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Privacy policy

Document Version:

Last Update: June 23, 2022

Version: 0.84

Questions about this document should be directed to [email protected]

Our commitment to privacy and confidentiality

Kids Help Phone is committed to protecting the confidentiality and privacy of the personal information and/or personal health information of its donors, employees, service delivery partners, service users (texting and counselling), service users of our website and Resources Around Me, peer-to-peer service users, website users (including chatbot micro-service users), volunteers (including Crisis Responders), and board members, collectively referred to as stakeholders. As part of that commitment, we have implemented this Privacy Policy. This policy applies to full/part time permanent or contracted employees, volunteers, contractors, consultants, temporary employees from agencies, and all personnel affiliated with third party service providers; hereinafter referred to as associates.

Personal information and personal health information are highly sensitive, and are collected under implied consent.

Scope

This policy sets out Kids Help Phone’s commitment to privacy. It governs all of its services and interactions with stakeholders: in-person, digital, online, or off-line. Kids Help Phone offers professional counselling; an interactive, personalised web experience; information; referrals; and volunteer-led, text-based support to young people in English and French, and we also facilitate voice translation by third parties. Services are provided for youth of any age living in Canada. Our volunteer-led, text-based service is also available to adults living in Canada, and we comply with all applicable Canadian laws. Kids Help Phone does not offer services outside of Canada.

Kids Help Phone does not require users to identify themselves; however, information collected may include identifying information. Kids Help Phone will deal with all information as private, privileged, and confidential. Kids Help Phone has an Information Security policy, stipulating various protection mechanisms, which governs all information under its custody and control. Kids Help Phone hosts its own services directly, via third party service providers, or on the cloud. Information may also be stored on mobile devices managed by Kids Help Phone, or on devices owned by associates. All associates agree to this Privacy Policy, to an internal Terms of Use, and to Kids Help Phone security policies. This Privacy Policy includes application-specific privacy notices, and Terms of Use.

Kids Help Phone leverages third-party tools such as Facebook, Microsoft Power BI, and Twilio, to support service users. Each of these third-party tools has its own Privacy Policy and Terms of Service. It may not be reasonable to expect that all service users will comprehend the various types of data processing, which include data collection, retention, use, and disclosure.

Kids Help Phone is transparent about its data uses. When we receive a request about the data practices of a third party, we will redirect the question to the respective privacy contact information of that service provider. Kids Help Phone cannot take responsibility for defending or representing such third-party providers. As well, Kids Help Phone cannot make any claims regarding the accuracy and openness of third-party tools or their commitments regarding individual access.

Kids Help Phone provides this Privacy Policy in English and in French. Translated versions are available on demand.

Kids Help Phone Privacy Policy

Accountability

Kids Help Phone is responsible for the personal information and personal health information under its control. We have appointed a Privacy Officer and created a Privacy, Security, & Risk Program to ensure compliance with Canadian privacy legislation and fair information principles.

The Use of Artificial Intelligence (AI): Kids Help Phone is introducing AI and machine learning tools to support its service delivery and Active Rescue processes. The risks involved with introducing AI is currently not considered proportional to the benefits of its use (as per R. v. Oakes). The AI tools are provided by reputable third parties.

Kids Help Phone policies exist to ensure that AI tools are from reputable sources; that AI tools are limited in their ability to link data per service; and are tested to ensure ethical data management and reduction of bias.

Crisis Response Service Delivery via Facebook Messenger: Kids Help Phone leverages Facebook to provide this service (https://en-khp-rebranding.4dconnect.com/get-virtual-support-with-facebook-messenger/.) This means that Facebook will analyze every utterance and response provided by Kids Help Phone. By using Facebook, service users have already agreed to Facebook’s Terms of Service. Kids Help Phone has no control over data processing by Facebook; as a result, anyone wishing to understand Facebook data processing practices should consult Facebook policies directly. Kids Help Phone is developing security policies for its Twilio platform.

Navigation Bot (“Kip”): Kids Help Phone leverages Google’s AI for the purpose of predicting the intent of service users’ utterances.

Insights: Kids Help Phone leverages Microsoft Power BI for the purpose of producing statistical analysis and graphs which map out audience priorities and demand (https://en-khp-rebranding.4dconnect.com/get-insights/home/). Kids Help Phone is developing security policies for its Power BI platform.

