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 telephone 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 protected by privacy legislation.
Who We Are?
Our organization, Robert J. Carson Funeral Directors Limited, Robert J. Carson Funeral Director (Midland) Limited (corporation names hereafter known as "Carson”, is in the business of providing funeral services to our client families (hereafter known as, "clients"). We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include part-time funeral directors, hostesses and funeral assistants, clergy, soloists, hairdressers, coroners, cemetery personnel, florists, and so forth. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
We Collect Personal Information:
Like all funeral homes, we collect, use and disclose personal information in order to serve our clients. The personal information which we collect is needed to:
- Identify the purchasers and beneficiaries of prearranged/prepaid and at need arrangements;
- Provide our services (e.g., arranging for cemetery plots, burials, services, cremations, transportation, forwarding remains, notices in newspapers, etc.);
- Comply with legislative and regulatory requirements (registering deaths under Vital Statistics Act of 1990, providing families with Proof of Death Certifications, etc.).
Examples of the type of personal information we collect for these purposes include the following: last, middle and first names, gender, social insurance number (optional), date of death, city, province and date of birth, age at time of death, place of death with address, name and address of physician who pronounced death, marital or relationship status, last name of the deceased's spouse or partner, primary work done most of living life, type of business or industry that the deceased worked in for most of his/her life, deceased's usual residence, father's place of birth, father's name, mother's place of birth, mother's maiden name, the name, address and relationship to the deceased of the informant (person signing the statement of death). Based on Health and Safety regulations we are privy to and do see medical information from the signed medical certificates which are submitted to the Ontario government along with the Statement of Death. This information is received without our client's consent but is required by law to complete the registration of the death.
Our primary purpose for collecting personal information from contract staff (e.g., part-time Funeral Directors, part-time drivers, parking attendants, hairdressers, soloists, etc.), is to contact them in the future for new assignments and for necessary work-related communications (e.g., sending out cheques, other funeral correspondences). Examples of the type of personal information are as follows: name, home contact information, drivers license (includes age, gender, and some health restrictions), funeral directors license (if applicable), health conditions, occupation/profession, work hours, transaction history and involvement with Carson. The collection of this information is based on an implied consent, as it is a requirement by the funeral home for operational, insurance and health and safety reasons.
When we investigate, audit or assess a person on behalf of someone else (e.g., legal investigation, financial and professional audits, medical assessment), our primary purposes for collecting personal information are as follows: based on legal requirements, to investigate a breach of law or to provide emergency information, to ensure compliance with professional rules and guidelines. These types of investigations/assessments can cover both clients and contract staff and would involve the various personal information collected and listed above as well as publicly available information specified in regulation (e.g., telephone directories, professional directories, court or tribunal records and information provided by the individual to newspapers, magazines and books.)
Related and Secondary 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:
- Invoicing and Collection - to invoice clients for goods/services that are not paid for at the time and to collect unpaid accounts. Additional personal information collected for this purpose may include employer name and credit checks
- Recall Visits - to advise clients that their product or service should be reviewed (e.g., preneed clients may be informed of legislative changes affecting their prepaid services or advise them of new product or services offered).
- New Goods and Services, Newsletters and Informational Bulletins - to advise clients and others of new goods and services as well as bereavement newsletters and informative bulletins.
- Quality Control and Risk Management - our organization reviews client files for the purpose of ensuring that we provide high quality services, including assessment of staff performance. In addition, external consultants (e.g., auditors, lawyers, practice consultants) may, on our behalf, do audits and continuing quality improvement reviews of our organization, including reviewing client files and interviewing our staff.
- External Regulations - our organization and its professional staff are regulated by the Board of Funeral Services that may inspect our records and interview our staff as part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients or other individuals to support the concern. Also, various government agencies have the authority to review our files and interview our staff as part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
- Third Party Billing - the cost of some goods/services provided by our organization to clients is paid by third parties (e.g., private insurance, government funding). These third party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
- Responding to Questions - clients or other individuals with whom we work with may have questions about our goods/services after they have been received. We also provide ongoing services for many of our clients over a period of months or years for which previous records are helpful. We retain our client information in a summarized, permanent form to enable us to respond to those questions and provide these services. Other than our permanent records, we destroy all information every ten years (as set by legislation for Funeral Services) at the first reasonable opportunity.
Our Privacy General Consent Form you may choose not to be part of some of these related or secondary purposes (e.g., by declining to receive newsletters and other information). Due to external regulations, some of these related or secondary purposes cannot be declined and do not require your consent.
Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information is either under supervision in a restricted area or secured in a restricted area.
- Electronic hardware is either under supervision or secured in restricted areas at all times. In addition, passwords are used to log on to each computer. All of our cell phones are digital, which signals are more difficult to intercept.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted through a direct line or is anonymized or encrypted.
- External consultants and agencies with access to personal information must enter into privacy agreements with us.
Retention and Destruction of Personal Information
We need to retain personal information for some time to ensure that we can answer any questions you or your family/executors (estate trustees) might have about the services provided and for our own accountability to external regulatory bodies (Board of Funeral Services). Any clients, “Atneed Paper Folders” containing personal information are kept for a minimum of 10 years and are then systematically shredded under the control of our own personnel. Any clients, “Preneed/Prearrangement Paper Folders” are kept until the need for services at which time it becomes an, "Atneed Folder" which then follows the "Atneed" disposition procedures. We do maintain permanent information that includes personal information of the deceased. This is maintained either electronically, or on microfiche, or on a specialized card or book system. This is required to fulfill certain business requests regarding geneology, cemetery burial locations and additional Proof of Death Certifications. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, at your request, we will remove such contact information promptly. We keep personal information received from individuals, who are not our clients, in response to our general correspondences, newsletters, seminars and other activities for approximately 12 months after the event has occurred.
We destroy paper information containing personal information by shredding and electronic information by deleting it. When the hardware is discarded, we ensure that the hard drive is physically destroyed.
You Can Look at your Information
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you as well as help you clarify any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
If there is a problem, we may ask you to put your request in writing. If we 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.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation to prove that our files are incorrect. Where we agree that we made a mistake, we will make the correction and notify anyone to whom this information was sent. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
Do You Have a Concern?
Our Information Officer can be reached at:
Carson Funeral Homes
54 Coldwater Street East, P.O. Box 37
Orillia, Ontario, L3V 6H9
To address any questions or concerns you might have, you can always contact us through email at email@example.com.
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.
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 as an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
Information and Privacy Commisioner
112 Kent Street,
Ottawa, Ontario K1A 1H3