The Personal Information Protection and Electronic Documents Act
Effective January 1st, 2004, the Federal Government of Canada has introduced The Personal Information Protection and Electronic Documents Act or PIPEDA. The purpose of PIPEDA is to provide Canadians with a right of privacy with respect to their personal information that is collected, used or disclosed by an organization in the private sector in an era in which technology increasingly facilitates the collection and free flow of information.

Why A Company Privacy Policy?
As a funeral home, we are required on a regular basis, to collect personal information related to clients, the general public and third parties. Our goal is to maintain the highest standards possible when collecting, holding and disclosing information of this nature. This means that we will only collect information that is required and will only use and release pertinent information as necessary to fulfill the terms of the Goods & Services that we have been contracted to provide. We also feel it is important that we be open and upfront as to how we handle personal information. The following document explains in detail our privacy policy.

What is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual's business address and telephone number), which is not otherwise protected by privacy legislation.

Who We Are
The Innisfil Funeral Home includes a combination of full & part-time staff. The composition of these staff members includes Licenced Funeral Directors, non-licenced assistants, occasional workers, organists, receptionist and cleaning staff. As a normal function of our business, we have regular contacts with organizations and private sector companies that are not employed by this funeral home. In the course of their duties, these organizations may have limited and controlled access to personal information we hold. These include cemeteries, churches, clergy, other funeral homes, accounting firms, lawyers, funeral vehicle rental companies, federal, provincial and municipal offices, transportation companies, monument companies, physicians, media, computer and Internet consultants, hospitals, financial institutions and other funeral related supply companies. We restrict their access to any personal information we hold as much as is reasonably possible. We also obtain, wherever reasonable and possible, their assurance that they follow appropriate privacy principles.

Collection of Personal Information: Primary Purposes
Information Collected From Clients
Like all funeral homes, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide funeral related Goods & Services. We collect information related to both the deceased and the legal authorized purchaser/contact person. More specifically, the primary purpose for gathering such information is to allow us to complete necessary documentation related to funeral services and to provide required information to outside organizations so that they may provide goods and services related to what we have been contracted for. Most information disclosed by our funeral home is done so on the basis that "we are acting as an agent on behalf of the purchaser/contact person". Any release of information is based on what would be considered reasonably related to the nature of the request. We will release information where we believe the client would consent if asked by this organization. (e.g. 1, Provincial Registration Forms might include information that would not be disclosed to cemeteries or clergy such as Social Insurance Number)(e.g. 2, Cemetery companies record personal information about the contact person over and above the deceased's information in order to maintain accurate records, whereas a company supplying an outer burial container on behalf of the funeral home would require limited information about the deceased only)

A common and expected practice within funeral homes is the release of personal information about the deceased and their family to the general public (e.g., memorial folders/bulletins, foyer name boards, newspaper notices, monuments, telephone inquiries). This information is limited to what is reasonably expected of a funeral home with information being directly related to the arrangements. We will not release to members of the public any personal phone numbers, addresses or business contact information even if this information is available in public directory publications or electronic databases.

It is not our usual practice to collect any personal information without the client's express consent, but this might occur in a case of urgency (e.g., the client is unavailable) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a nursing home informs us of a death but we have not heard from the family, we may request contact information to allow us to set appointment and complete arrangements).

Information Collected From or About Members of the General Public
For members of the general public, our primary purpose for collecting personal information is usually related to condolences and charitable contributions. Often this collection, use and disclosure is done without the individual's consent as this information is volunteered by them to us for that express purpose. It is reasonable for us to assume that the person providing this information understands that we will disclose this information to the funeral home contact person and charity involved. It is also an expected practice in funeral homes that a card containing the donor's name and address be placed on display in a public area of the funeral home.

It would also be considered reasonable for us to deliver condolences or donation acknowledgment cards to the funeral contact person even if the item is specifically addressed to another person related to the same family. Our obligation is to the contractee and often we do not have access to personal information of any other person but than that of the funeral home contactee. It is this person's sole responsibility to forward such items to the intended person and is done at their discretion.

As a funeral home, we often obtain information about third parties. This information is collected where required to fulfill the terms of our contract (e.g., newspaper notices, clergy records, cemeteries, provincial legislation) It is reasonable for us to assume that this information has been provided to us with permission. If any objection is received by the involved third party, we will remove this information from our files and from any documents that are still in our possession. (e.g., if someone files an objection that they do not want their name in a newspaper notice, we will remove this information providing the newspaper has not gone to print or that we have not passed the publication deadline for submissions and corrections as set by that company).

Any personal information provided by one person on behalf of a third party would lead us to reasonably assume that permission has been given for them to disclose this information to us and that they have no reason to expect that this would be inappropriate. (e.g., donation to a charity for someone who is unable to attend).

