Policy Name: FOIP Privacy Policy
Policy Number: Fin 4.02
Policy Owner: President
Policy Lead: Chief Financial Officer
Policy Authority and Approval Date:
Senior Leadership, November 5, 2019
A. Policy Statement As a public body, Lakeland College is governed by the Freedom of Information and Protection of Privacy (FOIP) Act as well as other federal and provincial legislation. Lakeland College collects Personal Information from students, employees and other members of the Lakeland College Community in order to accomplish its educational mandate. The college is committed to ensuring that reasonable security arrangements are in place to protect personal information against unauthorized access, use, disclosure or destruction. The college supports the public’s right of access to information and will provide access as permitted under the FOIP Act. As a public post-secondary institution, Lakeland College also has a responsibility to provide access to information where required under the legislation, and is committed to openness, transparency and public accountability. B. Scope Statement This policy applies to all Lakeland College Employees. Appendix A outlines specific guidelines for the collection, storage, access and protection of Student Personal Information. Appendix B outlines specific guidelines for the collection, storage, access and protection of Employee Personal Information. C. Definitions Employee: an individual who performs a service for Lakeland College, which includes an appointee, volunteer, student or other individual under a contract or agency relationship. Personal Information: recorded information about an individual, including: a. the individual’s name, home or business address or home or business telephone number; b. the individual’s race, national or ethnic origin, colour or religious or political beliefs or associations; c. the individual’s age, gender, sexual orientation, marital status or family status; d. an identifying number, symbol or other particular assigned to the individual; e. the individual’s fingerprints, other biometric information, blood type, genetic information or inheritable characteristics;
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information about the individual’s health and health care history, including information about a physical or mental disability; g. information about the individual’s educational, financial, employment or criminal history, including criminal records where a pardon has been given; h. anyone else’s opinions about the individual, and the individual’s personal views or opinions, except if they are about someone else. D. Policy 1. Lakeland College will collect, use, disclose, and manage Personal Information in accordance with the FOIP Act, and other applicable legislation. 2. The President of Lakeland College, as the FOIP Head, may delegate the responsibility for managing personal information accuracy, access, collection, use, disclosure and retention to the FOIP Coordinator, as well as other positions according to the delegation table. 3. All Lakeland College Employees are responsible for the protection of personal, confidential and sensitive information entrusted to them. 4. Lakeland College will ensure that all Employees are aware of the FOIP Act and the college privacy policies and procedures, through publications, training seminars and other communication means. Collection of Personal Information 5. The college may collect and record Personal Information only where: a. the collection is expressly authorized by an enactment of Alberta or Canada, b. the information is collected for the purposes of law enforcement, c. the information relates directly to and is necessary for an operating program or activity of the college. 6. The purpose of collection shall be clearly stated at or before the information is collected. A FOIP notification statement must be provided at the time the information is collected and be approved by the FOIP Coordinator. The FOIP notification statement must include the following: a. the purpose for which the information is collected; b. the specific legal authority for the collection; and c. the title, business address and business telephone number of the college Employee who can answer questions about the collection. 7. Personal Information shall be collected directly from the individuals, unless otherwise authorized under the FOIP Act, such as where the individual has expressly authorized another method of collection or where an individual is providing emergency contact information. 8. Every effort will be made to ensure that the information collected is accurate and complete. Individuals have a right to request correction to their own Personal Information.
