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FIPPA

MTCU Notice of Disclosure

St. Lawrence College is required to disclose personal information such as Ontario Education Numbers, student characteristics and educational outcomes to the Minister of Advanced Education and Skills Development under s. 15 of the Ministry of Training, Colleges and Universities Act, R.S.O. 1990, Chapter M.19 as amended. The ministry collects this data for purposes such as planning, allocating and administering public funding to colleges, universities and other post-secondary educational and training institutions and to conduct research and analysis, including longitudinal studies, and statistical activities conducted by or on behalf of the ministry for purposes that relate to post-secondary education and training. Further information on how the Minister of Advanced Education and Skills Development uses this personal information is available on the ministry’s website.

Public institutions have a responsibility to ensure personal information about their clients is protected, and to facilitate timely public access to information or decision-making of a general nature.

Our policy - click here.

Ministry of Advanced Education and Skills Development (MAESD) Notice of disclosure:

St. Lawrence College is required to disclose personal information such as Ontario Education Numbers, student characteristics and educational outcomes to the Minister of Advanced Education and Skills Development under s. 15 of the Ministry of Training, Colleges and Universities Act, R.S.O. 1990, Chapter M.19 as amended. The ministry collects this data for purposes such as planning, allocating and administering public funding to colleges, universities and other post-secondary educational and training institutions and to conduct research and analysis, including longitudinal studies, and statistical activities conducted by or on behalf of the ministry for purposes that relate to post-secondary education and training. Further information on how the Minister of Advanced Education and Skills Development uses this personal information is available on the ministry’s website.

A range of personal, business and research information such as:

  • Student information, including student number, academic records
  • Emails, electronic documents, paper documents
  • Staff information, including personnel records
  • Information relating to contracts, vendors, operational plans
  • Alumni information contained in our Alumni database

Note that Health records fall under separate legislation (PHIPA – Personal Health Information Protection Act)

Information that is necessary in the performance of the job duties may be acquired from sources that hold the information. The staff who obtain the information are required to maintain the confidentiality of the information.

The Freedom of Information Officer is located in the Executive Office, and can be reached at ext. 1114 or by email to: privacyoffice@sl.on.ca. The Senior Vice President, Corporate Services is responsible for SLC’s compliance under FIPPA. St. Lawrence College is under strict time limits in relation to compliance with FIPPA: therefore staff who receive access requests, must immediately forward the request(s) to the Freedom of Information Officer.

Refer all enquiries from police to the campus Security Office. Security will deal with the inquiry, file appropriate reports and notify the Freedom of Information Officer. There are exemptions in FIPPA for releasing personal information to law enforcement officers, however such inquiries must be handled centrally – hence the campus security office will coordinate the college response.

Reference information can only be provided if you have the explicit (in writing) consent of the employee or student. We have forms that are given to students to sign authorizing St. Lawrence College to respond to reference queries. Employees are required to provide written consent (i.e. completion of the Reference Check Consent Form for internal positions) or an email/note if it is for an external employer.

None. Refer the caller to Human Resources, who prepare specific letters if requested by the individual. If the request is about a student, redirect the caller to the appropriate Academic Operations Manager.

Some course outlines state that medical documentation is required under certain circumstances to validate reasons for absence. Students with Disabilities should work through their AccessAbility counsellor regarding this requirement. Some programs also state such requirements in program manuals. Also refer to item 6.1 in Academic Policy.

ANSWER: Names and St. Lawrence College email addresses may be shared for purposes of group work. Beyond that, students should decide what personal contact information they choose to share with classmates.

No. However, if it is an emergency situation, you must offer to contact the student yourself (or with staff assistance) and ask the student to contact the requestor.

ANSWER: None, unless the student signs a Student Consent Form. Although parents/legal guardians/spouse may believe they have a right to a student’s attendance and/or academic record, especially if they are paying the tuition, such information may be shared with a parent/legal guardian/spouse only with the student’s explicit written consent.

ANSWER: The student’s consent may be oral if they are in attendance with parent/legal guardian/spouse, or the student must complete and sign a Student Consent Form.

ANSWER: Yes. In a post-secondary context, personal information includes students’ papers, assignments, tests and examinations, grades and academic standing, and professors’ evaluative comments on their work.

ANSWER: Assignments, tests and exams that are not returned to the student must be retained for a minimum of one year after last use so that the student has a reasonable opportunity to obtain access to them. Beyond the one year retention requirement, assignments, tests and exams may be retained by Schools only so long as there is operational need for them, and then confidentially destroyed by shredding.

ANSWER: To protect individuals’ privacy, students’ work should be collected with adequate supervision and security and should be retained and returned to them with due attention to security. Where possible, return work directly to the student. Do not leave documents for pick-up in a general area where students may see others’ assignments.

ANSWER: It is preferable to write comments and grades inside the cover, not on the front page where others may see them.

ANSWER: Posting a hard copy of grades should be avoided, and instead students should be encouraged to verify their own grades on the Student Information System and/or Learning Management System (e.g. Blackboard). If grades are posted, anonymity must be assured. Grades are the student’s personal information, and the posting of grades in any format that can lead to the identification of an individual (e.g. grade + name +/or student number) would be considered an invasion of their personal information.