Peer-to-Peer Service: Kids Help Phone offers a platform that allows individuals to share and communicate via a forum-like interface. Kids Help Phone manages the platform technology and moderates its content. Peer-to-Peer is not a consulting service but rather a communication tool.

Good2Talk: Good2Talk is a program delivered by Kids Help Phone; hence, Kids Help Phone acts as the data custodian. The program is delivered in partnership with Ontario 211 as an agent and service provider of Kids Help Phone. Connex Ontario and The Centre provide services to the program. Good2Talk supports post-secondary institutions in Ontario. As data custodian, KHP responds to any questions related to access or privacy of information.

Data Hub Service: Kids Help Phone manages and implements an internal Data Hub service that provides analytics for operational and process improvement.

AI Cloud Services: Kids Help Phone leverages Google’s natural-language understanding (NLU), Dialogflow.

Other Cloud Services: Kids Help Phone leverages cloud services from Microsoft, Dropbox, and SurveyMonkey.Virtual Marketplaces: Kids Help Phone leverages Verint, Gratiflow, and Giveshop.

Kids Help Phone updates its policies and governance instruments at least once every calendar year. Governance instruments include a Privacy Policy, Terms of Use, IT Policy, Acceptable Use Policy, Data Classification Policy, Research Policy, and Incident and Breach Management Policy. Kids Help Phone is currently drafting a Research Policy.

Kids Help Phone is fully accountable for its actions across Canada where it collects, retains, uses, and discloses data  for the purpose of providing services to youth. To validate its accountability, Kids Help Phone engages a third party to conduct Privacy Impact Assessments for any new projects.

Purposes of data collection

Kids Help Phone collects personal information and personal health information to provide users with the above-mentioned services. Most Kids Help Phone services are delivered directly to the individual; for these services, we collect and store data internally. For the Peer-to-Peer service, data collected for the purpose of enabling user-to-user interaction is published to the Kids Help Phone website.

Kids Help Phone services are not considered mental health services as defined in the Mental Health Services Act (Mental Health Services Act (1990): https://www.ontario.ca/laws/statute/90m07). In addition, Kids Help Phone will use the information for data quality and service delivery improvement, and to share with research partners (row level data). We will disclose aggregate level data for funding reports, thought leadership publications including, (but not limited to) our website, media publicity, conference presentations, and participating in approved research. Kids Help Phone is in the process of developing a Research Policy.

Data collected through website interaction will be used for AI training to inform content development.

Information regarding donors, donors (in-kind and monetary), prospective donors, school staff, and partners (including those that assist in fundraising) is collected for: communications; requesting and managing donations; sending reminders, thank-you letters, and tax receipts; fundraising and gala events management; compliance; and for validating identity. We report back to fundraiser-organizing partners the staff participation count and amounts collected.

Other purposes of information collection and management include creating promotional material, writing of impact reports, formulating user experience stories, delivering motivational speaking presentations, and collecting feedback about these events.

Associates’ data will be used for the purposes of managing our employment relationship with them.

Service users may interact with Kids Help Phone in various ways: via phone, text, web application, Facebook, surveys, etc. Each of these modes of interaction has different implications in terms of Kids Help Phone’s ability to identify users from the data they have given the organization.

Kids Help Phone commits that service user data is:

  • Protected,
  • Held in confidence, and
  • Accessed by individuals who offer support to service users.

Service user data will be analyzed, to improve services and to create aggregate data for statistical analysis.

Kids Help Phone implements a privacy framework which complies with federal and provincial privacy legislation. Accordingly, a service user’s knowledge and consent are required for the collection, use, or disclosure of personal information and personal health information, except where inappropriate.

Service users agree that Kids Help Phone will receive data transmitted in the course of service interactions for the purposes of providing users with personal support.

By using Kids Help Phone applications and services, users agree and consent to the collection, retention, use, and disclosure rules listed in this Privacy Policy.

Limiting data collection

Kids Help Phone will limit the collection of personal information and personal health information to the intended purposes covered by this policy.

Kids Help Phone will not ask users for their name (we may ask for location if needed), to provide them with texting or counselling services; however, in the course of interaction, users may choose to provide information that is highly identifiable, such as their age, sex, gender, sexual orientation, or location. Kids Help Phone will treat all user information as personal health information.

While service users or the public interact with Kids Help Phone via phone, text, the Web, social media, or mobile application, these communications media provide us with various pieces of information that may identify users; for example:

  • Caller ID
  • Phone ID – text
  • Facebook name or alias
  • IP address

as well as other metadata about the browsers used or applications through which a user contacts us.

