Policies

PERSONAL INFORMATION PRIVACY POLICY FOR EMPLOYEES AND VOLUNTEERS

Safeguarding the personal information of employees and volunteers is a primary concern of CareerQuest College. We are committed to meeting or exceeding the privacy standards established by federal legislation entitled Personal Information Protection and Electronic Documents Act (PIPEDA). CareerQuest College respects the dignity of individuals, including the appropriate collection, use, and storage of personal information.

This Personal Information Privacy Policy for Employees and Volunteers details the policies and practices of CareerQuest College regarding the collection, use, and disclosure of personal information about employees and volunteers. This Personal Information Privacy Policy for Employees and Volunteers may be modified or supplemented from time to time, and in such instances all persons affected by the policy will be notified of the changes.

Definitions

In this Personal Information Policy for Employees and Volunteers, “personal information” means any information about an identifiable individual excluding the name, position name or title, business telephone number, business address, business e-mail and business fax number, as well as any publicly available information such as information found in a public telephone directory or public registry. Employee personal information is personal information collected, used or disclosed solely for the purposes reasonably required to establish, manage, or terminate an employment relationship, but does not include personal information that is not about an individual’s employment.

TEN PRIVACY PRINCIPLES

  1. Accountability
  2. At CareerQuest College the principal is the Privacy Officer responsible for implementing the privacy policy for employees and volunteers.

  3. Identifying purposes
  4. A. Employees
    CareerQuest College collects, uses, and discloses personal information about employees to establish, manage, and terminate the employment relationship, and for such other purpose(s) as identified when the information is collected.

    For example:

    • personal information collected during the hiring process such as the information on resumes, application forms, criminal record checks, and information collected from references;
    • payroll and related information including SIN, pay scale, hours of work, deductions, bank account information, court orders;
    • benefit information including SIN, premiums or contributions, coverage information, dependent information, date of birth, marital status, medical information;
    • performance information including work history, attendance history, performance and relationship reviews, discipline and related memos and notes, documentation related to qualifications and professional growth;
    • other personal information as required or permitted by law.

    B. Volunteers
    CareerQuest College collects, uses, and discloses personal information about volunteers for the purposes of recruiting volunteers, and establishing and managing an effective volunteer program, and for such other purpose(s) as identified when the information is collected.

    For example:

    • information collected, used, and disclosed in the recruiting process including information on resumes, application forms, criminal record checks, and information collected from references;
    • information related to the volunteers’ services including availability, schedule, duties, performance reviews, and notes, memos, and documentation related to qualifications.

    C. In addition
    Personal information about employees and volunteers, including photographs and biographical information may also be collected, used, and disclosed in the course of the school’s activities including in publications such as yearbooks, newsletters, and Websites;

    Personal information about employees and volunteers may be collected regarding the operation and maintenance of computers, internet and e-mail, as these are monitored in accordance with the school’s Policy on these systems;

    Personal information about employees and volunteers may be collected, used and disclosed in the course of the operation of building security systems, including video and other systems.

  5. Consent
  6. In most cases consent is not required for personal information collected, used, or disclosed for the purpose of establishing, maintaining or terminating employment or a volunteer relationship. CareerQuest College will take into account the sensitivity and intended use of personal information and where appropriate require consent to be expressed, or implied, or deemed.

  7. Limiting collection
  8. Personal information collected will be limited to that which is necessary for the purpose(s) identified.

  9. Limiting use, disclosure, and retention
  10. Personal information of employees and volunteers will only be used and disclosed for the purpose(s) for which it was collected and for which consent has been obtained, implied, or deemed. Personal information will only be retained for as long as is necessary for the fulfillment of the purpose(s).

    NOTE: CareerQuest College may disclose personal information to others in connection with the purpose(s) for which it was collected as consented to by the individual or as required or permitted bylaw. The list below should be reviewed to ensure disclosures are applicable.

    Third parties may include:

    • government bodies, departments and agencies (e.g. WSIB, Ministry of Education, CCRA);
    • payroll outsourcers;
    • insurance companies, benefit and pension plan administrators;
    • advisors to the school such as accountants, lawyers, consultants;

    CareerQuest College does not sell, lease, or trade information about employees and volunteers. Suppliers of specialized services (e.g. yearbook publishers) are given only the information necessary to provide those services, and CareerQuest College takes appropriate steps to ensure that such information is securely transferred and stored, and is used only for the purpose(s) for which it was disclosed to the service provider. If an individual seeks to limit the sharing of personal information as permitted by law, s/he must submit a written letter to the Privacy Officer specifying which information is to be limited and to whom this information is restricted. The Privacy Officer will advise the individual whether the request can be carried out. Personal information will be retained only for the time required to fulfill the purpose(s) for which it was collected. When the information is no longer needed to fulfill the purpose(s) for which it was collected, it will be destroyed or made anonymous.

