opportunities, and up-to-date information in the field of professional practice and health care, as well as information regarding the association itself.
In order to meet these goals, ONA may collect, use and disclose personal information of members and employees, when applicable, for the following purposes:
- To verify the identity of ONA members and employees.
- To register members and employees for ONA events, education, and programs.
- To permit and assist ONA members to communicate with each other and participate in ONA.
- To collect dues through employers.
- To provide representation to members including but not limiting to negotiating and administering collective agreements, enforcing statutes and legislation, administer employment relationships, and provide general assistance in other matters.
- To investigate and resolve grievances, Workplace Safety & Insurance Board claims, Long Term Disability claims, Ontario Relations Board issues, health & safety matters, regulatory proceedings, court, and other legal issues or proceedings, workload and quality patient care issues and professional practice issues.
- To detect and prevent fraud.
- To meet regulatory requirements.
- To research for trending purposes.
- To assess your eligibility for products and services.
- To communicate and provide information and updates to members including about ONA, its activities on behalf of members, and other information relevant to ONA members, member and employee benefits.
- To communicate and provide information about upcoming events, programs, services and other opportunities to members and employees.
- To provide members and employees the appropriate access to the secure areas of the ONA website and member portal.
How do individuals provide ONA with their consent for the collection, use and disclosure of their personal information?
To the extent that ONA acts as the exclusive bargaining agent for its members in their employment relations with employers, labour law gives it the authority to collect personal information that relates to the collective bargaining or collective agreement administration. The individual consent of members is not required since ONA requires this information to carry out its lawful activities as exclusive bargaining agent. This policy does not limit this legal authority.
Apart from this where consent is required, Individuals provide their consent in many ways, such as by choosing to work in an ONA unionized facility, by providing personal information to ONA to obtain service or employment, including information previously provided to us, by expressed consent for a specific purpose and through your authorized representative.
ONA staff, Board of Directors, and Local Executive have access only to the personal information provided by the member, employer or employee that is required to fulfill the purposes stated within this policy. Personal information about prospective members or employees may be collected from individuals when they approach ONA for organizing or employment.
With whom does ONA share information?
ONA may share your information with service providers who assist us including lawyers, doctors, accountants, and other professionals and affiliates, those who conduct membership or employee research for us, with outside mail houses or printing companies for ONA mailings and affinity programs as established by ONA.
These parties are not allowed to use personally identifiable information except for the purpose of providing these services.
How do individuals withdraw their consent for ONA to use and disclose your information?
To the extent ONA acts as a member’s exclusive bargaining agent, the consent of members to collect, use and disclose their personal information as it may relate to collective bargaining and collective agreement administration is not legally required according to labour law. For this reason, the withdrawal of individual consent does not arise.
Apart from this, where individual consent is required, you may, on reasonable notice, withdraw consent to the collection, use of or disclosure of your personal information provided there are no legal requirements to prevent this. However, that may prevent us from providing you with the requested product or service and impede our ability to represent you.
To the extent that consent is legally required to collect, use, or disclosure the membership information for a specific purpose (such as a voluntary communication/email from the union), consent can be withdrawn by contacting ONA who will ensure that the individual’s personal information will no longer be used or disclosed by the organization for that purpose.
How long does ONA retain personal information?
ONA retains personal information only for as long as is required to fulfill the purposes stated within this policy, and to meet all requirements by law.
How accurate is the personal information collected, used and disclosed by the ONA?
It is ONA’s goal that personal information that is collected, used and disclosed by ONA is as accurate as is necessary to fulfill the intended purpose. ONA’s primary sources for updates are members, leaders and employers. Members are encouraged to update ONA directly through the Dues and Membership Services Team at Toll Free; 1-800-387-5580 extension 2200, via email to memberchanges@ona.org or through the ONA website at www.ona.org
Employees may contact Human Resources to update their information.
Where there is a dispute about whether or not the personal information is accurate, which cannot be resolved, ONA will briefly record the nature of the dispute and, if it deems necessary and practical to do so, communicate this to anyone with whom it shared that information.
How secure is the personal information stored at ONA?
ONA is committed to ensuring that personal information is protected from unauthorized access, unintended disclosures or theft. This protection is provided by firewalls in the computer system, passwords and multi-factor authentication to protect databases and internal systems, lockable filing cabinets and restricted access to the offices. Access levels are assigned as required to fulfill the purposes stated within this policy. ONA regularly reviews its security infrastructure and implements improvements based on industry standard best practices.
How is personal information collected, used or disclosed via ONA’s website?
In order to enhance your browsing experience when accessing the secure section of ONA’s website, a small text file called a “cookie” is sent from our web server to your browser and stored on your computer. Cookies allow us to recognize you while you are logged in to ONA’s website and expire when you close your browser window. You may set your browser to notify you when you receive cookies, and you may choose to disable or delete cookies if you wish. Cookies are not programs or code, and are only used to optimize browsing.
ONA’s website may also log Internet Provider (IP) addresses of visitors. This information is used, in aggregate form, to provide statistical measures about usage of the site. This in turn allows us to continually improve the content and design of our websites.
ONA’s website may contain links to other websites owned and operated by third parties. While we attempt to ensure that these organizations adhere to similar privacy policies, we are not responsible for the content or privacy practices of such sites. It is highly recommended that you review the privacy policies of other sites prior to providing any personal information on those sites.
How can individuals learn more about ONA’s Privacy Policy?
Updated versions of this Privacy Policy will continue to be posted on the ONA website at www.ona.org as we make updates. This Policy is also available in hard copy at the ONA office, a copy of which can be requested by contacting ONA at:
Ontario Nurses’ Association
85 Grenville Street
Toronto, ON M5S 3A2
Phone: (416) 964-8833
Fax: (416) 964-8864
Email: onamail@ona.org
How can individuals access their personal information held by ONA?
Individuals have a right to seek access to their own personal information in the possession and control of ONA, subject to restrictions contained in this policy or by law. They also have a right to know if their information has been disclosed to any third parties. If individuals wish to access their personal information, they need to contact ONA in writing at the above mailing or email address. ONA reserves the right to charge a reasonable fee for the copying of this information.
Except where otherwise required by law, it is ONA’s policy that access to personal information may not be permitted in the following cases:
- Legally privileged information.
- Medical evaluations prepared at the request of ONA.
- Where disclosure is prohibited by law.
- Information concerning persons other than the individual seeking access.
- Information given to ONA in confidence.
- Information, which may threaten or harm the individual seeking access to their life, health, safety or security. ONA will consider releasing it to any health practitioner assisting the individual if it considers it sage and appropriate to do so.
- Where doing so might prejudice any claim brought by ONA on the individual’s behalf.
- Information relating to any dispute settlement process between ONA and the individual seeking access.
- Notes, communications, and other work product of ONA officers and staff.
- Information which could threaten or harm the life, health, safety or security of individuals other than the individual seeking access.
- Where in ONA’s view the request is frivolous, vexatious or made in bad faith.
Where ONA can sever the information that is not to be disclosed from that which can be, it will do so.
How can individuals relay their concerns about their personal information held by ONA?
If individuals have a question, concern, or complaint related to the ONA Privacy Policy, they can contact the Privacy Officer at ONAPrivacyOfficer@ona.org.