ISEAD PRIVACY POLICY

1. Purpose and Commitment to Privacy

Indigenous Skills Employment Apprenticeship and Development (ISEAD) is committed to respecting and protecting the privacy, confidentiality, dignity and personal information of individuals who engage with our organization, programs and services.

ISEAD recognizes that individuals entrust us with personal information when seeking employment, skills development, apprenticeship opportunities, education, training and other forms of program support. We have a responsibility to ensure that this information is collected for legitimate purposes, handled with integrity and protected against unauthorized access, use or disclosure.

This Privacy Policy establishes the principles governing the collection, use, disclosure, retention, safeguarding and management of personal information by ISEAD. The Policy is designed to be consistent with the ten privacy principles established in the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information, as referenced in our Skills Development Fund Training Stream (SDF-TS) funding agreement with the Province of Ontario.

ISEAD is committed to complying with applicable federal and provincial privacy legislation and the privacy protection obligations contained in its funding agreements, including its SDF-TS agreement with the Ministry of Labour, Immigration, Training and Skills Development.

2. Scope of the Privacy Policy

This Policy applies to personal information collected, used, disclosed or maintained by ISEAD in connection with its programs, services, organizational activities and website. It applies to information relating to program applicants, participants, clients, learners, employers, community partners and other individuals whose personal information is handled by ISEAD.

The Policy also establishes the privacy responsibilities applicable to employees, representatives, volunteers, placement students, independent contractors, authorized subcontractors and other service providers who may access personal information while performing duties on behalf of ISEAD.

Additional privacy requirements may apply to particular programs, funding agreements or services. Where these requirements impose more specific obligations, ISEAD will administer personal information in accordance with those obligations and applicable law.

3. Accountability for Personal Information

ISEAD is responsible for personal information under its custody or control, including information entrusted to authorized personnel or service providers for the delivery of its programs and services.

ISEAD has designated a Privacy Officer responsible for overseeing compliance with this Policy, supporting the implementation of privacy protection measures, addressing privacy-related inquiries and coordinating responses to suspected or actual privacy breaches.

Employees, contractors and authorized subcontractors who have access to personal information are required to comply with ISEAD’s privacy requirements and the applicable privacy protection provisions of relevant funding agreements. Personnel with access to personal information are subject to confidentiality obligations and appropriate privacy protection training.

Individuals may contact ISEAD’s Privacy Officer regarding privacy inquiries, complaints, access requests or concerns at privacy@isead.ca.

4. Identifying the Purposes for Collecting Personal Information

ISEAD collects personal information for identified and legitimate purposes connected to the administration and delivery of its programs and services. Depending on the particular program or service, personal information may be collected for the following purposes:

Determining eligibility for employment, apprenticeship, skills development, education and training opportunities.
Registering participants and administering program enrolment, participation and completion.
Developing and maintaining participant records, service plans, training records and employment-related documentation.
Coordinating training, assessments, work placements, apprenticeship opportunities and other authorized program supports.
Communicating with participants regarding program activities, requirements and services.
Monitoring program participation, progress, outcomes and employment status.
Preparing information required by government funding agreements, including financial, operational, performance and participant reporting.
Supporting authorized program monitoring, evaluation, audits and compliance reviews.
Meeting applicable legal, contractual, regulatory and records-management obligations.

For provincially funded programs, including SDF-TS, personal information may also be collected and used to support the Ministry’s authorized administration, monitoring, performance measurement and evaluation activities. ISEAD will identify the purposes for collecting personal information at or before the time of collection, as required by applicable law and program requirements.

5. Personal Information Collected

Personal information means information about an identifiable individual. The categories of information collected by ISEAD depend on the program, service or activity in which an individual participates. Where necessary and authorized, this information may include:

Personal identification and contact information, such as name, telephone number, email address and mailing address.
Information required to establish program eligibility and determine suitable services.
Employment, education, qualifications, training, apprenticeship and occupational experience.
Participant registration forms, consent documentation, applications and program-related agreements.
Information concerning training participation, attendance, progress, completion and employment outcomes.
Information required to arrange approved participant supports or administer program-related financial assistance.
Demographic or other personal information required by applicable government program forms and reporting obligations.