  11. Accuracy
  12. Personal information shall be kept as accurate, complete and up-to-date as is necessary to fulfill the purpose(s) for which it was collected. Employees and volunteers are responsible for providing current information to the school.

  13. Safeguards
  14. Personal information will be protected by appropriate safeguards to prevent unauthorized access or uses. Employees and volunteers will be appropriately educated about the importance of privacy, and will be required to follow the school’s policies and procedures regarding personal information. Employee and volunteer files will be stored in secure filing cabinets and access to personal information will be restricted to authorized and legitimate persons. Electronic files will be password protected. The school’s security practices will be reviewed in a timely fashion to ensure the privacy of personal information.

  15. Open policy
  16. CareerQuest College will readily make available its policies and practices regarding the protection of personal information.

  17. Individual access
  18. CareerQuest College shall give an employee or volunteer access to his/her personal information file in accordance with the law. An employee or volunteer may access and verify any personal information with appropriate notice, and may provide new and current information to the Privacy Officer to include in the file.

  19. Questions and concerns
  20. All questions and concerns relating to the schools policies and procedures about employee and volunteer personal information should be directed to the Privacy Officer.

CareerQuest College (October, 2017)

SEXUAL VIOLENCE POLICY

  1. Sexual Violence Policy
  2. At CareerQuest College the principal is the Privacy Officer responsible for implementing the privacy policy for employees and volunteers.

    1. CareerQuest is committed to providing its students with an educational environment free from sexual violence and treating its students who report incidents of sexual violence with dignity and respect.
    2. CareerQuest has adopted this Sexual Violence Policy, which defines sexual violence and outlines its training, reporting, investigative and disciplinary responses to complaints of sexual violence made by its students that have occurred on its campus, or at one of its events and involve its students.
    3. The person accused of engaging in sexual violence will be referred to as the "Respondent" and the person making the allegation as the "Complainant".
  3. Definition of Sexual Violence
  4. Sexual violence means any sexual act or act targeting a person's sexuality, gender identity or gender expression, whether the act is physical or psychological in nature, that is committed, threatened or attempted against a person without the person's consent, and includes sexual assault, sexual harassment, stalking, indecent exposure, voyeurism and sexual exploitation.

  5. Training, Reporting and Responding to Sexual Violence
    1. CareerQuest shall include a copy of the Sexual Violence Policy in every contract made between it and its students, and provide a copy of the Sexual Violence Policy to career college management ( corporate directors, controlling shareholders, owners, partners, other persons who manage or direct the career college's affairs, and their agents), instructors, staff, other employees and contractors and train them about the policy and its processes of reporting, investigating and responding to complaints of sexual violence involving its students. *Any company participating in offering student internships on their premises must provide an undertaking in writing that it is in compliance with all applicable legislation, including the Ontario Human Rights Code and the Occupational Health and Safety Act and will provide students access to those policies should they encounter issues relating to sexual violence in the workplace.
    2. The Sexual Violence Policy shall be published on its website (or where the Career College does not have a website in a conspicuous location on each of its campuses).
    3. Career college management, instructors, staff, other employees and contractors of CareerQuest will report incidents of or complaints of sexual violence to Robert Toscani, Director, upon becoming aware of them.
    4. Students who have been affected by sexual violence or who need information about support services should contact the Director.
    5. Subject to Section 4 below, to the extent it is possible, CareerQuest will attempt to keep all personal information of persons involved in the investigation confidential except in those circumstances where it believes an individual is at imminent risk of self-harm, or of harming another, or there are reasonable grounds to believe that others on its campus or the broader community are at risk. This will be done by:
      1. ensuring that all complaints/reports and information gathered as a result of the complainUreports will be only available to those who need to know for purposes of investigation, implementing safety measures and other circumstances that arise from any given case; and
      2. ensuring that the documentation is kept in a separate file from 1hat of the ComplainanUstudent or the Respondent.
    6. CareerQuest recognizes the right of the Complainant not to report an incident of or make a complaint about sexual violence or not request an investigation and not to participate in any investigation that may occur.
    7. Notwithstanding (f), in certain circumstances, CareerQuest may be required by law or its internal policies to initiate an internal investigation and/or inform police without the complainant's consent if it believes the safety of members of its campus or the broader community is at risk.
    8. In all cases, including (f) above, CareerQuest will appropriately accommodate the needs of its students who are affected by sexual violence. Students seeking accommodation should contact the Director.