ANSWER: Collect only the minimum of information required to facilitate group work. Where group work is an established part of the course, inform students in the course outline that their personal information will be collected and used to develop group work schedules.

ANSWER: Samples of student work which have been rendered anonymous may be used, preferably with the explicit written consent of the student(s). As well, FIPPA has specific information that is required for a research agreement. If conducting research, the policies and procedures of the Office of Research and Planning must be followed. Either Research and Planning or the Research Ethics Board can offer guidance concerning policies addressing research involving human subjects.

ANSWER: Where situations/incidents involve personal information about a member of the St. Lawrence College community, it is understood that the reporting of information shall not violate a person’s confidentiality and that the reporting of the information shall ensure an individual’s right to privacy.

Photographs or video or audio recordings must not be used or disclosed for purposes that were not identified in the original collection notice unless the individuals in the photographs or video or audio recordings have consented to the new use or disclosure.

Caution must be exercised when posting information on websites. Information that may be relatively innocuous when hanging on the wall in a school corridor – such as a student’s or staff name or photograph – may have serious privacy issues when posted on a website. This information, which can be downloaded and combined with other information, may result in a potentially significant invasion of privacy – and potentially lead to significant concerns about personal safety and security.

ANSWER: Yes

FIPPA defines personal information as “recorded information about an identifiable individual”. Where personal information is being collected, FIPPA requires St. Lawrence College to give notice, including the mandate for the collection, the purpose(s) for which the information is being collected, and the name of an individual who can answer questions about the collection. Note that personal information does not include information about one’s business identity; therefore, information about St. Lawrence College’s employees as it pertains to their business identity is not considered to be personal information.

For the most part, personal information can be used and disclosed only with the consent – explicit or implicit – of the individual to whom it pertains. However, it can be disclosed without consent in situations where such disclosure does not constitute an unjustified invasion of privacy. St. Lawrence College has determined that simple attendance on campus does not constitute an unjustified invasion of privacy. Nevertheless, where practical and as a courtesy, it is prudent to ask individuals for their consent, especially where the image or recording may be considered to be more sensitive. Thus, an image of a student walking into the Counselling Department is more sensitive than a student walking into the Library.

ANSWER: With small groups of people, simply ask them. For larger groups, you can make an announcement, post a written notice at the entrance to the place where the event is taking place, or place a notice on a website. The point is to ensure that the notice comes to the attention of the individuals you wish to photograph or record, and then abide by their wishes.

Remember, you do not need to provide notice or obtain consent from St. Lawrence College staff who are acting in their official capacity. However, it is common courtesy to do so.

If photographs or audio or video recordings are going to be stored in an image bank and/or used for another purpose in the future, it is important to obtain written consent. It is essential that the consent form contain a waiver of indemnity and release (i.e. that St. Lawrence College is not responsible for the misuse or alteration of any such photographs/recordings by third parties; that St. Lawrence College and any of its officers, directors, agents, employees or servants are released from any all actions, claims, loss or causes of action arising from the use or misuse of such images; etc.). Depending on the uses contemplated for the photographs/recordings there is additional language concerning indemnity and release that would need to be included – please contact the Freedom of Information Officer for assistance in preparing the waiver.

ANSWER: To support students’ learning, electronic devices and recording of classes may be permitted at the discretion of faculty, and as required by the Ontario Human Rights Code and/or the Accessibility for Ontarians with Disabilities Act. Please also refer to relevant sections of Academic Policy.

ANSWER: FIPPA is retroactive and therefore it is incumbent upon St. Lawrence College to protect the privacy of all personal information in its custody or control. Staff should consider the benefits of obtaining consents retroactively, especially for images on active websites.

I am the Chair of a Selection Committee, what are my responsibilities regarding the resumes of applicants and notes made by Committee members of candidates who were interviewed. 

All interview related documents, including resumes, notes, etc. should be collected at the conclusion of interviews and given to the hiring manager for review and next steps. Upon making hiring decision, manager will forward all materials to HR.

St. Lawrence College may use alumni records to maintain ongoing contact with graduates, and for the purposes of its own fundraising activities if the personal information is reasonably necessary for the fundraising activities and provided that certain steps are followed.

St. Lawrence College maintains contact with graduates via both paper and electronic publications. On graduation, the college alumni office is provided with information on graduating students for this purpose.

Academic Policy and the Acceptable Use for Computing Policy also contain relevant information on this topic.

Staff email messages are considered St. Lawrence College records and may be the subject of an access request under FIPPA.

All staff have an obligation to create records with the expectation that they may be disclosed. Omit unnecessary information; collect and record only the information needed to accomplish a task or meet a requirement. Records should be factual, objective and include only what is relevant. Use humour with caution in written communication – it may not be understood out of context or at a later date. Ensure that records for which circulation should be limited are clearly marked CONFIDENTIAL.

A privacy breach is unauthorized collection, use or disclosure of someone’s personal information, in contravention of the Freedom of Information and Protection of Privacy Act or the Personal Health Information Protection Act. If a privacy breach is suspected or confirmed, immediately report it to your supervisor and the Freedom of Information Officer.