The governing legislation ensures citizens’ right to privacy. Thus we have a clear obligation to inform service provider(s) of what personal information is collected and for what purposes, to store the information securely, to be clear about who has access to that information and to inform them of what information will be shared in what circumstances.
To ensure awareness and safety with respect to personal information, the following programs are in place:
- Upon Hire: Candidate signs a Confidentiality FORM: CAF-01 and is made aware of whom the Privacy officer is.
- Lunch and Learn: service provider(s) are strongly encouraged to participate in client/Synergy training sessions. As well regular newsletters will be provided by Synergy to its service provider.
- Manuals: service provider(s) will have resources related to patient and client confidentiality and privacy related issues available to them.
Clients – refers to any business partner, organization, business or associated business relationship conducting business or business transactions relating to the exchange, delivery or other such business practice(s) with SES.
Service Provider(s) – refers to any individual(s) that represent SES to any of our Clients or as general embassadors for the SES brand or division.
Principle 1 – Accountability
Synergy Employment Services Inc. (SES) is responsible for personal information under its control and shall designate an individual or individuals who are accountable for SES compliance with the following principles.
1.1 SES shall protect personal information of its clients and service provider(s)’ under its control. SES may delegate other individual(s) the responsibility of day-to-day collection and management of personal information.
1.2 SES shall make available the name and contact information for the individual(s) designated as the compliance officers of this policy upon request.
1.3 SES is responsible for personal information in its possession or custody, including information transferred to third parties, if any, for processing on its behalf. SES will attempt to assure that such third parties will have similar measures in place to protect information while being processed.
Principle 2 – Identifying Purpose
2.1 SES identifies the purpose for which personal information is being collected at or before the time of collection from the person the information is collected. This allows SES to determine the information that needs to be collected.
2.2 Information may be collected by electronic mediums, orally or in writing depending on the nature of information collected. Examples include; personal information for hiring new staff or updating current service provider(s) files, registering for services, participating in services and/or participating in educational tools.
2.3 In the event that personal information collected is required to be used or disclosed for a purpose not already outlined, in a manner that the service provider(s) or client has not already granted permission, the personal information will not be used or disclosed. Only upon receiving permission to use or disclose such information will it be used or disclosed.
2.4 Individual(s) collecting personal information should be able to explain as to why such information is necessary and is being collected at the time of collection.
Principle 3 – Obtaining Consent
3.1 SES collects personal information by ethical, fair and lawful means. SES obtains the individual’s consent for the collection, use or disclosure of personal information as required by the ACT or law.
3.2 SES may obtain personal information by various methods, depending on the circumstances and nature of information collected. SES will in general obtain consent for personal and/or health information. Certain situations may require express consent. Consent can also be implied or given by authorized individual. Authorized individuals will be determined by the Substitute Decisions Act.
3.3 Consent may be given in various ways including and not limited to application forms, forms may be used for consent, completion and signing of forms, orally and/or implied by the individuals use of a product or service.
3.4 The consent may only apply when consent and knowledge are present. SES shall make reasonable efforts to ensure that individuals are advised of the purpose for which the information is being collected.
3.5 SES may require an individual to consent to the collection, use or disclosure or information beyond that specifically outlined for legitimate reasons.
3.6 A service provider(s) may withdraw consent to use his or her personal information at any time, subject to any legal or contractual restrictions and upon giving SES reasonable notice. SES will inform the individual of implications, if any, of withdrawing consent and how to do so.
3.7 SES will seek consent from its service provider(s) and clients to collect, use and disclose personal information in most circumstances. There are some exceptions to the requirement to obtain consent. These exceptions include, and are not limited to, where SES is required to comply with a court order or investigation by law authorities.
Principle 4 - Limiting Collection of Personal Information
4.1 SES limits the collection of personal information to which is reasonably necessary for identification and employment purposes. Information shall be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention
5.1 SES does not use or disclose personal information for reasons other than what have been specified under collection. Certain exceptions will exist only under the consent of the individual, or as permitted by the law.
