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Policies

TERMS OF SERVICE

Your privacy is important to us. Calls may be recorded for quality control training. Harmful or abusive language may result in your interaction being terminated and your access to the service being restricted. We encourage respectful behaviour during all interactions.

Please Note: Failure to abide by this policy may result in your interaction being terminated.

PRIVACY POLICY

  1. Our Commitment and Approach

The Distress Centres of Greater Toronto (“DGCT”, “we”, “our”, or “us”) is committed to protecting personal information in a manner consistent with fair information principles, including the CSA Model Code for the Protection of Personal Information. Our privacy program is designed around those principles and is administered in a manner appropriate to applicable legal requirements for our services. We will not share your personal information, except as required by law, to protect life and safety, or as otherwise described in this Privacy Policy. We maintain physical, organizational, and technological safeguards to protect your information.

  1. Application of this Policy

This Privacy Policy applies to all personal information we collect, use or disclose in connection with our services and programs (in person, digitally, online, or offline). The term “personal information” means information about an identifiable individual; it does not include de-identified or aggregated information that cannot reasonably be associated with an identifiable individual. 

If we refer you to other organizations or direct you to third party resources, this Policy does not apply to those interactions, and DCGT is not accountable for those interactions.

  1. Identifying Purposes

We collect, use, and disclose personal information for the following purposes:

  • to provide services, such as crisis and distress support, survivor support, and our outbound monitoring programs.
  • to assess and respond to risk and conduct safety checks.
  • to supervise, coach, and support staff and volunteers.
  • to ensure quality, training, and service improvement.
  • to manage and secure our platforms and prevent abuse.
  • to conduct research and reporting (with de-identified or aggregated information).
  • to communicate with you about our services; and
  • to meet legal, regulatory, audit, and risk management obligations.


When you call our inbound distress phone lines, you are not required to provide your name in order to receive our services, but some of the information we learn could result in us being able to identify you. For continuity of service, we record some details about our interactions with you, including your phone number, in a secure database.

DCGT also collects personal information from employees, volunteers, and individuals applying for employment or volunteer positions for purposes such as recruitment, administration, payroll, benefits, volunteer coordination, legal and regulatory compliance, and internal operations.

  1. What We Collect

We collect the minimum personal information reasonably necessary to fulfill the purposes identified above. This may include:

Contact and Identification Information:

  • Name (or preferred name/alias, where you choose to provide one)
  • Telephone number(s), including caller ID (even where the number is blocked, see Automatic Unblocking of Telephone Numbers below) and call-back numbers
  • Email address
  • Mailing address or general geographic location
  • Emergency contact information (where voluntarily provided or necessary for safety purposes)
  • Preferred language and communication preferences
  • For job or volunteer applicants; employment, educational background and Vulnerable Sector Check results


Interaction and Communication Records:

  • Content of calls, texts, emails, or other communications with our staff and volunteers
  • Voicemail messages
  • Date, time, duration, and frequency of contacts
  • Call queue and routing information
  • Health related information (to the extent shared)
  • Case notes documenting the nature of the interaction and any follow-up actions (e.g., nature and severity of distress or crisis, emotional state, coping strategies discussed, referrals made)
  • Safety and risk information
  • Recordings of calls or text sessions


For Survivor Support Services:

  • Type of trauma or victimization experienced (at a level of detail you choose to share)
  • Support needs and goals
  • Referrals to community resources, legal services, or healthcare providers
  • Advocacy and accompaniment records


For Outbound Support Calls:

  • Agreed schedule and frequency of check-ins
  • Wellness status and responses during check-ins
  • Missed check-in records and follow-up actions
  • Emergency contact and escalation instructions
  • Location information (where voluntarily provided for safety purposes)


For Medication Reminders:

  • Preferred reminder schedule and timing
  • General medication information (e.g., medication name, dosage schedule) sufficient to provide the reminder service
  • Confirmation of reminder receipt or acknowledgment
  • Missed reminder records and any follow-up actions
  • Healthcare provider’s contact information (where voluntarily provided for escalation purposes)


