Privacy policy.
Aspire Community & Developmental Services Privacy Policy
Aspire Community & Developmental Services ("Aspire Services") has established this Privacy Policy to explain how it protects and manages the personal information that it collects from you (the client) online and offline. This privacy policy may be updated at any time, and a copy of the updated policy will be posted on the Aspire Community & Developmental Services website.
Privacy Officer
The privacy officer of Aspire Community & Developmental Services is the Founder, Becky Kurtz. The responsibility of the privacy officer is to respond to inquiries and complaints; establish and maintain confidence for client’s personal information that is shared for programs and services; assist in updating information that is published on the website; understand the legislation; and apply pertinent changes to the Aspire Community & Developmental Services Privacy Policy. Contact information is: phone: 705-790-2169 or email: info@aspireservices.ca
Why is this Personal Information Collected (Business Purposes)?
Aspire Community & Developmental Services collects and uses personal information for the following Identified Purposes:
To understand and fulfill client needs or requests for Aspire Community & Developmental Services programs and personalized coaching;
To develop private client accounts for our clients, provide access to our website and to maintain the integrity of the website;
To provide services and coaching for our clients, including goals, strategies, schedules, materials and transmitting information
To confirm the Identity of specific clients
To communicate with clients and site visitors, when necessary, and to inform clients of upgrades, as well as marketing offers for other programs and coaching available from Aspire Community & Developmental Services
To bill accounts and maintain payment records; and to collect payment, or unpaid accounts if necessary;
To comply with any applicable law, regulation, legal process or government request; or to bring legal action if the company is threatened.
To respond to a legitimate claim, or to address our reasonable belief, that you are violating the rights of any of the agreements or policies that govern your use of the Aspire Community & Developmental Services site or any product or service;
To protect the services, products or rights of Aspire Community & Developmental Services, including but not limited to the security or integrity of the Aspire Community & Developmental Services site;
To identify and resolve technical problems concerning the Aspire Community & Developmental Services site, products and services.
To analyse client activity in aggregate form (i.e., not individually attributable to you) to understand visitor and client preferences via cookies or pixels for the website and/or social media, for its business analysis, operational, marketing and other promotional purposes.
When you visit the Aspire Community & Developmental Services web site, a cookie may be placed on your computer or the cookie may be read if you have visited the Aspire Community & Developmental Services site previously. If you choose to not have your browser accept cookies or pixels from the Aspire Community & Developmental Services web site, or social media sites, you may not be able to view all the text on the screens, or to experience a personalised visit, or to subscribe to certain service and product offerings on the Aspire Community & Developmental Services site.
Consent for Collection, Use and Disclosure of Information
Your use of the Aspire Community & Developmental Services site and/or your registration for programs and services constitute your consent to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Aspire Community & Developmental Services site or Aspire Community & Developmental Services programs and services.
Consent is obtained from each client by giving them a service agreement to be signed that explains the use of material and states confidential information will remain with Aspire Community & Developmental Services unless written permission is granted to share with a third party. If a third party is inquiring, a separate Consent to Release Information form must be filled out by the participant, caregiver and privacy officer of Aspire Community & Developmental Services disclosing if information is to be collected, disclosed or both. This document will be valid for 3 months from date of signing, in which an additional form will need to be filled out. This document will also be filled out for participants over the age of 18 to allow communication between Aspire Community & Developmental Services and parents/caregivers to collect and disclose information regarding programming and personal information.
Consent may be withdrawn at any time by advising the Privacy Officer that the client is withdrawing consent (e.g. by unsubscribing from lists, or requesting that information stopped being shared with a third party).
Limiting the Collection of Personal Information
Aspire Community & Developmental Services limits its collection of personal information to only that information which is necessary for the Identified Purposes. Aspire Community & Developmental Services does not direct its site to, nor does it knowingly collect any personal information from children under the age of thirteen. Personal information is only collected from people under the age of 13 if they are agreeing to participate in a program or coaching from Aspire Community & Developmental Services and only information which is necessary is collected.
a) What kind of information does Aspire Community & Developmental Services collect?
