Confidentiality Policy

WOODSWORTH HOUSING CO-OPERATIVE

CONFIDENTIALITY POLICY

Presented and approved at GMM on April 1, 1993

1. Basic Principles

The intention of this policy is to create a culture and a climate which supports maintaining confidentiality and makes it explicitly unacceptable behaviour to violate a member’s right to confidentiality.

This climate is fostered by such things as:

Board and committees discouraging anyone from presenting them with confidential information which they do not need to possess to function.

Staff making a point of offering members privacy for discussions in the office.

Members of the Board and sensitive committees shall acknowledge that they have received a copy of the confidentiality policy and that they understand their obligation to protect members’ privacy and confidentiality.

The Board and Committee members should not discuss with any other person the details of confidential matters.

2. Content of a member’s file

2.1 There will be a file for each individual member, not just household files.

2.2 The minimum that each file will contain will be the signed Member Application, Occupancy Agreement, and some tracking of where in the Co-op the member has lived and when. In addition, information on grievance and arrears would be included, as well as copies of correspondence to and from the member.

2.3 There will be nothing in the file that the member has not seen.

2.4 Information about grievances or arrears which is more than 5 years old, unless it is part of an ongoing pattern, should be discarded. Staff will consult with the Arrears Committee and the Grievance Committee regarding what should be discarded.

2.5 Content of the Unit (also called the Maintenance) file will be on the computer.

2.6 Member files are kept in the office in locked filing cabinets.

3. Member access to his/her own member file

3.1 It was agreed that members have the right to look at their own files. This may be done by making an appointment with the Co-ordinator to view the file during office hours.

 3.2 The Co-ordinator must be present while the member is viewing the file in order to answer any questions and to make sure that nothing is removed from the file.

3.3 The file itself may not be removed from the office, although members have the right to make photocopies of anything in the file.

4. Other access to the member file

4.1 No member, even if part of an elected committee, has the right to access any other member’s file, except where specifically directed by the Board.

4.2 If the Board or a committee needs information from a file, that information will be obtained through the Co-ordinator or Admin. Assistant. Maintenance information may also be obtained through the Maintenance workers in the absence of the Co-ordinator.

5. Function of Committees to maintain confidentiality

(e.g., Board, Membership, Arrears, Grievance)

 5.1 The Board

The Board will implement a mechanism for discussing issues at Board level without knowing the names of the people involved (e.g. President distribute copies of letters with names blacked out).

5.2 The Arrears Committee

 The Arrears Committee does not need to know who is on subsidy, except when discussing a particular Arrears case. Duplicate lists of those in Arrears should be destroyed as soon as possible after the meeting.

5.3 Grievance Committee

Policy states that “All particulars and minutes of meetings shall be kept strictly confidential and shall be disclosed only to the Board of Directors at their request. At the end of each year, and after consultation with the Committee, the Secretary shall precis and record the premise and conclusion of each grievance, to be kept in the files of the Grievance Committee and the members involved. This is to facilitate the resolution of future complaints that might involve any of the parties. All related testimony, documents and notes will be destroyed.

All files of Grievance Committee will be kept in the office, except for active files which may be temporarily removed from the office by a member of the Grievance Committee while a complaint is being worked on.

The Board does not generally need to know the details of particular grievances unless Board action is required.

5.4 General

The Board (and other Committees) should be very conscious of procedures which ensure that positions taken by particular Board or committee members on an issue are not discussed outside the meeting.

6. When the Member breaches his/her own confidentiality

(e.g., a member appeal)

If a member chooses to reveal confidential information about her or himself in order to appeal a decision of the Board or Committee , he must understand that this means that the Board (or other committee being appealed against) has the right to reveal any information upon which they acted, even if it is information that would otherwise be kept confidential.

7. Destruction of files

Each member of committees and the Board who deal with confidential material is expected to ensure that they dispose of confidential material in an appropriate manner. The office has a shredding machine, which may be used to shred documents. No copies of confidential material will be left lying around, either in Committee boxes or in the Board room where members might see them.

 At the end of a member’s term of office on the Board or a Committee, it is the member’s responsibility to make sure that confidential information obtained during the term is properly disposed of.

8. Process for implementation

The following implementation procedures will be developed by appropriate committees and staff.

8.1 Change filing system from Household files to Member files.

8.2 Procedures for removing old Arrears information.

8.3 Procedures for removing old Grievance information.

8.4 Process for regular reporting of Member in Good Standing Status to Membership Committee. [Section 5.2 re: definition of member in good standing was struck from approved version.]

Consolidated up to April 2010 and adopted September 30, 2010.