Technical and Device Information:

  • Telephone number and telecom carrier
  • IP address and general geolocation (derived from IP)
  • Device type, operating system, and browser (for online services)
  • Session identifiers and authentication information (for account-based services)
  • Website cookies and analytics data


Demographic Information

  • Age or age range
  • Gender identity and pronouns
  • Cultural, ethnic, or linguistic background
  • Geographic region (e.g., urban, rural, northern community)
  • Other demographic details voluntarily provided to help us improve equitable access and service quality

  1. Use, Disclosure, and Retention

We use and disclose personal information only for the purposes identified above or where applicable law permits or requires it.  We take reasonable steps to ensure that we only use or disclose the minimum personal information necessary for the specific purpose and circumstances.

We may anonymize your information and use it for evaluating, planning, and improving our services. Anonymized information is information that does not identify you or anyone else and cannot reasonably be used to do so. We use various methods and safeguards to anonymize information, such as removing or encrypting personal identifiers, aggregating data, and applying statistical techniques.

We may disclose information to third parties with your consent, or where we are permitted or required by law to do so.  For example, if we are concerned about a risk of harm, we may need to take steps to ensure your safety or the safety of others, such as reaching out to emergency responders or appropriate authorities. If we need to share your information, we will involve you in the process as much as possible.

We may also use or disclose information to manage threats, abuse, or attacks on our responders or systems and may restrict access to services where it is necessary to protect safety and service integrity.

We retain personal information only as long as necessary to fulfill the purposes for which it was collected and to meet legal or operational requirements. The retention periods for personal information vary, depending on the services at issue, legal obligations, and our reporting requirements. At the end of the retention period, the data is de-identified, aggregated, or securely destroyed using safeguards appropriate to the sensitivity of the information.

  1. Automatic Unblocking of Telephone Numbers

When you contact us by telephone, our systems will automatically remove any caller ID block that you have initiated. We collect and use this information to promote safety of callers and our staff. For example, we may share the number with emergency responders if there is a risk of harm to you or others, or we may use it to manage abusive treatment towards our staff.

  1. Monitoring and Quality Assurance

We record all calls for safety, quality assurance, and training purposes. Authorized supervisors have access to these recordings.  These recordings are reviewed if there are complaints or issues arising from a call, or for training purposes to improve our service delivery. These recordings are stored in a secure location and retained only as long as necessary for those purposes.  You can request that we do not use your recorded call(s) for training purposes.

  1. Consent and Your Choices

We seek meaningful consent for the collection, use, and disclosure of personal information, except where consent is not required or permitted by law. Where capacity is in question, we take a contextual approach to assess meaningful consent and use the least intrusive means to promote safety. 

Consent may be express (for example, where you request monitoring or call-backs) or implied (for example, when you elect to share information during a conversation so we can respond).

You may withdraw consent at any time by contacting our Privacy Officer, subject to legal or operational requirements and reasonable notice. A withdrawal of consent is not retroactive and applies only going forward, and it may limit our ability to provide services or conduct safety checks in urgent circumstances.

  1. Service Providers and Cross-Border Transfers

We transfer personal information to third party service providers (including telecommunications, cloud hosting, analytics, and security vendors) who support our services. We require these providers to protect personal information with appropriate safeguards and to process it only for our purposes under contractual obligations. We require our service providers to store personal information in Canada. But some providers may be located outside your province or Canada; as a result, your information may be subject to the laws of those jurisdictions and accessed by courts, law enforcement, or regulators in those places. We take steps to assess and mitigate privacy and security risks related to cross-border processing.

  1. Accuracy

We take reasonable steps to keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

  1. Safeguards

We follow industry standards to safeguard personal information. These standards include administrative, technical, and physical measures appropriate to the sensitivity of the personal information, including access controls and role-based permissions; staff and volunteer screening, training, and confidentiality agreements; secure network architecture; encryption of data in transit and at rest where appropriate; logging and monitoring; and structured incident response procedures. We regularly review safeguards and adjust them to address evolving risks.