For clients: Aspire Community & Developmental Services collects information to fulfill the business purposes outlined above, at the time of your registration, certain “personal information” (information that personally identifies you) including but not limited to the following:
Contact information (home information, including name, email addresses, home address, phone numbers)
Age categories
Any diagnosis that have been identified with the participant to help with program design, needs and appropriate strategies. Aspire Community & Developmental Services will rely on parent/caregiver/participant to provide accurate and complete information of diagnosis and personal goals.
Hobbies, interests, school supports, personal goals, safety risk are collected to help with designing of programs and coaching services and to ensure safety of all parties
For general visitors to the Aspire Community & Developmental Services site or social media, computer hardware or software information through cookies or pixels (e.g., IP address, operating system, browser type, domain name, URL, access times, and referring web site addresses).
Information may be made available to the following third parties, all of which have privacy policies in place. They include:
The Aspire Community & Developmental Services accountant and bookkeeper (financial information for the purposes of tax planning and reimbursement)
Square Software for credit invoices (online)
Email Marketing services (currently Mail Chimp)
Web firms which support the Aspire Community & Developmental Services website
Virtual Assistants (from time to time to past due collections and miscellaneous administrative activities)
5. Limiting Use, Disclosure and Retention
Clients and non-clients who sign-on to receive email communications (without necessarily becoming clients of Aspire Community & Developmental Services), provide their name and email address. This information is stored in our Mail Chimp account and the Aspire Community & Developmental Services website.
6. How will this information be processed and stored?
Your information may be stored and processed in the Canada or the United States, or in any other country in which Aspire Community & Developmental Services or its affiliates, subsidiaries, suppliers or agents maintain facilities. By using this web site, you consent to any such possible transfer of information outside of your country.
Electronic files and information is primarily managed internally and is stored on computers belonging to Aspire Community & Developmental Services employees or contractors.
Communications regarding the program are sent by the email address provided to Aspire Community & Developmental Services.
If Aspire Community & Developmental Services hires other companies to provide some products or services on our behalf, we will only provide those companies or individuals the personal information they need for the Identified Purposes within their scope of work, and we will limit their rights to use and further disclose your personal information as appropriate in the course of their work for us.
Information that Aspire Community & Developmental Services gathers is retained in web-based software associated with the Aspire Community & Developmental Services website, paper copies of personal information are stored in a client specific file in a locked cabinet, in a Mail Chimp account for email services, Square software to manage finances and in an excel-based database or reports.
Information is also stored on password protected computers owned by individuals who are participants in the company or are contracted to the company, to provide support. Hard copies of reports may be retained in a locked filing cabinet in the Aspire Community & Developmental Services (home-based) office and on the Aspire Community & Developmental Services Google business account (in Google docs). Backups of Aspire Community & Developmental Services computers are made on a continuous basis to USB drives and external hard drives (not connected to internet).
7. Will this information be disclosed?
Aspire Community & Developmental Services does not sell or rent your personal information to anyone. Aspire Community & Developmental Services does not disclose your personal information to anyone who falls outside the umbrella of the Identified purposes, except in limited situations for example in the following cases:
Aspire Community & Developmental Services has a legal obligation to report any child protection issues to Simcoe Muskoka Family Connexions
A third party that has been granted written consent to collect or disclose personal information for one or more Identified Purposes (listed above)
To Aspire Community & Developmental Services employees and service providers who provide services to Aspire Community & Developmental Services™;
If Aspire Community & Developmental Services has reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with Aspire Community & Developmental Services's rights or property, other users of the Aspire Community & Developmental Services web site, products or services, or anyone else that could be harmed by such activities; and
To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
8. How long will the information be retained?
Aspire Community & Developmental Services client information will be used in relation to the identified purposes below. When service with Aspire Community & Developmental Services has been terminated, either by choosing to withdraw from a program, completion of a program or completion of individual coaching, your personal information will be kept in Aspire Community & Developmental Services private archives. Your information will then be used only as necessary for tax reasons or to prove that Aspire Community & Developmental Services is compliant with any applicable law.
When a person has unsubscribed from the Aspire Community & Developmental Services email list, their email address is maintained in our 3rd party database under the unsubscribed category (and in our website database as an unsubscribed email address) to ensure adherence to legal statutes.
Financial records are retained according to CRA guidelines.
9. How will information be disposed of?
Aspire Community & Developmental Services account records are maintained to satisfy CRA requirements, and then will be shredded.