Some programs may require information that individuals consider sensitive, including information relating to disability, accommodation needs, Indigenous identity or other eligibility and demographic characteristics. ISEAD will limit the collection of such information to circumstances where it is necessary and authorized for an identified purpose, and will apply safeguards appropriate to its sensitivity.

ISEAD does not collect personal information beyond what is necessary to deliver its programs and services or fulfil its applicable legal and contractual obligations.

6. Consent and Notice of Collection

ISEAD respects the right of individuals to understand why their personal information is being collected and how it will be used or disclosed. Where required, ISEAD provides a Notice of Collection and obtains the appropriate consent before collecting, using or disclosing personal information.

Participants in SDF-funded programs are required to complete the applicable government-prescribed participant registration and consent documentation, including consent relating to indirect collection where specified by the Ministry.

Personal information collected for the delivery of an SDF-funded project will not be used for a purpose outside the delivery of that project without the individual’s informed and voluntary written consent, in accordance with the applicable funding agreement. Where such additional consent is required for a participant under 18 years of age, written consent from a parent or guardian must also be obtained in accordance with the SDF funding agreement.

Individuals may contact ISEAD’s Privacy Officer to ask questions about consent, the purposes for which information is collected or the implications of withholding or withdrawing consent. Any withdrawal of consent will be considered in accordance with applicable legal and contractual requirements. Certain information may need to be retained or used to fulfil existing obligations, including requirements associated with government-funded programs.

A website privacy policy does not replace any specific Notice of Collection, registration form or consent document required for participation in an ISEAD program.

7. Limiting the Collection of Personal Information

ISEAD collects only the personal information reasonably necessary to achieve identified program, service, operational, legal and contractual purposes. Information collection must be carried out through fair and lawful means and in accordance with applicable privacy requirements. Personnel are not authorized to collect personal information for unrelated purposes or for personal use.

Where an ISEAD program is funded by the Province of Ontario, the collection of participant information will be limited to what is required to deliver the project and comply with the applicable funding agreement, including authorized monitoring, evaluation and reporting requirements.

8. Limiting the Use and Disclosure of Personal Information

ISEAD uses and discloses personal information only for identified and authorized purposes, subject to applicable privacy laws and contractual requirements. Access to personal information is restricted to personnel, contractors and authorized subcontractors who require the information to carry out legitimate responsibilities on behalf of ISEAD.

Personal information may be disclosed to authorized recipients where necessary for program delivery, including relevant training providers, participating employers, service providers or government funding authorities, subject to applicable consent and disclosure requirements.

Disclosure to the Province of Ontario

For programs funded through the Skills Development Fund Training Stream, ISEAD may be required to disclose participant information to the Ministry of Labour, Immigration, Training and Skills Development for authorized program administration, reporting, monitoring, evaluation, verification, audit and compliance purposes. Such information may include participant registration information, eligibility documentation, program participation records, training and employment outcomes, and other information required

under the applicable funding agreement.

Authorized participant information may also be recorded in designated provincial systems, including the Employment Ontario Information System Case Management System (EOIS-CaMS). Access to provincial systems is limited to authorized users in accordance with the applicable system registration, privacy and security requirements.

SDF Participant Exit and Follow-Up Activities

For participants in SDF-TS Full-Service Projects to whom the applicable exit and follow-up requirements apply, ISEAD conducts an exit interview using the Employment Status Questionnaire (ESQ) and records the required information in EOIS-CaMS. Under the SDF-TS agreement, participants who complete all service plans or interventions are followed up at three, six and twelve months after exit to document employment status and program outcomes, including where follow-up occurs after the agreement expires or terminates.