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9. Where Personal Information is handled and/or collected a privacy impact assessment must be conducted by the FOIP Coordinator prior to: a. implementation of a new technology or system that handles or collects Personal Information; b. change to a technology or system handling or collecting Personal Information; c. changing from a traditional to an electronic service delivery program; or d. issuing a new or updated rule/guideline that affects Personal Information. 10. Personal information banks of all Personal Information housed at the college shall be kept as required by the FOIP Act. Personal information banks (PIBs) are descriptions of personal information under the control of Lakeland College that is organized and retrievable by an individual's name or by a number, symbol or other element that identifies that individual Use of Personal Information 11. Personal Information will only be used: a. for the purpose for which the information was collected or compiled or for a use consistent with that purpose; b. for statistical or research purposes according to the requirements set out in s. 42 of the FOIP Act; c. where the individual for which the information is about has consented in the prescribed manner, as described below, to the specified use; or d. where the use has been authorized by the Dean/Director/Registrar or the FOIP Coordinator, following the rules outlined in the FOIP Act (s. 40, 41, 42). 12. The college will only use the Personal Information to the extent necessary to enable the college to carry out its operating program or activities in a reasonable manner. Right of Access 13. Individuals have the right of access to their own personal information. This right is subject only to the limited exceptions in the FOIP Act. This right of access does not include the right to remove or destroy information contained in a file. 14. Third parties also have a general right of access under the Act. The college will provide access to information only in accordance with approved policy and procedures, and in compliance with the FOIP Act. 15. The college will strive where feasible to make information available without having to submit a Formal Information Request. Individuals have a right to make a Formal Information Request under the FOIP Act, which can be submitted in accordance with the Access to Information Procedure Fin 4.03.
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Disclosure of Personal Information 16. Personal Information will not be released to third parties and will only be disclosed where consistent with the purpose for which it was collected, except with the informed consent of the individual, or under the limited exceptions in the FOIP Act. 17. Personal Information is only disclosed to other Lakeland College Employees on a “need to know basis”. The information may only be disclosed where necessary for the performance of the duties the Employee was hired to perform. 18. Certain Personal Information collected by the college is disclosed to specific third parties in order to comply with provincial and federal law and to facilitate routine college operations. Examples include but are not limited to the following: Students’ Association of Lakeland College, Alumni Association of Lakeland College, Alberta government ministries and to the Canadian federal government. Informed Consent 19. Where an individual has provided consent to disclose the information, the Informed Consent must be in the proper form: a. individual has identified the information that is being consenting to b. indicates to whom the Personal Information may be disclosed c. how the Personal Information may be used; and d. signed written consent 20. Informed Consent will generally be written; however, electronic and oral consent may be allowed in certain circumstances, where prior approval by the appropriate Dean/Director/Registrar has been given and the following conditions have been met: a. Where electronic consent is obtained i. a record of consent will be retained as per Lakeland College’s Retention Schedule, ii. the record of consent is accessible for future reference and use, and iii. contains a reliable electronic signature that authenticates the identity of the user b. Where oral consent is obtained i. a record of the consent will be created, ii. the record of consent is accessible for future reference and use, iii. will be retained as per Lakeland College’s Retention Schedule, and iv. the consent reliably authenticates the identity of the user Security and Disposal 21. Personal Information will be maintained only as long as necessary to fulfill the purpose for which it was collected according to the college’s Records Retention Schedule. Personal Information used to make a decision on an individual must be retained for a minimum of one year.
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22. Personal Information authorized for destruction must be safely and securely destroyed: a. Electronic records should be properly deleted/erased in accordance with the Electronic Media Disposal Standard (IT 9.65). b. Paper records containing Personal Information should be shredded in a cross shredder or placed in a secure shredding bin. 23. Employees will safeguard personal information and take all reasonable steps to protect this information by following all Lakeland College Policy & Procedures, in particular, but not limited to: Access to Information Procedure (Fin 4.03), Records Retention (Gen 8.73), Social Media Policy (Gen 8.89), Security of Student Information (STU 5.80), Information Technology Security Policy (IT 9.50), and Electronic Media Disposal Standard (IT 9.65). Privacy Breach 24. A privacy breach occurs when personal information is collected, retained, used or disclosed in ways that are contrary to the provisions in the FOIP Act. If a privacy breach occurs the Employee must immediately notify their direct supervisor and the FOIP Coordinator. Where the risk involves a breach of electronic data, the Director of Information and Technology should also be immediately notified. 25. The college will take the following steps to respond to a Privacy Breach: a. Contain and minimize the breach b. Evaluation of the impact of the breach, c. Notification of individuals if required, and d. Prevention to preclude occurrence of similar breaches in the future. 26. The FOIP Coordinator will notify the President and immediately conduct an internal investigation of any breaches assessed at a high risk. The FOIP Coordinator will assess whether notification to third parties and the Office of the Information and Privacy Commissioner is required. Training 27. The FOIP Coordinator will provide relevant FOIP training and support to employees.
