As part of providing services, Key Assets Newfoundland and Labrador (KANL) collects personal information about clients. This is a statement on how KANL uses and protects personal information by which you can be identified (referred to as Personal Health Information). Personal health information means recorded information about an identifiable individual. KANL must obtain a client’s consent either expressed or implied to collect, use, or disclose personal information. KANL shall only collect information which is essential for the provision of service to its clients.
Personal health information collected may be utilized for the following purposes:
• related only to the core services provided by the agency;
• for service and/or treatment planning;
• facilitate collaboration within clients’ “Circle of Care”;
• conduct risk assessment activities;
• evaluate services and programs;
• research purposes (utilizing non-identifying information only);
• comply with legal and regulatory requirements; and
• fulfill other purposes permitted or required by law.
KANL endeavors to ensure that all personal data will:
• be processed fairly, lawfully and transparently;
• be collected and processed only for identified purposes;
• be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
• be accurate and kept up to date, where any inaccurate data will be rectified without delay;
• not to be kept for any longer that is necessary for the purposes for which it is processed; and
• be processed securely.
KANL has implemented appropriate technical and organizational measures to ensure compliance with data protection law and to prove such compliance. KANL is committed to ensuring that personal health information is accurate and up to date as is necessary for the purpose for which the information is used relative to services. You have a right to access or rectify your personal data with KANL if it is incorrect or incomplete. If a client believes that their personal health information is not accurate or is incomplete, they may request to have information amended as to correct the inaccurate or incomplete information. Such requests shall be made in good faith in writing to the Privacy Officer who will respond in writing within thirty (30) days.
Data will be kept only for as long as it is needed for the purpose for which it was collected. KANL has an established policy and practice for the destruction and disposal of personal health information.

A privacy breach is defined as non-consensual disclosure of a client’s PHI to unauthorized individuals thereby constituting a breach of the agency’s Privacy Policy. The Privacy Officer (see contact information below) will be immediately advised of the breach and will notify the client of the specifics of the breach and coordinate a timely investigative process. KANL is committed to resolving all issues related to breaches of this policy or any other concerns related to the privacy of their information. When such resolution is not received as successful by the client, contact can be made with the Office of the Information and Privacy Commissioner.

Privacy Officer for Key Assets Newfoundland and Labrador:
Laura Cross, MASP – Quality Assurance Manager
21 Adams Avenue,
St. John’s, NL A1C 4Z1
laura.cross@keyassetsnl.ca

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