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Support for People with Disabilities
(formerly Citizen Advocacy) trading as ABLE2
Charitable Registration Number 13036 2817 RR0001

312 Parkdale Avenue,
Ottawa K1Y 4X5

Telephone: 613-761-9522

Toll Free: 1-866-222-2138

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Land Acknowledgement
Privacy Policy
External Feedback and Complaints Resolution Policy & Procedure

Privacy Policy

ABLE2 is committed to maintaining the accuracy, confidentiality, and security of your personal information. As part of this commitment, our privacy policy governs our actions as they relate to the collection, use and disclosure of Personal Information (PI). ABLE2’s privacy policy follows the best practice guidelines set out in Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) as well as any provincial legislation where applicable.

For the purposes of this policy ABLE2 defines PI as any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

age, name, ID numbers, income, ethnic origin, or blood type;
opinions, evaluations, comments, social status, or disciplinary actions; and
employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).

Introduction

ABLE2 is responsible for maintaining and protecting the PI under our control. We have designated an individual who is responsible for the compliance of our privacy policy.

Identifying Purpose: Why We Collect Personal Information

ABLE2’s goal is to best assist individuals and their families use our services. We collect, use and disclose PI based on the nature of the relationship you have with ABLE2.

In general, we collect information that will assist us to provide you with the information and services you have requested.

The purpose for which we collect PI will always be explained to you before or at the time the information is collected. In addition, we will let you know what we intend to use the information for, and how it maybe disclosed to others.

In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address and payment information are provided as part of fee-for-service payments, purchase of event tickets and donations.

Consent

Knowledge and consent are required for the collection, use or disclosure of PI except where required or permitted by law.

ABLE2 will always ask for your consent before or when it collects, uses, or discloses your personal information, except where appropriate.

Consent can be provided to us through written authorization, verbally, electronically, or through your authorized representative, such as your guardian or lawyer. Giving us your written consent may also be through completing and signing one of our applications. We will always try to use clear, understandable language when asking you for your permission to collect your PI.

Other than in certain legal circumstances, you may withdraw your consent to our collection, use, or disclosure of your personal information at any time by contacting our Privacy Officer at ABLE2. However, your decision to withhold certain information may impact the information and services that we can provide to you.

Limiting Collection of Personal Information

The PI collected by ABLE2 will be limited to what is necessary to fulfill the purposes it is collected for.

With your consent ABLE2 may collect PI from you:

In person;
Over the telephone;
By mail correspondence;
By email;
Facsimile; and
The Internet and/or other social media platforms used by ABLE2.

Limiting Use, Disclosure, Retention of Personal Information

Your PI may only be used or disclosed for the purpose in which it was collected unless you have otherwise consented, or when it is required or permitted by law. Your PI will be retained only for the period required to fulfill the purpose for which it was collected or as may be required by law.

We will seek your consent if we need to use the information for purposes other than those outlined in this policy. We will only disclose your information to third parties where you have given consent, or where it is required by law. In addition, we will also seek your consent for the method of transmission of your information.

Access to your information will be limited to only those individuals authorized to view, hold, or handle your information for their current job duties. Your information will be kept in the strictest of confidence and will not be shared with unauthorized persons.

When ABLE2 no longer requires your PI, it will be destroyed or made anonymous. Some information, however, may need to be kept indefinitely or archived.

Accuracy

ABLE2 will make every reasonable effort to keep your PI as complete and up-to-date as is necessary for the purposes for which it is to be used.

We encourage you to inform our Privacy Officer at ABLE2 of any relevant changes in information we retain about you, such as a change in address, telephone number etc. We will correct any errors in the information we hold upon notification to us of the error.

Safeguards

Personal information will be protected by security safeguards appropriate for the sensitivity of the information.

ABLE2 will take all reasonable precautions to protect your PI from any loss, theft, unauthorize use, access, disclosure or modification.

Personal information at ABLE2 is maintained in a combination of paper and electronic files and is protected regardless of the format. Filing cabinets are locked and access to the offices is restricted. Our computer systems are password-secured and are constructed in such a way that only authorized individuals can access secure files and databases.