Policy Acknowledgment 28. All Lakeland College employees must sign the Code of Conduct Acknowledgment Form (HR 2.04-1) confirming the Employee’s responsibility with respect to confidential information. 29. Each employee who has access in the course of their work to Personal Information shall be asked to sign an acknowledgment that they have read and understood this policy. Any questions about this policy can be directed to the FOIP Coordinator.
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E. Related Policies/Procedures Access to Information Procedure (Fin 4.03) Correction to Personal Information (Fin 4.04) (“approval in progress”) Code of Conduct (HR 2.04-1) Records Retention (Gen 8.73) Social Media Policy (Gen 8.89) Information Technology Security Policy (IT 9.50) Electronic Media Disposal Standard (IT 9.65) F. Relevant Legislation Freedom of Information and Protection of Privacy Act Health Information Act Post-Secondary Learning Act G. Related Forms/Documents Request to Access Information Form Code of Conduct Acknowledgment Form (HR 057) Informed Consent for Disclosure of Personal Information (TLC 014) Retention Schedule
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Appendix A FOIP - Student Personal Information Policy Definitions Student Academic Record: contains documentation from the initial application to graduation, such as application, official transcripts, name change requests etc. Student Personal Information: recorded information about an identifiable individual. Student Personal Information may include, but is not limited to name, maiden name/other name, address, telephone, gender, marital status, birth date, social insurance number, citizenship information for non-Canadians, financial aid records, previous educational and/or employment background including academic records, letters of referral and location of activity, medical history, fees assessed and paid to Lakeland College, correspondence generated by the college to the student regarding academic standing or disciplinary action taken, anyone else’s opinions about the student, and the student’s personal views or opinions, except if they are about someone else etc. Collection, Storage and Accuracy of Student Records 1. Lakeland College is committed to establishing and maintaining strong effective mechanisms to protect the privacy of our students. All employees of Lakeland College with access to Student Personal Information are required to maintain the confidentiality of student records. 2. Student Personal Information is collected under the authority of the Post-Secondary Learning Act and the FOIP Act and is used in the normal course of operations in accordance with this legislation. The information is used for recruitment, admission, enrolment, academic programs, evaluations, official document requests, financial aid and awards, assisting student associations and graduation and other Lakeland College academic programs and services. 3. The Registrar’s Office is responsible for the collection of Student Personal Information and storage of the official Lakeland College Academic Student Record. Academic and operations departments may also collect and store Personal Student Information.
