Privacy Policy

The privacy policy applies to personal information about the children in our care, their parents/legal guardians, their siblings, and other individuals who are involved in their care and upbringing (collectively, “the children in our care and their families"). VINCI Education Corporation's Child Care Programs respect privacy and we have a longstanding commitment to protecting the personal information of the children in our care and their families.

For the purposes of this policy, “personal information" is defined as any identifiable information about the children in our care and their families, such as contact details, health information, living arrangements, background information, the child's personal characteristics and behaviour styles.

Personal information is only collected, used and disclosed by VINCI Education Corporation in accordance with this Privacy Policy and the legal obligations imposed by the Personal Information Protection and Electronic Documents Act (PIPEDA).

WHY DO WE COLLECT PERSONAL INFORMATION

When enrolling your child/children in our child care program, as the parent or legal guardian, you are asked to provide certain pieces of information in order for us to provide you and your child/children with the best possible service. In addition to your contact details and the names and contact information of your family members, your child's file may include the following information about your child:

Living arrangements.
Health information and special needs.
Personal characteristics, skills and behavioural information.
Incidents about the child as recorded by our staff.

Personal information is only collected for the following purposes:

To identify the children in our care and their families;
To monitor the health and well-being of the children in our care;
To monitor developmental levels, skill acquisition and special needs of the children in our care.To establish a culturally sensitive and developmentally appropriate program for the children in our care;
To understand the desires, concerns and opinions of the children in our care and their families;
To establish and maintain good relationships with the children in our care and their families;
To provide the responsible child care services expected of a licensed child care program to the children in our care and their families;
To manage and enhance our business and operations; and to meet legal and regulatory requirements, such as those contained in the Day Nurseries Act and its associated Regulations.
The forms may also require financial information for the purpose of billing and payment. This information is used to provide appropriate services through VINCI Portal.

VINCI Education Corporation never collects more personal information than is needed to fulfill these purposes, unless you have consented to such collection.

WHEN DO WE DISCLOSE PERSONAL INFORMATION AND TO WHOM

We will make sure that any required disclosures of personal information are made on a “need to know" basis, and where applicable, on a confidential basis, and in accordance with the provisions of the Ontario Child Care and Early Learning Act and its associated Regulations. Personal information is never traded, sold or leased by us to any external companies. We may disclose personal information to:

Public Health
Ministry of Education
City of Kingston Childcare Programs
Prince Edward - Lennox and Addington Children's Services
United Counties of Leeds and Grenville Community and Social Services
VINCI Education Corporation's Board of Directors
Therapists, volunteers, students on placement with VINCI Education Corporation
Educational or regulatory observers and other service providers on an as-needed basis in order for them to assist us in managing,providing or evaluating our child care services and program; an agent of a public authority (such as the Children's Aid Society) if, in our reasonable judgment, it appears that there is imminent danger to life or property which could be avoided or minimized by the disclosure of the information
A third party with whom we are negotiating in order for them to take over some or all of our services and/or other activities
A third party where the individual (or his/her parent/legal guardian) has consented to such disclosure; a third party where such disclosure is required or permitted by law.

When sharing personal information we release limited information as required for the function that will be performed by the representative on our behalf. We also ensure that every representative is clear on their obligation to protect personal information and only use the information for the purpose(s) for which it is being provided.

Examples of the Representatives that VINCI Education Corporation may share your limited personal information with include:

Professionals who may assist us in caring for the physical, emotional, social and/or intellectual well being and/or safety of the children in our care
Entities that assist us with general administration, including debt collection.

Note that whenever practical, VINCI Education Corporation discloses de-identified information as opposed to personal information.

HAVE YOU CONSENTED

Having read this policy and by enrolling your child in our child care program and by providing us with the personal information requested, you consent to the collection, use and disclosure of your personal information as specified herein.

If VINCI Education Corporation will be using or disclosing personal information for purposes that have not been stated in this policy and that we do not feel are obvious to you, we will first obtain your express consent. We may imply your consent if we feel we are using your personal information for purposes that are obvious to you. For example, if you tell us that your child has a food allergy, we may not seek your express consent before providing this information to our kitchen staff. With written notice you may withdraw consent at any time subject to legal or contractual restrictions and reasonable notice. You may contact us for more information regarding the implications of withdrawing consent.