Information may be collected from a member of the public in order to answer questions or to provide information about our goods and services. Information will only be used to provide the information requested. On some occasions, we must disclose personal information to a third party in order to fulfill the details requested (e.g., someone might call for a quotation for us to provide funeral services but may also ask us to confirm with a cemetery that there is room in an existing family plot).

Information Collected From Outside Employees and Suppliers
For people who are contracted to do work for us (e.g., funeral coach provider, occasional part-time staff), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out pay cheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes may include business & home addresses and telephone numbers.

It is rare for us to collect such information without prior consent, however, on occasion, we may gather this information to establish an initial contact or for emergency situations (e.g. grave opening required on short notice).

Information Collected Related To Cause of Death
The funeral home normally receives a document that outlines the Medical Cause of Death. We as a funeral home are not permitted by law to disclose or provide this information to any party (including the funeral home informant/contractee) except where required to obtain Coroner's Warrants and/or register the death with the Province of Ontario as legally required. The Medical Certificate can not be copied by us nor do we retain a record of the cause of death. The only information recorded on file in our office from this form is the legal date and place of death and the name and address of the signing Medical Practitioner.

Collection of Personal Information: Secondary & Related Purposes
Like most organizations, we also collect, use and disclose information for purposes related to, or secondary to, our primary purposes. The most common examples of our related and secondary purposes are as follows:

What Information Do We Not Release To The General Public?
We will not release names, addresses or phone numbers of any of our contacts to members of the general public. Our rationale is that it is not possible for us to verify if this personal information is listed in public directories or has been specified as unlisted. We are also unable to verify the nature for someone wanting this information. We suggest that any letters or cards expressing condolences be sent to us and we will forward them to the contact person. Any requests for telephone contact will be forwarded to the contact person on behalf of the party inquiring. It will be at the sole discretion of the contact person if they wish to make contact. We will not release any names, addresses or phone numbers to the general public even if requested by the contact person. It is difficult to maintain records of who has granted permission and who has not, thus resulting in a consistent policy that is to be followed by all staff members.

Effective immediately, our office will not release Funeral Directors Proofs of Death directly to lawyers offices, insurance companies or financial institutions who have contacted our office by telephone. We are unable to accurately determine if this request is legitimate or if they are authorized to request this document. To further rationalize this position, we release multiple copies of these certificates to families for the sole purpose of estate settlement. It is the duty of the executor or administrator of the estate to delivery these copies as required. An exception may be made if the executor/administrator are not local and they no longer have or are able to locate a copy.

How Long Are Records Maintained?
Clients or other individuals we deal with may have questions about the services they received. We also provide ongoing services for many of our clients over a period of years for which previous records are important. We retain our client information for an indefinite period of time. Currently, we have on file all records dating back to 1936, when the funeral home was first established.

Funeral homes are required by law to maintain these records indefinitely, or to ensure that any records are properly archived should the funeral home no longer be able to retain these records (i.e. funeral home closure). The funeral home may also discontinue this service related to events beyond their control (i.e. theft, fire, natural disasters).

Electronic Hardware

Denial of Access
If there is a problem with allowing access, we may ask you to put your request in writing. If we still cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

Error in Information
If you believe there is a mistake in the information held on file, you have the right to ask for it to be corrected. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and where possible, notify anyone to whom we sent this information (e.g., if an error contained in a memorial folder produced for funeral attendees it would be unreasonable to expect this to be corrected after the funeral has concluded). If the error contained in the information was not our fault and documents have been filed with legal/government offices, a fee may be required by the third party office in order to make a correction (e.g., a $40.00 fee applies for changes made to the Provincial Statement of Death once it has been officially registered with the Province).

What If I Have A Question Or A Concern?
If you have further questions or concerns, please contact our Information Officer:
Stuart Clark
McClelland & Slessor Funeral Home
152 Bradford Street
Barrie, ON L4N 3B5
Voice: (705) 722-6656
Fax: (705) 722-8376
E-Mail: pipeda@funeralhome.on.ca

Stuart will attempt to answer any questions or concerns you might have.

Submitting a Formal Complaint
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

Disclaimer
This policy is made under the Personal Information Protection and Electronic Documents Act. It is a new and complex Act that leaves much room for interpretation. The PIPEDA provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. Since this Act is new and many areas are very broad and nonspecified, it may be required from time to time to adjust our privacy policy accordingly.

A copy of this policy is available without cost or obligation.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts in a manner similar to an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

112 Kent Street
Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Toll-free: (800)-282-1376
Fax: (613) 947-6850
TTY: (613) 992-9190
www.privcom.gc.ca

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