ISEAD may also contact participants, trainers, participating employers, project partners or other stakeholders in connection with authorized Ministry evaluation activities, including surveys, interviews and discussion groups, where required under the agreement and permitted by applicable privacy laws and notices of collection.

ISEAD does not authorize personnel or service providers to access, use or disclose participant information for purposes unrelated to their approved responsibilities. Where information is required for a new purpose outside authorized project activities, ISEAD will obtain the informed and voluntary written consent required by its SDF agreement, subject to applicable law.

9. Accuracy of Personal Information

ISEAD takes reasonable measures to ensure that personal information used in the administration of its programs is accurate, complete and up to date to the extent necessary for its intended purposes. This includes information used to establish program eligibility, maintain participant records, administer services and fulfil applicable government reporting requirements.

Individuals are encouraged to advise ISEAD if information previously provided is inaccurate or has changed. Requests to review or correct personal information may be directed to privacy@isead.ca. ISEAD will review such requests and address them in accordance with applicable privacy laws, program obligations and organizational procedures.

10. Safeguards and Protection of Personal Information

ISEAD is committed to maintaining administrative, technical and physical safeguards appropriate to the nature and sensitivity of the personal information under its custody or control. These safeguards are intended to protect personal information against unauthorized or inadvertent collection, access, use, disclosure, alteration, loss or destruction.

ISEAD’s Privacy and Security Standard of Conduct establishes requirements addressing secure information handling, confidentiality, authorized access, electronic information security, information transfer, record retention and destruction, cybersecurity awareness and incident reporting. Personnel and authorized service providers must handle personal information in accordance with their assigned responsibilities and applicable confidentiality obligations.

Electronic Information and Canadian Data Storage

Personal information collected and stored in connection with ISEAD’s SDF-funded activities is maintained within Canada using Canadian data centre infrastructure in accordance with the applicable contractual data residency and security requirements. These requirements include the relevant ISO/IEC security standards and Government of Ontario Information Technology Standard GO-ITS 25.0, as specified in ISEAD’s SDF-TS agreement.

Access to electronically stored personal information is restricted to authorized users and governed by applicable access and security controls. ISEAD requires personnel and service providers handling personal information to follow approved information management and security procedures.

11. Retention and Secure Destruction of Personal Information

ISEAD retains personal information only for as long as necessary to fulfil the purposes for which it was collected and satisfy applicable legal, regulatory and contractual obligations. Records associated with government-funded programs are subject to the retention requirements established in the relevant funding agreements.

Under ISEAD’s SDF-TS agreement, financial and non-financial records relating to the funded project must be maintained for seven (7) years from their creation. The agreement also requires the retention of signed participant forms mandated by the Province for seven (7) years and their production to the Province upon request.

ISEAD maintains procedures governing the retention, authorized handling and secure destruction of personal information in paper and electronic formats. When personal information is no longer required and all applicable retention obligations have been satisfied, records are subject to secure destruction or disposal in accordance with ISEAD’s approved procedures. Records will not be destroyed where continued retention is required by law, contractual obligation, audit, investigation or another applicable legal requirement.

12. Individual Access to Personal Information

ISEAD recognizes the importance of providing individuals with appropriate access to personal information held about them. Individuals may request access to their personal information or seek correction of information they believe is inaccurate or incomplete.

Requests must be directed to ISEAD’s Privacy Officer at privacy@isead.ca. ISEAD will review requests and provide access or address correction requests in accordance with applicable privacy laws, its Privacy Policy and relevant contractual obligations. Reasonable steps may be taken to verify the identity and authority of an individual requesting access to personal information before any information is released.

Where access must be limited or refused under applicable law, ISEAD will communicate the applicable decision and available options for further inquiry or review.