Despite the fact that Kids Help Phone may have access to identifying data, we will not use this data to identify service users. Kids Help Phone doesn’t have the tools to ascertain service user identity from the data we collect.

Kids Help Phone will collect demographic data including ethnicity to measure our service commitment to diversity and inclusion.

Kids Help Phone works with partners to collect donations. Some partners collect donations on our behalf and provide donor information, amounts, addresses, and names.

Kids Help Phone will limit collection of associate information according to associate role and function.

Information collected by Kids Help Phone may be either personal information or personal health information, which are together referred to in this policy as “information.”

Kids Help Phone may from time to time rent donor lists from not-for-profit organizations. People who do not wish to receive communications can contact Kids Help Phone to be removed from the list.

Kids Help Phone may reach out to you, directly or indirectly, to seek out your opinion of our services.

Crisis Response Service Delivery via Facebook Messenger: Kids Help Phone leverages Facebook to provide Crisis Response Service Delivery via Facebook Messenger. Facebook’s Privacy Policy and Terms of Service require users to agree to the collection, retention, use, and disclosure of their data and metadata, and information about friends and family, in addition to various rights to content uploaded by its subscribers. By using Facebook, service users have already agreed to Facebook’s Terms of Service. Kids Help Phone will leverage service user data and metadata in accordance with Facebook’s Terms of Service. By leveraging Facebook, Kids Help Phone collects Facebook user profile information and metadata related to the interaction between the service user and Kids Help Phone.

Good2Talk: For programs such as Good2Talk, implemented in partnership with other organizations, such as Ontario 211, ConnexOntario, and the Ontario Centre of Excellence for Child and Youth Mental Health (the Centre), Kids Help Phone collects row level and aggregate level data.

Limiting data retention, use, and disclosure

Kids Help Phone is committed to the proper classification, secure retention, and timely and secure disposal of any record containing any information. Kids Help Phone’s various services have varied retention schedules, depending on technology limits, legal obligations, and quality control and reporting requirements. The Data Retention and Disposal Policy and Terms of Use list data retention by service. Kids Help Phone’s Data Retention and Disposal Policy also specifies when data is disposed of, and by whom.

User information will not be disclosed except in accordance with Kids Help Phone’s legal obligations to report to child services and policing agencies. In addition, Kids Help Phone will only release aggregate reports and row-level data about its services to agencies such as Canada Health Infoway or to major funders. Any disclosure of aggregate data must be deidentified to include at least 100 people in the data set, thus greatly reducing the potential of re-identification. Even though Kids Help Phone shares data in certain listed circumstances, we will not share data that is stigmatizing or puts a group or individual in a negative light based on our Non-discrimination Policy. For research and publications, we will seek formal research ethics approval as per the Canadian Tri-Council Policy Statement of Ethical Conduct for Research Involving Humans.

We do share row level data with research partners. We will disclose aggregate level data (deidentified to include at least 100 people in the data set) for funding reports, thought leadership publications, media publicity, conference presentations, and participating in approved research.

Donor information will only be disclosed for the purposes of validating identity and collecting donations. However, we may report back to donating partners the number of staff participating in events, and how much was raised at a fundraising event. We will not disclose information pertaining to donors who request anonymity.

We will limit the use of associate information to identity validation, managing payroll, capturing demographic information, next of kin, and emergency contacts.

Through its Privacy Impact Assessments, Kids Help Phone will document and asses the risk for any data extraction out of jurisdiction (including the province of Quebec and other Canadian provinces and territories).

Duty to Report

It is the legal and ethical duty of the Crisis Responder or Supervisor who answers your text not to reveal information about you to unauthorized individuals. However, there are legal limits to confidentiality. We may be required to disclose your telephone number and other information to an external agency, usually a local child welfare agency or, less commonly, the police, if we think that you or others may be in danger. This is called the “duty to report.”

We have a duty to report in the following cases:

  1. If you tell us that a child is or may be in need of protection; or
  2. If you tell us that someone is hurting you, has hurt you, or is likely to hurt you in the future; or
  3. If you tell us you are planning to hurt yourself or someone else; or
  4. If the artificial intelligence (AI) in the chat system flags your conversation as showing a risk of harm.