4. Changes and updates to Student Personal Information are done upon notification to the Office of the Registrar and in accordance with the Correction to Personal Information Procedure Gen 8.91 (“Approval in Progress”). Access to Student Records 5. No information regarding a student’s status or Student’s Academic Record will be released by an individual, besides the Registrar’s Office. 6. Student Personal Information is not shared within or between other Departments except where consistent for the purpose for which the information was collected, and where the information is necessary for the performance of the employee’s duties. Disclosure is limited to a “need-to-know” basis and the minimum personal information necessary will be disclosed. Examples, of where such information may be disclosed include:
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a. a class list containing student’s name, email address, program and student I.D. provided to the instructor for their confidential use. This information must be securely destroyed at the end of the semester, b. to a faculty member coordinating a student's program, c. to an individual serving on committees of selection or appeals, d. the Awards Office for the purpose of awards selection. 7. Access and use of student information for research purposes must meet the conditions outlined in the FOIP Act and Lakeland College's research policies and procedures. 8. For the exception of the limited exceptions under the FOIP Act, Student Personal Information will not be disclosed to a third party without informed written consent. For example, reference information may only be disclosed to a potential employer with the consent of the student. Similarly, financial aid information may only be disclosed to a parent with consent. Examples of limited exceptions where disclosure may be made without consent include, but are not limited to: • • •
•
disclosure to law enforcement; to a collection agency for the purpose of collecting a Lakeland College fine or debt; government agencies to comply with an agreement, Act or Regulation. In the normal course of operations, Student Personal Information is shared with the federal government and government of Alberta for statistical purposes. Similarly, The Financial Aid Office also provides confirmation of enrollment, withdrawal and full/part-time status to funding agencies; Certain Student Personal Information may also be disclosed to the Students’ Association, Alumni Association or another public body that offers a common integrated program or service.
These disclosures must be properly authorized by the Registrar or other authorized individuals under the FOIP delegation table. 9. When training service is being provided to a client organization on a contractual basis and no individual tuition fee applies, information from the student’s record may be reported back to the client organization where authorized by the terms of the contract. Other sponsors require a release to receive the information. 10. The following Student Personal Information is presumed to be a matter of public record that may be shared with a third party without consent. a. Confirmation of enrollment or registration in the college or in a Program (does not include confirmation of attendance); b. Participation or attendance at a public event or activity related to the college, such as a graduation ceremony, sporting event, cultural program, club event or field trip; c. Confirmation of a diploma, certificate, or degree, honour or award received by or through the college.
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Students have the right to request that this information not be disclosed. The release of this information should only be done under the authority of the Dean/Director/Registrar or the FOIP Coordinator and where disclosure is not deemed contrary to the public interest. 11. Student Health Records and student Counselling Records are held by the Health and Counselling Offices respectively. These records are only released with written consent, or for health and safety reasons as required by law. Health Records in the custody of the Health Office are subject to the rules under the Health Information Act. 12. Student may access their personal health and counselling records by making a request to the appropriate office.
Access by an Individual to their Personal Information 13. Students are permitted access to their own personal information, subject to only a few limited exceptions under the legislation. Students wishing to review the contents of their official Academic Student Record should contact the Office of the Registrar. 14. Students have a right to request correction to their own personal information, which in most cases can be handled through an informal process. Students also have the right to make a formal request to correct their personal information under the FOIP Act (see Correction to Personal Information Procedure Fin 4.04 “Approval in Progress’).
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Appendix B FOIP - Employee Personal Information Policy Collection, Storage and Accuracy of Employee Records 1. Employee personnel files are housed in Human Resources. 2. As a general principle, personal documents belonging to employees should not be stored on the Institution premises. Employee’s personal documents stored on college premises are under the custody of the college and, therefore, may be subject to access under the FOIP Act. 3. If the records of an employee relate to the operational functions of Lakeland College, then the records are the property of the college and are covered by the Act. The records remain the property of the college even where these records are stored off-site or on personal devices. Access to an Employee’s own Records 4. Employees are permitted access to their own personal information, subject to only a few limited exceptions under the legislation. An employee may make an appointment through the Human Resources Office to view his/her personnel file. 5. All written information pertinent to a grievance proceeding will be made available to the appropriate parties. In determining pertinence, the college shall consider all relevant circumstances as identified in the Freedom of Information and Protection of Privacy Act. Access to Employee Records by Third Parties 6. Where an outside caller is attempting to locate an individual within the college, the name of the department and the telephone extension of the individual may be given, but no personal information may be disclosed. 7. When an individual is hired by the college certain information is presumed to be a matter of public record and may be disclosed to third parties without consent, at the discretion of the Dean/Director: • Employment status • Business – address, telephone number, email address • Job title, job profile • Classification • Salary range • Relevant education qualifications • Attendance at a public event or activity related to the college (e.g. graduation, sporting, or cultural event) • Personal information already in the public domain
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8. Certain information such as emergency contact information, performance appraisals, attendance records and disciplinary information is generally accessible to supervisors where a “need to know� basis has been established. 9. For the exception of the limited exceptions under the FOIP Act, Employee Personal Information will not be disclosed to a third party without informed written consent. 10. Under the authority of the Director of Human Resources, certain employee information, may be shared within the college where necessary for administering or managing Lakeland College staff. 11. The college is required to provide information to the federal and provincial Governments for purposes such as taxation and statistics. Statistical data, in which individuals are not identifiable, may be provided in response to other external requests. 12. The college provides personal information for the administration of the employees’ benefits programs to the trustee of the pension plans and to the insurance company which administers the benefits programs.
