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THE BERMUDA MENTAL HEALTH FOUNDATION P.O. Box HM 2892, Hamilton HM LX, Bermuda Website: www.bmhf.bm Email: [email protected] Telephone: (441) 703 0003
Personal Information Protection Policy |
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The Bermuda Mental Health Foundation (the “Foundation”) is committed to safeguarding the personal information entrusted to us by persons (“relevant persons” with whom we interact. These include: – the residents of our homes, – our members, directors and officers, – our volunteers, – our service providers. We manage their personal information in accordance with Bermuda’s Personal Information Protection Act 2016 (“PIPA”). This policy outlines the principles and practices we follow in protecting such personal information. This policy applies to the Foundation and to any person providing services on its behalf. A copy of this policy will be provided upon request and is available on the Foundation’s website www.bmhf.bm .
Nothing in this Policy shall restrict any use of personal information that is expressly permitted by PIPA such as personal information that is publicly available or where the use of the personal information is within the reasonable expectations of the individual to whom the information relates.
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What is personal information? Personal information means information about an identifiable individual such as the individual’s name, home address, phone number, age, sex, marital or family status, an identifying number, financial information, educational history and health information. Personal information includes sensitive personal information which is defined in PIPA as any personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, sexual life, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political opinions, trade union membership, biometric information or genetic information. Sensitive personal information must not be used to discriminate against a person contrary to Part II of the Human Rights Act 1981 without lawful authority as set out in PIPA.
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What personal information do we collect? We collect only the personal information that we need for the purposes of providing services to our residents, where required by law or where necessary for the Foundation to conduct its activities. We normally collect personal information directly from the persons involved but we may collect information from other persons with your consent or as authorized by law.
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We inform relevant persons, before or at the time of collecting personal information, of the purposes for which we are collecting the information. The only time we don’t provide this notification is when a person volunteers information for an obvious purpose (for example when a service provider provides their bank account details to enable the Foundation to pay them).
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Consent We ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where information is volunteered for an obvious purpose. PIPA deems that personal information about any person collected before the coming into force of PIPA was collected with the person’s consent and may be used by the Foundation for the purposes for which the information was collected. |
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We ask for the express consent of relevant persons for some purposes and may not be able to provide certain services if they are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask relevant persons to provide their consent orally in person or by telephone, or in writing by signing a consent form.
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A relevant person may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect such a decision, but we may not be able to provide them with certain products and services if we do not have the necessary personal information.
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We may collect, use or disclose client personal information without consent only as authorized by law. For example, we are not required to request consent when the collection, use or disclosure is in an emergency that threatens life, health or security of an individual or the public.
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How do we use and disclose personal information? We use and disclose client personal information only for the purpose for which the information was collected, except as authorized by law. For example, we may use client contact information to deliver goods.
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If we wish to use or disclose personal information for any new business purpose, we will ask for consent. We may not seek consent if the law allows us to use the personal information without consent (e.g. the law allows organizations to use personal information without consent for the purpose of collecting a debt).
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What is personal volunteer information? Personal volunteer information is personal information about a volunteer which is collected, used or disclosed solely for the purposes of establishing, managing or terminating a volunteer work relationship. Personal volunteer information may, in some circumstances, include bank account information or address.
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We can collect, use and disclose your personal volunteer information without your consent only for the purposes of establishing, managing or ending the volunteer relationship. We will provide current volunteers with prior notice about what information we collect, use or disclose and our purpose for doing so.
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What personal volunteer information do we collect, use and disclose? We collect, use and disclose personal volunteer information to meet the following purposes: · Determining eligibility for volunteer work, including verifying qualifications and references · Establishing training and development requirements · Assessing performance and managing performance issues if they arise · Complying with requirements of funding bodies · Complying with applicable laws
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We only collect, use and disclose the amount and type of personal volunteer information that is reasonable to meet the above purposes. The following is a list of personal volunteer information that we may collect, use and disclose to meet those purposes.
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We will inform our volunteers of any new purpose for which we will collect, use, or disclose personal information, or we will obtain your consent, before or at the time the information is collected.
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We will obtain your consent to collect, use and disclose your personal information for purposes unrelated to the volunteer relationship.
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What information do we provide for volunteer references? In some cases, after your volunteer relationship with us ends, we will be contacted by other organizations and asked to provide a reference for you. It is our policy not to disclose personal information about volunteers to other organizations who request references without consent. The personal information we normally provide in a reference includes:
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How do we safeguard personal information? We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
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We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.
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We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
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We retain personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes. Usually such information will be destroyed after 6 years from the date the person’s relationship with the Foundation has ended.
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Access to records containing personal information Individuals have a right to access their own personal information in a record that is in the custody or under the control of the Foundation, subject to some exceptions. For example, organizations are required under PIPA to refuse to provide access to information that would reveal personal information about another individual.
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If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
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You may make a request for access to your personal information by writing to James Macdonald at [email protected] and [email protected] . You must provide sufficient information in your request to allow us to identify the information you are seeking.
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You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. In addition, you may request a correction of an error or omission in your personal information or the erasing and destroying such information.
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We will respond to your request within 45 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.
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Questions and complaints If you have a question or concern about any collection, use or disclosure of personal information by the Foundation, or about a request for access to your own personal information, please contact James Macdonald [email protected] and [email protected] .
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If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Bermuda: Office of the Privacy Commissioner of Bermuda Maxwell Roberts Building 4th Floor 1 Church Street Hamilton, HM11 Bermuda
Telephone: (441) 543 7748 Email: [email protected]
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