5.2 SES retains personal information for as long as is deemed necessary for the fulfillment of those purposes or as required by the law.
5.3 Personal information that is no longer deemed necessary, will be destroyed, erased or made anonymous within a reasonable period of time.
5.4 SES may disclose personal information to a person or organization that is directly or indirectly involved in supplying a product or service to SES and/or its clients. This may include without limitation our sales and marketing department, human resources, invoice printing and mailing suppliers, data processing and product/ service providers. The personal information disclosed is only to the extent to which is deemed necessary and is only for used for efficiently supplying SES with services. This disclosure requires the person or entity receiving the information to keep it confidential.
5.5 SES will take reasonable measures to ensure that only service provider(s)s who need to know or whose responsibilities require them to know, are given access to personal information.
5.6 SES will ensure that all information collected is void of any identifiers should that information be required as per the collection agreement by the client and SES.
Principle 6 – Accuracy
6.1 Personal information shall be as accurate, complete and up-to-date as necessary for the purposes for which it was collected.
6.2 SES will take reasonable measures to keep personal information accurate, complete and up-to-date depending on the use of the information. Individual(s) may be required, or asked to update information periodically and may verify information or correct by submitting a correction notice.
6.3 SES will rely on the presentation presented by the individual for completeness, accuracy and legitimacy. SES retains the right to verify such information by means of cooperation with regulatory bodies and/or issuing offices.
Principle 7 – Safeguards
7.1 SES maintains security safeguards to protect personal information from unauthorized access, use and disclosure. The level of safeguarding will depend on the nature of the personal information that has been collected.
7.2 These safeguards will include loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. All SES service provider(s) are made aware of the importance of maintaining confidentiality of personal information.
7.3 Measures will be in place for the appropriate destruction or disposal of personal information.
Principle 8 – Openness
8.1 SES will make information about policies and procedures available to all service provider(s) and clients.
Principle 9 – Obtaining access to Personal Information
9.1 Upon written request and according to requirements under this policy, SES provides access to their personal information and details about its use and disclosure.
9.2 The individual may be able to challenge the accuracy and completeness of his or her personal information and have it corrected by accepted means, as or when necessary.
9.3 SES shall make reasonable efforts to respond to any written request for personal information within 35 days after receipt of that request and at minimal or no cost. Any extensions of time that may be required on SES’s behalf will be made to individual in writing.
9.4 Certain circumstances will not allow SES to give access to all personal information about an individual or client. Some example may be, if the information contains reference to another individual or client, cannot be disclosed for legal, commercial or proprietary reasons or the information is subject to solicitor or litigation privilege. In the event that SES is not available to release personal information, written notice shall be given to the individual in request and possible recourse actions available.
Principle 10 – Challenging Compliance
10.1 An individual shall be able to challenge a concern addressing compliance with the above written principles to the designated individual(s) for SES.
10.2 All concerns must be received in writing and addressed to Compliance Officer, Synergy Employment Services Inc. at:
Synergy Employment Services
29 Gervais Drive, Suite 205
Toronto, ON M3C 1Y9
The Privacy & Confidentiality policy and signing and agreeing to Confidentiality Agreement Form CAF-01, is mandatory for all service provider(s) to participate in prior to placement with any client of Synergy Employment Services Inc. This training can be facilitated at offices of Synergy Employment Services Inc. or can be offered in conjunction with its clients and their similarly oriented training programs. Records of participation and successful acknowledgment of the contents of the training will be maintained and reviewed by Synergy Employment Services Inc.
Equality & Human Rights Impact Statement:
This policy embraces diversity, dignity and inclusion in line with emerging human rights guidance. We recognize, acknowledge and value difference and consideration and ensure that no-one is belittled, excluded or disadvantaged in anyway shape or form.
Synergy Employment Services reviews all of its policies, procedures and programs on an annual basis.