13. Privacy and Security Breaches

ISEAD recognizes that the protection of personal information includes the responsibility to identify and respond promptly to suspected or actual privacy and information security breaches. A privacy breach may involve the unauthorized collection, use, access or disclosure of personal information, or the loss or improper handling of information. A security breach may involve unauthorized access to electronic systems, applications, networks, devices or information.

ISEAD’s Privacy and Security Standard of Conduct establishes mandatory reporting procedures for suspected or actual privacy and security incidents. All personnel and authorized service providers are required to report suspected or actual incidents immediately through ISEAD’s designated privacy reporting process.

ISEAD will assess reported incidents and initiate appropriate action in accordance with its policies and applicable legal and contractual obligations. For SDF-funded activities, ISEAD is required to notify the Province as soon as it becomes aware of a potential or actual breach of its privacy policy or the privacy protection provisions of the agreement relating to records containing personal information.

ISEAD will cooperate with the Province and its authorized representatives in any applicable investigation or audit involving privacy protection requirements. Where notification to affected individuals or other authorities is required, ISEAD will undertake such notification in accordance with its applicable obligations. Privacy or security concerns may be reported to privacy@isead.ca

14. Website Privacy and Electronic Communications

ISEAD may receive personal information that individuals choose to provide through website contact or inquiry forms, program-related registration processes, email correspondence and other authorized electronic communications. Where this occurs, ISEAD uses that information to respond to the inquiry, administer the requested service, assess eligibility where applicable, or carry out another purpose identified at the point of collection.

Website submissions that include personal information are subject to this Policy, including limitations on use and disclosure, access restrictions, safeguarding and applicable retention requirements. Individuals should not include sensitive personal information in general website inquiries unless it is requested through an authorized program collection process.

Website functionality may involve technical information, such as browser or connection data, and may involve cookies, analytics or third-party tools. The types of such technologies, the information they collect and any available consent or preference controls depend on the website features in operation. Where these tools collect personal information, the applicable collection purposes and privacy choices must be communicated through a relevant website notice or interface as required by law. This Policy does not represent that a particular analytics or advertising technology is in use.

A link to a third-party website or service does not mean that ISEAD controls that third party’s independent privacy practices. Where a service provider handles personal information on ISEAD’s behalf, that handling is subject to applicable contractual, confidentiality and security obligations.

15. Openness and Transparency

ISEAD is committed to making information about its privacy practices accessible and understandable to individuals who participate in its programs and services. This Privacy Policy is publicly available through ISEAD’s website and describes the organization’s general practices regarding personal information. Additional notices, consent forms or privacy information may be provided where required for particular programs or services.

Individuals may request clarification regarding ISEAD’s personal information practices, applicable consent requirements or procedures for accessing their personal information.

16. Privacy Complaints and Challenging Compliance

Individuals have the right to raise questions or concerns regarding ISEAD’s handling of their personal information. ISEAD is committed to receiving and reviewing privacy concerns respectfully, confidentially and in accordance with applicable legal and contractual obligations.

A privacy complaint may relate to the collection, use, disclosure, security, accuracy, retention or accessibility of personal information. Individuals who believe their personal information has been handled inconsistently with this Policy may submit their concern to ISEAD’s Privacy Officer at privacy@isead.ca. ISEAD will review privacy concerns and determine appropriate action in accordance with its responsibilities and applicable requirements.

17. Policy Review and Amendments

ISEAD will review and update this Privacy Policy as necessary to reflect changes in applicable privacy legislation, funding agreements, organizational operations, information management practices or program requirements. Changes to the Policy will be published through ISEAD’s website. Where material changes affect the purposes for which personal information is collected, used or disclosed, ISEAD will provide additional notice or obtain consent where required.

18. Privacy Contact

For all inquiries concerning personal information, privacy rights, access or correction requests, privacy concerns, complaints or suspected privacy breaches, individuals may contact:

Privacy Officer
Indigenous Skills Employment Apprenticeship and Development (ISEAD)
Email: privacy@isead.ca