Throughout clients’ and learners’ association with an LBS program, quite a bit of information must be gathered. This is especially true at intake and during the initial assessment. It is often a difficult step for adults to join a literacy program. They may be embarrassed and not want others to know they are there. Some learners may be reluctant to give out their home address or to share an email address or unlisted telephone number. In order for you to serve them better, learners may have to share some very personal and sensitive information about themselves.
Maintaining confidentiality and correctly handling and storing personal, private information is essential. Learners should be able to trust that you will not share this information with others. If a learner cannot trust your literacy program, then it will be difficult to develop a productive learning environment. You must be able to reassure them that their personal information will only be used to develop their learner plan, to help them with their learning goals and to contact them in the case of absence or for follow-up purposes.
There will also be learners who provide more information than you require. Try to limit them to sharing only the information necessary to maintain contact and develop their learner plan. Take some time to talk about personal and private information and why it should not be shared.
Maintaining careful controls over private information isn’t just the right thing to do; it is part of your LBS contract with MTCU. Privacy requirements are included in your LBS contract. The risk assessment done by the Ministry and the Monitoring Questionnaire that your agency must complete on EOIS-SP Connect both contain sections on privacy.
Privacy and keeping private information confidential is also the law (Personal Information Protection and Electronic Documents Act – PIPEDA). As with most issues, it is important for your organization to have a policy in place.
Here are several examples of good practice that can help your agency maintain the confidentiality of learner information:
- Keep copies of learner plans and learner files in a locked filing cabinet. Put files away when not in use.
- Destroy rough copies or jotted down notes as soon as the information has been transferred to the learner’s file. (Shredders are wonderful, inexpensive tools!)
- Ensure that all computer records are password-protected.
- Have a “need to know only” policy. Don’t give information, access to files or passwords to people who don’t really need them. Don’t look at or keep information or files that you don’t need.
To assist organizations in meeting their privacy obligations, MTCU has developed some tools, which can be found on the Employment Ontario Partners’ Gateway’s Protecting Personal Privacy section. This page offers a Summary of Your Organization’s Privacy Obligations; Questions and Answers (Asked by Clients); and Privacy Resources links. Also, under the link “Tips to Safeguard Clients’ Personal Information” they offer these further privacy tips:
- Hard copy documents containing clients’ personal information must be stored in locked filing cabinets.
- Follow a clean-desk policy.
- Lock your computer every time you leave your workstation. On a PC, you can lock your desktop by using Ctrl-Alt-Del and pressing Enter. For a Mac you can lock it by using Ctrl-Shift-Eject.
- Update clients’ personal information through a face-to-face meeting or a signed mail-in request.
- Do not send or leave personal information in an email or voicemail.
- Do not store clients’ personal information on portable memory sticks (USBs), laptops, your computer desktop or mobile devices.
- If you must take client paper files off-site (e.g., resumes for potential employers), be vigilant in protecting them.
- Be aware of your surroundings when discussing clients’ personal information. Limit what you say (talk softly!).
This Questions & Answers on Privacy and Access to Information (April 2012) is based on actual questions submitted to the Ministry and has some practical information for protecting client data.
- What steps could you take to ensure that learner information remains confidential?
- How do you ensure that your ONe-key password and your EOIS-CaMS Private Identification Number remain secure?
- What would you say or do to reassure a learner who is reluctant to give you his or her home address, telephone number or email address?