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ACCESS TO INFORMATION PROCEDURE Finance – Procedure 4.03
GENERAL STATEMENT: Lakeland College is committed to openness, transparency and public accountability. As a public postsecondary institution, the college must comply with the Freedom of Information and Protection of Privacy (FOIP) Act. The college supports the public’s right to access information and where appropriate will actively disseminate information and provide access by way of routine information requests. The college also recognizes an individual’s right to access their Personal Information. Most information can be obtained directly from the college without submitting a formal FOIP request. This right of access is restricted only by the limited exceptions and provisions in the FOIP Act and other legislation. This procedure relates to FOIP Privacy Policy FIN 4.02 and applies to all Lakeland College employees who have a responsibility to provide appropriate access to information following the rules set out in the FOIP Act. Appendix A provides additional guidance and examples of access to student Personal Information, while Appendix B relates to employee Personal Information. DEFINITIONS Active Dissemination - manner of dissemination where information is periodically released without a Formal Information Request. Examples include information released in a newsletter or on the college website. Applicant - The individual who submits a Formal Information Request. Consent - Consent given freely in a prescribed manner and with full knowledge of the Personal Information to be provided and the use to be made of such information. Delegated FOIP Authority - an employee or officer within the college that has been authorized by the FOIP Head (the President of Lakeland College) to carry out certain powers or duties under the FOIP Act, as delegated in the FOIP Delegation Authority Matrix. Formal Information Request - A formal request for information under the FOIP Act. Personal Information - Recorded information about an individual, including: i. the individual’s name, home or business address or home or business telephone number; ii. the individual’s race, national or ethnic origin, colour or religious or political beliefs or associations; iii. the individual’s age, gender, sexual orientation, marital status or family status; iv. an identifying number, symbol or other particular assigned to the individual; v. the individual’s fingerprints, other biometric information, blood type, genetic information or inheritable characteristics; Mission: To inspire lifelong learning and leadership through experience, excellence and innovation. Vision: Transforming the future through innovative learning. Values: We value learner success, integrity, respect, community, excellence and innovation.
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information about the individual’s health and health care history, including information about a physical or mental disability; vii. information about the individual’s educational, financial, employment or criminal history, including criminal records where a pardon has been given; or viii. anyone else’s opinions about the individual, and the individual’s personal views or opinions, except if they are about someone else. Routine Disclosure: Response to a routine inquiry or request, where access to a record can be granted without a Formal Information Request under the FOIP Act. PROCEDURE Active Dissemination 1. Records that contain public information, such as approved Board policies, strategic plan, news releases etc. can be actively disseminated through the college website, printed materials, social media forums and other methods of communication. 2. Personal or business information should be severed, unless consent has been obtained or disclosure is authorized under the FOIP Act. 3. Departments should coordinate the dissemination of this information with the Marketing and Communications Department and ensure all communication policies and procedures are complied with. 4. Access to manuals, handbooks or guidelines used in the decision-making process in administering or carrying out programs or activities of the college will be made available for viewing on request.