If we believe that you may be in danger, we will begin an “Active Rescue” (AR). We will let you know that we believe you are in danger and we will have a discussion with you about what will happen with the AR and any preferences you have. Depending on the Kids Help Phone service you are using, the AR may take place with the involvement of the Facebook Law Enforcement Response team and the RCMP.

AI and data intelligence tools

Kids Help Phone uses artificial intelligence (AI) technologies to guide website users and recommend content. AI processing may occur on the premises of Kids Help Phone or of third-party vendors. Facebook will process data using AI for its own processes.

Kids Help Phone uses data intelligence to extract aggregate and statistical data for the above purposes, and discloses this data publicly via its Insights service.

Crisis response service delivery via Facebook Messenger:

Retention: Kids Help Phone will retain your data in the Facebook platform for six months after our last interaction with you. After six months, user data will still remain in the texting and Insights databases; this data will have been analyzed, and Kids Help Phone cannot remove already-analysed data.

Use: Kids Help Phone will use your data to provide you with our services. Facebook will use data (as defined in their Terms of Service). As well, Kids Help Phone leverages Twilio as a communications medium between Facebook and Kids Help Phone. Facebook processing includes, but is not limited to, linking of data and application of artificial intelligence. The Kids Help Phone service creates a connection between the Kids Help Phone Facebook service page, Twilio, and the Kids Help Phone Crisis Text Line tool.

Disclosure: Kids Help Phone will not disclose data received via Facebook, except as per mandatory reporting requirements, such as Active Rescue.

Navigation bot (“Kip”):

Retention: Kids Help Phone will retain data for thirty days.

Use: Kids Help Phone will process data using AI and analytics.

Disclosure: Kids Help Phone will disclose statistical data via its Insights service.

Insights:

Retention: Kids Help Phone will retain data for seven years.

Use: Kids Help Phone will process data using advanced analytics tools. Data will be used to improve policy and service provision.

The solution will utilize Microsoft Power BI, and will leverage data from the phone counselling system (including ComputerTalk’s CentreICE platform, iCarol) and from the Text Crisis Response system (including the Kids Help Phone Crisis Text Line platform).

Disclosure: Kids Help Phone will present the data publicly on its website in the form of analytics dashboards. Furthermore, Kids Help Phone will deliver presentations featuring highlights of recent studies that utilize Kids Help Phone data holdings and linkages.

Peer-to-Peer service:

Retention: Data will be retained in the platform as long as users do not delete their accounts.

Use: Data will be used by Kids Help Phone for analytics and system performance.

Disclosure: Data will not be disclosed outside of Kids Help Phone

Good2Talk:

Retention: Through Good2Talk, Kids Help Phone retains data from Ontario 211, participating educational institutions, Connex Ontario, and the Centre. This data includes survey participating data, row level caller data, in addition to aggregate performance and evaluation data.

Use: The retained data is used for program evaluation, reporting, and funding proposals. Kids Help Phone conducts advanced analytics on Good2Talk information. This advanced analytics is considered a use of data about service users.

Disclosure: Aggregate program evaluation and Key Performance Indicators are released to funding organizations.

Data hub:

Retention: User data shall be retained in the Data Hub for 7 years plus the user’s age of majority as defined in their province of residence.

Use: Data will be used for internal analytics operational performance and for internal aggregate reporting.

Disclosure: Any data disclosure shall be reviewed for privacy compliance; including, but not limited to, ethics and research obligations. Data will not be disclosed outside of Kids Help Phone.

Ensuring accuracy

Kids Help Phone will ensure that appropriate reviews are executed for donor and system data integrity, will report any data integrity issues to the data quality team (which includes staff from business and information technology), and will correct all data integrity issues in a timely manner. Kids Help Phone will attempt to validate donor payment details and address information to ensure continuity of billing, and to provide tax receipts. Staff transcribe phone conversations if needed for reporting purposes.

In contexts where Kids Help Phone uses AI, the predictive analytics engine may not always comprehend or accurately assess user intent. Kids Help Phone will continuously attempt to improve these systems’ accuracy and response. Members of the public (including service users) are invited to send Kids Help Phone requests to update any errors encountered.

For Short Messaging and Chat Services, we will store “text” exchanges to ensure service quality and for training purposes. Kids Help Phone relies on individuals providing accurate data; Kids Help Phone does not have the means of ensuring the accuracy of information. Its counsellors assume that what they are told is accurate, and will document information based on service user statements.

Kids Help Phone is in the process of developing a quality assurance protocol for all of its services, and continuous measurement of its services.