6. Ensure the Accuracy of Personal Information
The Chief Privacy Officer is responsible to ensure the information collected is as accurate as can be at the time of collection. Aspire Community & Developmental Services ensures the accuracy of personal information by completing the pre-assessment forms with the parent/caregivers and participants (if possible) and relying on accurate information to be provided. Aspire Community & Developmental Services will use reasonable efforts to keep client personal information accurate for the Identified Purposes, and to minimize the possibility of making inappropriate client decisions based on such information.
Clients are responsible for informing Aspire Community & Developmental Services about changes to their personal information. They can do this by sending an email to info@aspireservices.ca or using the contact form on the website. Aspire Community & Developmental Services will use new or updated personal information it receives from clients to update its own records.
7. How will the information be safeguarded?
Electronic databases, servers and individual computers are password protected. All computer hardware has firewall and virus protection in place and data is backed up using USB drives.
The filing cabinet housing personal information in the Aspire Community & Developmental Services office is locked when not in use. Access is only granted on a need-to-know basis to those individuals who are under contract to Aspire Community & Developmental Services to provide specific services. No unauthorized parties are able to access this information.
8. Openness, and
9. Individual Access
Requests for access, updating or withdrawal of information
Aspire Community & Developmental Services will afford clients and vendors a reasonable opportunity to review the personal information in their file. Please direct any requests for access to your information in writing to Becky Kurtz, info@aspireservices.ca or by mail at Suite Success at ESS Direct, Suite 5, 411 Huronia Road, Barrie, ON L4N 9B3.
Please allow 14 days for a response to your request.
Your information will be provided to you as quickly as possible (but no later than 30 days from the date of your request), as long as that information may be legally copied to the person making the inquiry.
If Aspire Community & Developmental Services is not able to provide access to some aspect of a client’s personal information, it will provide reasons for denying access such as (see legal restrictions and examples below):
That the information relates to a breach of an agreement or a contravention of law
Its disclosure could reasonably be expected to threaten the life or security of another individual.
In terms of mandatory exceptions, organizations must refuse an individual access to personal information:
If it would reveal personal information about another individual unless there is consent or a life-threatening situation. This is unlikely since records are usually individual but could be required in the event of involvement in a law suit; or
If an individual requests that he or she be informed of information disclosed to a government institution in certain specified cases, or for access to the information itself, and the government institution objects to the institution complying with the access request. In such cases, Aspire Community & Developmental Services must refuse the request and notify the Privacy Commissioner of Canada. As well, Aspire Community & Developmental Services cannot inform the individual of the disclosure to the government institution, that the institution was notified of the request, or that the Privacy Commissioner of Canada was notified of the refusal.
In terms of discretionary exceptions, Aspire Community & Developmental Services may refuse access to personal information if the information:
To develop private client accounts for our cli Is protected by solicitor-client privilege
Would reveal confidential commercial information, although if this information can be redacted, Aspire Community & Developmental Services will release the remaining information
Would reasonably be expected to harm an individual's life or security; although if this information can be redacted, Aspire Community & Developmental Services will release the remaining information
Was collected without the individual's knowledge or consent to ensure its availability and accuracy, and the collection was required to investigate a breach of an agreement or violation of a federal or provincial law (the Privacy Commissioner of Canada must be notified)
Was generated in the course of a formal dispute resolution process, or
Was created for the purpose of making a disclosure under the Public Servants Disclosure Protection Act or a related investigation.
10. Challenging Compliance: Recourse
Complaints about the organization
Please direct any complaints about the Aspire Community & Developmental Services organization in writing to Becky Kurtz, info@aspireservices.ca
Please allow 14 days for a response to your request.
To find resolution to a complaint, first approach the Aspire Community & Developmental Services privacy officer. Should that prove unsatisfactory, individuals can contact the Privacy Commissioner of Canada:
Daniel Therrien, 112 Kent St., Ottawa, ON K1A 1H3.
1-800-282-1376
1-613-947-6850 Fax
Clients have the right to request that information is removed that is no longer accurate or complete and information be amended as appropriate, by contacting Becky Kurtz as described above, who will promptly correct such personal information.
Any challenges an individual wishes to make to the organization’s compliance with the above principles in this policy should be addressed to Becky Kurtz, the Chief Privacy Officer at the above contacts, in writing.