  1. Access and Correction

On written request and after we verify your identity (and authority, where applicable), we will inform you of the existence of your personal information and provide access to it, subject to limited exceptions (for example, where access would reveal another person’s personal information, compromise safety, or be subject to legal privilege). You may also request corrections to your personal information, and we will amend or annotate records as appropriate. 

Our Privacy Officer will reply in writing to a request for access or correction no later than 30 days after the date the request is received. We will explain the reasons for any refusal and describe any available recourse.

Access to your personal information will be provided at no cost or for a minimal fee. If a fee applies, we will provide an estimate in advance and obtain your agreement before proceeding. The fee will depend on the format and volume of the records requested.

  1. Challenging Compliance and Complaints

You may raise questions or complaints about our compliance with this Policy by contacting our Privacy Officer using the details below. We will investigate and respond in a timely manner and will take appropriate steps to address substantiated concerns, which may include updating our practices or providing additional training.

  1. Websites, Cookies, and Online Analytics

If you visit our websites or use our online services, we and our service providers may use cookies and similar technologies to operate the site, remember preferences, measure traffic and usage, and improve user experience. You can manage cookies through your browser settings; however, disabling cookies may affect site functionality. Where we use analytics tools, we do so to generate aggregated statistics and not to identify individuals, unless you are signed into an account-based feature you have chosen to use.

  1. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices, technologies, or legal requirements. We will post changes and update the effective date. Your continued use of the services following any update indicates acceptance of the revised Policy.

  1. Contact for Privacy Matters

To ask questions, exercise your rights of access or correction, withdraw consent, or submit a privacy complaint, please contact our Privacy Officer at:

privacy@ dcogt.com ; or by mail at:

Privacy Officer
Distress Centres of Greater Toronto
Box 243, Adelaide P.O.
Toronto, Ontario, M5C 2J4

We will investigate complaints and take appropriate steps.

EXTERNAL COMPLAINT POLICY

This policy applies to complaints (“Complaints”) received from individuals who are not affiliated with DCGT (i.e., not Staff, Volunteers, Management, or Directors). We value all feedback and are committed to handling Complaints fairly and professionally.

Process for Handling Complaints:

Referral:

Upon receipt, Complaints are directed to the appropriate Staff member, usually the relevant Program Manager.

Response:

 The Staff member will:

  • Log the Complaint and document all actions taken.
  • Conduct a reasonable investigation into the matter.
  • Take steps to address the issue and prevent similar incidents.
  • Contact the complainant (if contact information is provided) to confirm actions were taken and, where appropriate, explain those actions.


Timelines:
 

  • Complaints will be logged, investigated, and responded to (if applicable) within 7 days of receipt.
  • In rare cases requiring more time, the Complaint must still be logged and the investigation initiated within 7 days, with an estimated timeline provided for full resolution.


Escalation:
 

  • If either the complainant or the subject of the Complaint is dissatisfied with the response, the matter will be escalated to the Executive Director.
  • The Executive Director may consult others at any stage as needed.


Oversight:
 

The Executive Director will regularly review all logged Complaints to identify and address any recurring issues or trends.

Accessibility: 

Information about how to submit a Complaint, along with an outline of this process, will be made readily available, including on the DCGT website.

CALLER & COMMUNITY FEEDBACK PROCEDURES

DCGT is committed to listening to our community. You can share your feedback with us in any of the following ways:

  1. Email: Send your comments to info@dcogt.com. Please include “FEEDBACK” in the subject line.
  2. Phone: Call our feedback line at 416-486-3180 and leave a message. If you request a response, we will reply within one week. Be sure to include your contact information if you’d like to hear back from a staff member.
  3. Mail: Send written feedback to the address below. Please note that responses to mailed comments may take up to four weeks:

    Distress Centres of Greater Toronto
    Box 243, Adelaide P.O.
    Toronto, Ontario, M5C 2J4 

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