Fairview Mennonite Homes
515 Langs Drive
Cambridge, ON N3H 5E4
DEPARTMENT:
Board of Directors
REFERENCE NO FMH BP-10
SUBJECT: Confidentiality
Date of Approval: Dec. 2005
Approved by: Board of Directors
Revised: Dec 2016
Reviewed: Dec 2016
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POLICY
It is the policy of Fairview Mennonite Homes to maintain its reputation of integrity in the community, as
well as with its affiliated organizations. Its reputation is in turn dependent upon the integrity and sense
of responsibility of its directors, officers and employees in whom great trust rests. The way in which that
trust is discharged determines the success of Fairview Mennonite Homes and the place of pride which it
enjoys in the community.
The transactions in which Fairview Mennonite Homes engages are diverse, multi-faceted and
increasingly complex. It is not possible to provide a set of rules that would codify proper behaviour in
every situation. However, it is imperative that a high standard of ethical, moral and legal conduct is
evidenced in all business practices.
Board members are entrusted with both verbal and written information regarding the people they serve,
their families, employees, volunteers, fellow directors, and the organization. Board members are expected
to maintain complete confidentiality regarding any information.
The right of every individual to privacy should be recognized and protected to the greatest extent
possible.
The purpose of this policy is to ensure confidentiality of information and activities relating to residents,
their families, employees, volunteers, Board of Directors and the organization of Fairview Mennonite
Homes.
PROCEDURE
1. Each Board member has a duty of care to use utmost discretion in the handling of confidential or
privileged information, and other information not normally available to the public generally and
coming to them by reason of their position. Such information shall not be used for personal
benefit or for the benefit of family, friends or associates.
2. All members of the Board of Directors of Fairview Mennonite Homes will sign a "Board Member
Confidentiality Agreement” form (see Appendix A).
3. Board members will sign this "Board Member Confidentiality" form annually at the meeting of the
Board of Directors in June immediately following the Annual General Meeting.
4. Confidential matters are defined as follows:
a) Residents/Tenants
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Any information related to the residents/tenants including income, subsidy, arrears, personal
circumstances, health, medical records, conflicts between residents/tenants/staff, and any
requests from residents/tenants that are personal.
b) Staff
Anything related to hiring, terminating, disciplining, salary negotiations, residents/tenants'
complaints; problems between staff members; and information of a personal nature.
c) Other
Anything else that Fairview Mennonite Homes’ lawyers advise is confidential, that the Chief
Executive Officer deems confidential, or that the Board deems confidential.
d) Below are guidelines which establish, but are not limited to, the following items as
confidential:
I.
the name of a person where it appears with other confidential information.
II.
home address, home telephone numbers and email addresses of staff.
III.
home address, telephone numbers and email addresses of residents/tenants who
have asked that they be kept confidential
IV.
personal and medical information
V.
details of job applications and resumes
VI.
social insurance numbers
VII.
personal correspondence between Board, staff and residents/tenants
VIII.
information about employment record, finances and education of employees and
residents/tenants
IX.
personal information about subsidy or rent geared-to-income assistance which
residents or tenants receive
X.
details about conflicts that involve Board, residents/tenants, and/or staff
XI.
details covered by the Human Rights Code, such as race, age, religion
XII.
information about Fairview Mennonite Homes’ business that may damage the
Corporation's reputation if others know about it
5. Guidance Regarding Confidentiality:
a) Board members must not discuss any confidential matter as defined above except at a duly
constituted Board meeting or as directed by Fairview Mennonite Homes’ lawyers.
b) Printed confidential material shall be so indicated.
c) All written material related to confidential matters shall be destroyed immediately following
the Board meeting at which it was discussed except for the official records, which shall be
kept in a locked area of the Business Office or in the locked record storage area.
d) When in doubt as to whether certain information is confidential, seek management advice
before disclosing it to anyone.
e) Information needed by the Board will usually be in a summary form where identification of
individuals is not relevant. The Board does not need to know the names of individuals.
f) There are some circumstances in which such information may be release. These may
include medical emergencies, threats to safety, consent of the person concerned, or a
criminal investigation. Such situations need to balance the individual’s right to confidentiality
with their personal safety and that of the whole community.
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g) Even with the above exceptions, the information is not to be freely released. Personal
information should only be released on a need-to-know basis – when it is crucial to the issue
being considered.
h) All media questions must be referred to the Chief Executive Officer.
6. Consequences of Breaching Confidentiality:
a) A breach of confidentiality by a Board Member is grounds for this person to be removed as a
Board member.
b) A Board member who breaches confidentiality may not be covered by Fairview Mennonite
Homes’ insurance if a resident/tenant or staff member were to successfully sue for libel.
7. The Board should be aware that Fairview Mennonite Homes’ information provided to the funding
authorities can be obtained by the public through the Freedom of Information and Protection of
Privacy Act. This Act gives the public a right of access to certain information held by the
government. Thus, it may affect Fairview Mennonite Homes indirectly because of reporting
information sent to the Ministry of Health and Long Term Care. Members of the public could apply
to the Ministry for information about Fairview Mennonite Homes. There are certain exemptions
which allow the Ministry to refuse access to some information (matter involving solicitor-client
privilege and financial or labour relations information supplied in confidence), but these
exemptions are very limited and members of the public may obtain information about Fairview
Mennonite Home Corporation such as annual records and audits, i.e. anything that is in Ministry
files about Fairview Mennonite Homes.
8. The public is also able to request and obtain information from the appropriate government
ministry about Fairview Mennonite Homes’ letters patent, supplementary letters patent, and
names, addresses and phone numbers of members of the Board.
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“Appendix “A”
Fairview Mennonite Homes
BOARD MEMBER CONFIDENTIALITY AGREEMENT
NAME OF BOARD MEMBER ____________________________________
I acknowledge that, during my tenure on the Board of Directors of Fairview Mennonite Homes and
Parkwood Mennonite Home, I will have access to personal information about clients/residents and their
families, employees, volunteers, donors and other members of the Board of Directors, as well as other
organizational, administrative, clinical and financial information about Fairview Mennonite Homes and
Parkwood Mennonite Home.
At all times I will respect the privacy of clients/residents and their families, employees, volunteers, donors
and other members of the Board of Directors.
I will treat all personal information about clients/residents and their families, employees, volunteers,
donors and other members of the Board of Directors, as well as other organizational, administrative,
clinical and financial information about Fairview Mennonite Homes and Parkwood Mennonite Home as
confidential information that should not be disclosed to anyone other than persons who are authorized to
receive such information.
I will ensure that private and confidential information is not inappropriately accessed, used or disclosed,
either directly by me or by virtue of paper or electronic documents in my care or control or my password to
any electronic or online systems.
If I am in doubt as to whether certain information is confidential, I will seek the advice of the Board of
Directors and the Chief Executive Officer before disclosing to anybody. I understand that all media
questions must be referred to the Chief Executive Officer.
I confirm that I have read, understood, and in good faith accept and will abide by the Confidentiality
policies set by Fairview Mennonite Homes and Parkwood Mennonite Home, as may be amended (FMH
BP-10 and PMH BP-10).
I understand and agree to abide by the conditions outlined in this Agreement, which will remain in force
even after my tenure on the Board of Directors has ended.
I understand that if any of these conditions are breached, I may be subject to disciplinary action that may
include removal from the Board.
NAME (please print): __________________________
SIGNATURE: _________________________
NAME OF WITNESS: _________________________
SIGNATURE: _________________________
DATE: ______________________