In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual (or his/her parents/legal guardian). For example: If it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated; If seeking the consent might defeat the purpose for collecting the information, such as in the context of an investigation of a breach of an agreement or a contravention of a federal or provincial law; or If there is an emergency where the life, health or security of an individual is threatened.

HOW LONG IS YOUR INFORMATION RETAINED

We retain personal information only as long as it remains necessary or relevant for the identified purposes, and in accordance with legal requirements. Therefore, we will retain your child's file as long as your child is enrolled in our child care program and for a fixed period of time thereafter.

Depending upon the circumstances, where personal information has been used to make a decision about an individual, we will retain the information for a period of time that is reasonably sufficient to allow for access by that individual (or his/her parent/legal guardian).

VINCI Education Corporation retains and securely destroys personal information in accordance with our internal record retention procedure. Our retention procedure takes into account retention requirements for financial and insurance records, the statutes of limitation relevant to injuries that occur while children are in our care, as well as the requirements of the Day Nurseries Act and its associated Regulations.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE

We have procedures and policies in place to ensure that personal information, in both paper and electronic format, are protected against the risk of loss, theft, unauthorized access, disclosure, copying, modification or destruction. For example, we have the following safeguards in place:

All visitors are required to report to the office and will be escorted while on the premises.
Filing cabinets containing personal information are only accessible to the director, supervisor, general manager and the on-site-supervisors of our child care programs. When filing cabinets are not in use and after hours they are locked.
Access to electronic files is limited on a need-to-know basis depending on job function.
Paper records containing personal information that are no longer needed are securely shredded.
Password selection criteria and password expiry make unauthorized access to our systems extremely difficult. VINCI Education Corporation's secure databases are well-protected on servers equipped with enterprise firewalls that are immediately updated when new patches and fixes are released. Staff training on the importance of privacy and security is undertaken regularly.

HOW CAN YOU ACCESS YOUR PERSONAL INFORMATION AND CHECK ITS ACCURACY

VINCI Education Corporation relies on the information provided by you when enrolling your child in our child care program. You may at any time make a written request for access to your or your child's personal information using our “Access to Personal Information Form". Personal information will be provided in an understandable form within a reasonable time and at minimum or no cost to the individual.

However, in certain situations we may not be able to provide access to all of the personalinformation we hold about an individual (or his/her child) as there are numerous exceptions to the access principle under PIPEDA. For example, we cannot provide access to personal information about another individual if they have not consented, or to information that could reasonably be expected to threaten the life or security of another individual. Also, we cannot provide access to information that was generated in the course of a formal dispute resolution process. If we are unable to provide you with all the information contained in your child's file, we will let you know.

VINCI Education Corporation strives to maintain accurate records of your personal information, however, this cannot be achieved without your help. In this ongoing effort, we ask you to provide us with up-to-date information. Let us know of any personal information you have given to us in the past that is incomplete, inaccurate, or no longer relevant, or of any new issues or information that will help us in caring for your child. If you feel a record in your child's file is inaccurate or incomplete, and we agree with your assessment, we will promptly correct or complete the information. Any unresolved differences as to accuracy or completeness will be noted in the file.

WHY DO WE COLLECT PERSONAL INFORMATION

Living arrangements.
Health information and special needs.
Personal characteristics, skills and behavioural information.
Incidents about the child as recorded by our staff.

Personal information is only collected for the following purposes:

To identify the children in our care and their families;
To monitor the health and well-being of the children in our care;
To monitor developmental levels, skill acquisition and special needs of the children in our care.To establish a culturally sensitive and developmentally appropriate program for the children in our care;
To understand the desires, concerns and opinions of the children in our care and their families;
To establish and maintain good relationships with the children in our care and their families;
To provide the responsible child care services expected of a licensed child care program to the children in our care and their families;
To manage and enhance our business and operations; and to meet legal and regulatory requirements, such as those contained in the Day Nurseries Act and its associated Regulations.

VINCI Education Corporation never collects more personal information than is needed to fulfill these purposes, unless you have consented to such collection.