Routine Disclosure 5. Where feasible, Lakeland College will attempt to provide Routine Access to records. The following factors will be used to assess whether the information can be provided routinely, without filing a Formal Information Request: a. the disclosure is authorized or required by another piece of legislation, b. the information is publicly available, c. the disclosure contains only the individual’s personal information (i.e. does not contain any third-party information and no FOIP exceptions identified in (d) apply), d. no other FOIP exceptions apply to the records. Examples of these FOIP exceptions include but are not limited to: confidential business information; other third-party information; information related to law enforcement; planning, advice or recommendations; and information subject to legal privilege. 6. Details of the Routine Disclosure should be properly documented in the appropriate file(s). 7. The FOIP Act authorizes disclosure but does not require it. Employees have a duty to confirm the authority of individuals requesting Personal Information and to confirm their identity. For example, a. Where phone calls from individuals requesting their own Personal Information are received, information confirming the identity of the caller should be requested. b. Where a third party, such as a bank, requests personal information, written proof of consent should be provided by the third party. c. Where a government official requests information, the section in the legislation authorizing the disclosure, as well as the identity of the government official should be confirmed. Mission: To inspire lifelong learning and leadership through experience, excellence and innovation. Vision: Transforming the future through innovative learning. Values: We value learner success, integrity, respect, community, excellence and innovation.
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8. A Department under the authority of the Dean/Director may routinely disclose information in the following circumstances: a. where necessary for the performance of duties of an employee of the college, b. where the information was collected or compiled or for a use consistent with that purpose, c. where consent was obtained in the prescribed manner, d. the information requested is the individual’s own Personal Information and the information does not contain any other third-party Personal Information or other sensitive information (see sec. 5(d) above), e. the request relates to a specific type of record where disclosure is explicitly authorized by a college policy or procedure (e.g. a student can access their student transcript). In all other cases, the FOIP Coordinator should be consulted. 9. In all cases, only the information necessary to respond to the request should be released. 10. If a request cannot be met by Routine Disclosure it may be necessary to file a Formal Information Request. The request should be forwarded to the attention of the FOIP Coordinator who will then determine whether the access request can be done through Routine Disclosure or whether a Formal Information Request is required. Formal Information Requests 11. Access to information that is not disclosed through Active Dissemination or Routine Disclosure must be submitted through a Formal Information Request in writing, accompanied by the appropriate fees, prescribed by the FOIP regulations. 12. All Formal Information Requests must be forwarded immediately to the FOIP Coordinator. The FOIP Coordinator will advise the FOIP Head (the President) that a request has been received. 13. The FOIP Coordinator will assist the applicant with: a. clarifying the request and timeline, b. coordinating the search for responsive records, and if appropriate provide a fee estimate to the applicant, c. review and redact responsive records in accordance with specific and limited exceptions in the FOIP Act, and d. log all FOIP requests from the date of receipt to the close of the file. 14. Each department will appoint a contact person who will assist with the search for responsive records within their respective department. 15. Where a formal Information Request is in process, no record including transitory records may be destroyed. 16. In consultation with the FOIP Coordinator, the President (FOIP Head) will review the request, the responsive information, and the recommendations for the release of the information. 17. Costs associated with handling access requests may be charged but cannot exceed the costs set out in the FOIP Regulations.
Mission: To inspire lifelong learning and leadership through experience, excellence and innovation. Vision: Transforming the future through innovative learning. Values: We value learner success, integrity, respect, community, excellence and innovation.