ABLE2 uses qualified third-party payment services and the organization’s website is certified as secure.

All employees at ABLE2 are required to keep your PI confidential and have signed an agreement that verifies their understanding and responsibilities related to the confidentiality of PI.

Openness

ABLE2 will provide the Privacy Policy available on the website and in paper format.

Changes made to this policy will be posted to our website. Any such changes will be approved by the ABLE2’s Board of Directors.

If you have any additional questions or concerns about ABLE2’s privacy policies and practices relating to the management of personal information, we invite you to contact us by phone, mail, email, or through our website, and we will address your concerns to the best of our ability.

Individual Access

Upon the receipt of a written request and proof of entitlement, ABLE2 will give you access to the PI we retain about you within a reasonable time.

You have the right to know how we collected your PI, how we are using it and to whom it may be disclosed. Additionally, you may review your PI for accuracy and completeness and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you where other individuals are referenced or if there is a legal or security restriction.

Providing Recourse

ABLE2 encourages you to contact our Privacy Officer if you have any questions or enquires with respect to our privacy policy or practices. We will investigate and respond to any of your concerns related to our handling of your PI.

You may contact the Privacy Officer by:

Phone: 613-761-9522
TTY: 613-725-6175
Fax: 613-761-9525
Email: info@able2.org
Mail: ABLE2, 1 Community Place, 312 Parkdale Ave, Ottawa, ON, Canada K1Y 4X5

Board Approved: June 24, 2020

External Feedback and Complaints Resolution Policy & Procedure

Purpose

The purpose of this policy and procedure is to set out how anyone in receipt of services from ABLE2: Support for People with Disabilities (ABLE2) can provide feedback and/or make a complaint about our services and the process for complaint resolution.

Scope

It applies to anyone who receives service(s) from ABLE2.

Definitions

Compliment - an expression of praise, encouragement, or gratitude about an individual staff member, a team, or a service.

Complainant- a person who makes a complaint or has made a complaint on their behalf.

Complaint - an expression of dissatisfaction made to, or about an individual, team or staff as it relates to the provision of ABLE2’s services.

Policy

Compliments, complaints, and other feedback provides ABLE2 with valuable information. It is an opportunity to improve our services.

Feedback is taken seriously by ABLE2. ABLE2’s complaints management process and resolution procedures ensure that people can easily provide feedback and/or make a complaint and that the complaint is dealt with fairly and quickly.

ABLE2 makes information available to all about how to make a complaint and keeps records of complaints received and their resolution.

Procedure

General

ABLE2’s staff promotes the use of best practices, continuous improvement and an open and respectful culture that encourages and supports participants to make complaints without consequence.

Staff must provide participants (people using our services) with information about ABLE2’s feedback and complaints resolution process when they first access ABLE2’s services, providing participants with an ABLE2 brochure outlining the Feedback and Complaints Policy and Process. Throughout service delivery, staff must remind participants of their right to make a confidential complaint without fear that it will impact their service. Any participants wishing to submit feedback, or a complaint, must be provided with this information.

To ensure participants understand their right to make a complaint and how to make a complaint, staff

must provide information to them in ways that suit their individual communication needs. This could include but is not limited to the provision of:

• The material in larger print formats
• The process outlined verbally
• The process outlined via sign language or other alternative communication forms
• The process in either of the official languages whichever is preferred by the individual

The Executive Director, or Executive Assistant, will track and review feedback and complaints to identify ongoing issues using the ABLE2 Feedback and Complaint Tracking System. Feedback and complaints will be reported to the management team as part of their regular meetings. In addition, feedback and complaints will be part of the Executive Director’s regular reports to ABLE2’s Board of Directors.

Feedback

Providing feedback to ABLE2 is voluntary.

Feedback can be provided at anytime, in anyway, by any stakeholder, through:

• A staff member.
• Email, mail, or phone.
• Satisfaction surveys.
• On ABLE2’s website or social media platforms.

