Last Updated: December 1, 2023

Stepped Care Solutions Privacy Statement


This privacy statement explains how Stepped Care Solutions (“
SCS” or “we” or “us”) processes and protects personal information. SCS is a not-for-profit mental health system consultancy group that collaborates with organizations, communities and institutions to support in the training and implementation of the SC2.0 model and for special projects, including the development and provision of mental health and substance use health services.

Accountability for Personal Information

SCS has implemented a privacy program for the protection of personal information that includes policies and procedures to address the following: limiting collection, use and disclosure of personal information to the minimum necessary amount; limiting access to personal information to employees who require access for their role; data breach response and mitigation; data retention and secure destruction of personal information; and a process for responding to privacy-related complaints and inquiries. SCS has appointed a Privacy Officer as the person responsible for oversight of our privacy program. All SCS employees are responsible for compliance with our privacy policies and procedures and are required to protect personal information throughout its lifecycle. Employees undergo privacy training and may be subject to disciplinary action for non-compliance with privacy policies and procedures.

Collection and Use of Personal Information 

SCS collects and uses limited amounts of personal information as a partner in the delivery of Wellness Together Canada (WTC). WTC, which is funded by the Government of Canada, is a portal that provides access to free resources and services for mental and substance use health support. Personal information processed may include an email address, a phone number, limited demographic information, and self-assessment responses and scores. For more information about WTC, please refer to the WTC Privacy Policy.

SCS also collects business contact information about individual representatives and employees of the organizations, communities and institutions we work with and/or have developed a relationship with through events or conferences. This may include name, business email address and phone number, business address and title. This information is used to communicate with these parties if they have agreed to be contacted, and to deliver training through our online learning management system.

In some circumstances, where permitted or required by law, we may process personal information without knowledge or consent. For example, we may be required to use personal information to protect the security or availability of our services, to protect or enforce our legal rights, or to protect the health and safety of individuals.

Disclosures of Personal Information

We only disclose personal information with consent or when required or permitted by law, including in the following circumstances: 

  • in response to court orders or other lawful demands;
  • to protect the security or availability of our services; or
  • to protect the health or safety of individuals. 

In each instance, we share the minimum amount of personal information required. 

Analytics, Cookies and Other Technologies

Web log files, analytics tools, cookies, web beacons and similar technologies may be used to remember user preferences and obtain information about how the website is used.

Web Log Files

Log files are automatically generated records of all website visits and are used to report website trends and identify and troubleshoot issues. Log files include the following information:

  • User’s operating system (example: iOS 12), 
  • IP address,
  • Date and time,
  • Length of the website visit, 
  • Pages and documents accessed, and 
  • Previously accessed website (for example, the search engine that referred the user to the website). 

Analytics Tools

We use Google Analytics to help us measure and understand how our website is used. These tools use cookies and similar technologies to collect certain non-identifiable information, including IP addresses, device or browser types, traffic sources, and activities on the website, such as click rates and bounce rates. To prevent Google Analytics from collecting information about your site use, click here.

Cookies

Cookies are small text files stored on your device that identify your IP address to our servers each time you visit the website. 

You can control stored cookies on your device and turn them off through your web browser. To turn off cookies, follow the instructions found in the “Help,” “Tools,” or “Edit” menus in your browser. Our website depends on the use of certain cookies. If you turn off all cookies, you may be unable to use some website features.

Security

We use reasonable administrative, technical and physical safeguards to protect personal information against theft, loss, unauthorized access, use, modification and disclosure. However, despite our efforts, no safeguards can eliminate all security risks.

Data Retention

We retain personal information for only as long as necessary to fulfil the purposes for which it was collected, and as may be required to comply with applicable law. When personal information is no longer required, we make reasonable efforts to ensure all electronic and hard copies of such information are securely destroyed and irreversibly deleted from our systems in accordance with industry standards. However, if the information has been disclosed to third parties for the purposes described above, they may retain the information according to their own retention policies.

Use of Service Providers and Storage of Personal Information

We use third-party providers of services that handle personal information on our behalf. This includes, for example, our learning management system and customer relationship management system. 

The personal information we process may be stored on servers or otherwise transferred outside of Canada, and as a result, your personal information may be subject to the laws of those jurisdictions and could be accessible without notice to you by the courts, law enforcement and national security authorities of those jurisdictions. Notice to Quebec residents: Your personal information may be transferred outside of Quebec, even if it remains in Canada.

Accessing Your Personal Information

If you would like to request access or make corrections to personal information, please contact the Privacy Office at [email protected]. If you are a WTC user, please refer to Wellness Together Canada | Privacy and Confidentiality for information on how to access your personal information.

Changes to this Privacy Statement

We may update this Privacy Statement at any time. We will notify you by email of any material updates.

For Further Information

If you have any complaints or questions about this Privacy Statement or our personal information handling practices, please contact the Privacy Office at [email protected].