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APPENDIX A Routine Access to Student Records Requests for Student’s own Information 1. Where a request is received by a student for their own Personal Information. The following information may be routinely disclosed: ▪ the portion of the student file that is deemed to be routinely accessible ▪ information supplied by the student ▪ information copied to the student ▪ consent obtained in the prescribed form authorizing the disclosure to the student 2. Requests for graded assignments and exams should be made directly to the Instructor. Requests from Lakeland College Employees and Contractors 3. The FOIP Act permits the disclosure of certain information to other Lakeland College employees, such as to instructors where necessary for the performance of their duties. Only the minimal amount of information required should be disclosed. ▪ Examples of information that would normally be available to instructors include student IDs, and student contact information. 4. Disclosure of personal information to a Lakeland College contractor should only be made as authorized by the terms and conditions of the written contract. Requests from Third Parties 5. Student Personal Information should only be disclosed to Third Parties in the following circumstances: a. Consent has been obtained in the prescribed form; or b. The information is limited to the following and the disclosure has been authorized by the Registrar (i.e. determined not to be contrary to the public interested and the individual has not specifically requested that this information not be disclosed): i. Confirmation of enrolment or registration in the college or in a Program (does not include confirmation of attendance); ii. Participation or attendance at a public event or activity related to the college, such as a graduation ceremony, sporting event, cultural program, club event or field trip; iii. Confirmation of a diploma, certificate, or degree, honour or award received by or through the college; or c. The information is requested by a government official where disclosure is authorized or required by a piece of legislation and the disclosure has been approved by the Registrar; or d. In all other cases please consult with the FOIP Coordinator. 6. The following types of records should not be routinely disclosed and should be forwarded to the FOIP Coordinator as the request may have to go through a Formal Information Request: ▪ letters of reference supplied in confidence ▪ evaluative comments provided by anyone in a formal evaluation process ▪ records relating to a grievance or appeal process ▪ records relating to a legal or an administrative investigation ▪ letters of complaint Mission: To inspire lifelong learning and leadership through experience, excellence and innovation. Vision: Transforming the future through innovative learning. Values: We value learner success, integrity, respect, community, excellence and innovation.
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APPENDIX B Routine Access to Employee Records Requests for Employee’s own Information 1. The following employee information may be Routinely Disclosed by the Human Resources Department: a. the employee file b. information supplied by the employee, c. information copied to the employee, d. performance evaluations (any identifying information other than by the supervisor should be severed) e. with consent obtained in the prescribed form authorizing the disclosure to the employee. 2. The following types of records should not be Routinely Disclosed and should be forwarded to the FOIP Coordinator as the requests may have to go through a Formal Information Request: a. Letters of reference supplied in confidence, b. documents relating to a grievance or appeal process, c. documents relating to legal or administrative investigations, d. letters of complaint unless the author has consented to the disclosure, e. evaluative comments, not by the supervisor. Requests from Third Parties - Lakeland College Employees 3. Limited information may be disclosed to other Lakeland College employees, such as the employee’s supervisor where necessary for the performance of their duties. Only the minimal amount of information required should be disclosed. ▪ Examples of information that would normally be accessible to a supervisor include: performance evaluation, employee number, information about the employee’s service, salary, vacation leave and sick leave statistics, and attendance information. 4. Disclosure of Personal Information to a Lakeland College Contractor, such as Blue Cross should only be released as authorized by the terms and conditions of the contract. Requests from Third Parties - Other 5. The following types of records can be Routinely Disclosed at the discretion of the Director of Human Resources: a. specifications, manuals and guidelines (should be routinely available for viewing by the public); b. training material; c. Job descriptions and organizational charts (personal information should be severed – i.e. salary, appointment history. Employee ID should not be released where connected with an employee name). d. Working hours for a position (not for a specific employee); e. Severance or separation allowance formula; f. General information about benefits; g. Job profile and description of ideal candidate; h. Advertising material, expenditures on advertising and media strategy; i. Names of screening or selection panel members, including job titles; j. Candidate rating and ranking (all personal information such as names must be severed); k. Confirmation that references have been contacted _______________________________________ Implementation Date: December 18, 2019 Latest Revision Date: January 17, 2020 Mission: To inspire lifelong learning and leadership through experience, excellence and innovation. Vision: Transforming the future through innovative learning. Values: We value learner success, integrity, respect, community, excellence and innovation.