      In this regard, CareerQuest will assist students who have experienced sexual violence in obtaining counselling and medical care, and provide them with information about sexual violence supports and services available in the community as set out in Appendix 1 attached hereto. Students are not required to file a formal complaint in order to access supports and services.
  6. Investigating Reports of Sexual Violence
    1. Under this Sexual Violence Policy, any student of CareerQuest college may file a report of an incident or a complaint to the Director in writing. The other official that will be involved in the investigation is the Executive Director.
    2. Upon receipt of a report of an incident or a complaint of alleged sexual violence being made, the Director will respond promptly and:
      1. determine whether an investigation should proceed and if the Complainant wishes to participate in an investigation;
      2. determine who should conduct the investigation having regard to the seriousness of the allegation and the parties involved;
      3. determine whether the incident should be referred immediately to the police; In such cases or where civil proceedings are commenced in respect of allegations of sexual violence, CareerQuest may conduct its own independent investigation. and make its own determination in accordance with its own policies and procedures; and
      4. determine what interim measures ought to be put in place pending the investigation process such as removal of the Respondent. or seeking alternate methods of providing necessary course studies.
    3. Once an investigation is initiated, the following will occur:
      1. the Complainant and the Respondent will be advised that they may ask another person to be present throughout the in'{estigation;
      2. interviewing the Complainant to ensure a complete understanding of the allegation and gathering additional information that may not have been included in the written complaint such as the date and time of the incident, the persons involved, the names of any person who witnessed the incident and a complete description of what occurred;
      3. informing and interviewing the Respondent of the complaint, providing details of the allegations and giving the Respondent an opportunity to respond to those allegations and to provide any witnesses the Respondent feels are essential to the investigation;
      4. interviewing any person involved or who has, or may have, knowledge of the incident and any identified witnesses;
      5. providing reasonable updates to the Complainant and the Respondent about the status of the investigation; and
      6. following the investigation, the Director will:
        1. review all of the evidence collected during the investigation;
        2. determine whether sexual violence occurred; and if so
        3. determine what disciplinary action, i( any, should be taken as set out in Section 5 below.
  7. Disciplinary Measures
    1. If it is determined by CareerQuest that the Respondent did engage in sexual violence, immediate disciplinary or corrective action will be taken. This may include:
      1. disciplinary action up to and including termination of employment of instructors or staff; or
      2. expulsion of a student; and /or
      3. the placement of certain restrictions on the Respondent's ability to access certain premises or facilities; and/or
      4. any other actions that may be appropriate in the circumstances.
  8. Appeal
    1. Should the Complainant or the Respondent not agree with the decision resulting from the investigation, he or she may appeal the decision to CareerQuest within 7 days by submitting a letter addressed to the Director advising of the person's intent to appeal the decision.
  9. Making False Statements
    1. It is a violation of this Sexual Violence Policy for anyone to knowingly make a false complaint of sexual violence or to provide false information about a complaint.
    2. Individuals who violate this Sexual Violence Policy are subject to disciplinary and I or corrective action up to and including termination of employment of instructors or staff or expulsion of a student.
  10. Reprisal
    1. It is a violation of this Sexual Violence Policy to retaliate or threaten to retaliate against a complainant who has brought forward a complaint of sexual violence, provided information related to a complaint, or otherwise been involved in the complaint investigation process.
    2. Individuals who violate the Sexual Violence Policy are subject to disciplinary and /or corrective action, up to and including termination of employment of instructors or staff or expulsion of a student.
  11. Review
    1. CareerQuest shall ensure that student input is considered in the development of its Sexual Violence Policy and every time it is reviewed or amended.
    2. CareerQuest shall review its Sexual Violence Policy 3 years after it is first implemented and amend it where appropriate. This date is January 1, 2020.
  12. Collection of Student Data
    1. CareerQuest shall collect and be prepared to provide upon request by the Superintendent of Private Career Colleges such data and information as required according to Subsections 32. 3 (8), (9) and (10) of Schedule 5 of the Private Career Colleges Act, 2005 as amended.

This is intended to be a Sexual Violence and Harassment Policy and is not intended as legal advice.