Where feedback is provided verbally, the receiving staff member will document it repeat it back to the individual to ensure accuracy and ask the individual to provide consent to share the feedback. Once completed the documented feedback would be sent to the Executive Director, or Executive Assistant, for input in the ABLE2 Feedback and Complaint Tracking System. In addition, all written feedback (emails, surveys, social media or through the website) will be recorded in the ABLE2 Feedback and Complaint Tracking System. Feedback and Complaints will be held in the database for 18 months, at which time the documentation will be deleted. All information in the database will be held in confidence as outlined under the Privacy and Information section of this policy and process.

Complaints

Participants can make a complaint about any aspects of ABLE2’s services, including breaches of policy and procedures, or Codes of Conduct. It should be noted that the complaints process is not for issues that arise about other recipients of ABLE2’s services. If an issue should arise within a meeting or event held by ABLE2 related to a participant, the complaint will be received and processed as per the process laid out below.

If a person has a complaint, ABLE2 encourages them to first speak directly to the staff member to try to resolve the matter.

When speaking with staff about an issue or complaint, ABLE2 expects that staff will:

• Listen openly to the complaint raised by the complainant.
• Ask the complainant what outcome they are seeking.
• Inform the complainant of the full complaint process.

• Be empathetic towards the person and action all commitments made.
• Action situations that pose an immediate threat or danger or require a specialize response. This would include but is not limited to:

✓ If there are concerns that an individual would harm themselves or someone else.
✓ If there is a concern that a child/ren are in immediate danger and may need protection.
✓ A serious/life threatening medical situation arises.

However, ABLE2 recognizes that addressing the complaint directly to the staff may not always be possible so participants can make a complaint:

• In writing directly to ABLE2, 312 Parkdale Ave, ON, K1Y 4X5.
• By email to info@able2.org.
• By phone: 613-761-9522 ext: 226.

*Please note: Receipt of the complaint and confirming of the process will be provided within two working days of the receipt of the complaint. As well, complaints can be made on behalf of a participant by a third party if needed.

If the complaint cannot be resolved by the staff involved, within five working days, it must be referred to the respective program manager. The Manager will immediately contact the complainant to set up a meeting with them to resolve the complaint. If the complaint cannot be resolved within five working days, the complaint is forwarded to the Executive Director for resolution.

The Executive will immediately contact the complainant to set up a meeting with them to resolve the complaint. If the complaint cannot be resolved within five working days, the complaint is forwarded to the Board Chair for resolution.

The Board Chair will immediately contact the complainant to set up a meeting with them to resolve the complaint. If the complaint cannot be resolved within five working days, ABLE2 will bring in an outside consultant to investigate the complaint and work with the parties to resolve the issue.

Throughout the process, it is expected that all related discussions, and commitments will be documented accurately and shared with the complainant. When a resolution has been reached it must be documented in a letter or communication format that the individual is comfortable with and tracked in the ABLE2 Feedback and Complaint Tracking System.

In addition, the complainant should be told at the onset of the complaint process and regularly thereafter that at any and/or all points in the complaint resolution process they may ask for a supporter or advocate to assist them.

Reporting to the Board

A report on the number and nature of the feedback and complaints received by ABLE2 will be presented to the Board on an annual basis.

Privacy and Information Management

All personal information collected by ABLE2 to manage feedback or complaints will be kept confidential and will only be accessible to the Executive Director or Executive Assistant. Disclosure can only be made if required by law or if not disclosing is likely to place the health, safety, or wellbeing of any person at risk. ABLE2 staff must take all reasonable steps to notify the complainant before deciding not to keep personal information confidential.

Complaints will be registered and tracked in the ABLE2 Complaint Tracking System which will consist of:

• Details of the feedback or complaint.
• Any action taken to resolve the complaint.
• The outcome of the action taken.
• All relevant notes/documentation.

All information regarding feedback and complaints will be treated as private and confidential and will only be released where:

• The law requires or a court had ordered the release of certain information.
• Where the individual, families or caregivers have given their consent.

Please note: For any staff of ABLE2 that may have a complaint please refer to the process outlined in the
ABLE2 Human Resource Handbook Section 14.