Safeguards

We follow industry standards to safeguard data against loss or theft, as well as unauthorized use, access, disclosure, copying, modification, retention, or disposal. We use a variety of physical, electronic, and procedural safeguards to protect all captured information.

Most texting user information is stored in Canada and the US. Some companies providing services to Kids Help Phone are located outside of Canada (including the US) and so information may be stored in those jurisdictions. Under the laws of some countries (including the US) information may be made available to the government, or its agencies, under a court order made in that country. For further information, please contact us at [email protected]. Donor information is stored in Canada.

Kids Help Phone establishes with its vendors contractual safeguards which:

  • Ensure that the vendor notifies Kids Help Phone of any privacy or security incident as soon as possible;
  • Ensure that vendor complies with a Kids Help Phone investigation or audit if needed.
  • Ensure that vendors access information solely for the purpose of delivering services.
  • Ensure that vendors return data as soon as the contract ends.

Openness

Kids Help Phone publishes a summary of this Policy in plain language. Kids Help Phone can make accessible its data protection policies on demand.

Crisis Response Service Delivery via Facebook Messenger: Individuals will have access to their own conversations on their own devices, as long as they have not deleted them.

Good2Talk: Kids Help Phone publishes information about the Good2Talk program in this Privacy Policy as well as in its Terms of Service. 

Individual access

Kids Help Phone voluntarily implements access to information procedures so that relevant parties can access their own data. Kids Help Phone will not release data unless the identity of the requester is authenticated, and we are able to ascertain that the information requested is linked to the requester.

For donors, Kids Help Phone has a documented procedure, with clear accountabilities, to comply with applicable legislation allowing an individual to access their information. Systems and documented processes are in place, with controls and audit trails, to respond to individual requests for data access.

Data Hub: Access to information or correction requests will not be processed for the Data Hub. Data inside the Hub is not linked to individuals, and individuals cannot be identified from it.

Good2Talk: Members of the public may request record level data if uniquely identifying information about them is documented in the records.

Governance

In order to meet its obligations under privacy legislation, and to clients and funders, Kids Help Phone has:

  • Created a Privacy, Security, and Risk Program and assigned a Privacy Officer to ensure compliance with legal obligations related to privacy and security.
  • Used or developed practices and procedures to:
    • Develop key performance indicators to assess and report on privacy or security metrics.
    • Review Kids Help Phone privacy and security policies, practices, and procedures annually to ensure that they comply with applicable legal, industry, and regulatory standards and requirements and to determine whether changes are necessary or appropriate based on changes in laws or significant legal or other developments.

In the event of a security incident or breach, the Privacy, Security, and Risk Program team will immediately form a response team. This team includes the Privacy Officer or delegate, the program/project/executive involved with the breach, and the Director of IT, as well as any other participants decided on by the Privacy Officer. The team will ensure that the incident or breach is immediately addressed, and that any fallout is managed with impacted individuals.

Human resources

Kids Help Phone uses and develops practices and procedures to ensure that associates who perform services or otherwise have access to confidential information will:

  • Sign a Confidentiality Agreement.
  • Receive training in all privacy- and security-related policies and procedures (these are readily accessible to all personnel).

Training and awareness

Kids Help Phone believes that a culture of privacy and security is necessary to meet the individual and collective responsibilities of the organization, and delivers comprehensive privacy training and ongoing privacy awareness initiatives to all associates as required.

Auditing policy and procedures

Kids Help Phone is establishing an overarching audit policy. Until such a policy is developed, we will audit access on an as-needed basis.

Breach response protocol

Kids Help Phone affirms its ability to promptly and appropriately respond to, contain, and mitigate the impact of a privacy or security breach or incident. Accordingly, Kids Help Phone has a documented breach response protocol to identify, manage, and resolve privacy and security breaches. Systems and documented processes are in place, with controls and audit trails, to respond to privacy and security breaches which occur as the result of loss, theft, unauthorized use, access, disclosure, copying, modification, or unauthorized or unsecured disposal of collected information.

The following Prevention Strategies should be followed to minimize the possibility of a breach, and to ensure preparedness in the event that a breach does occur.

Prevention Strategies

Security

Make sure that all physical, logical, and IT controls are appropriate for the type of information collected and stored.

All patches and updates must be installed system-wide on release. Many breaches occur because a security patch was not installed in a timely manner.

Wherever possible, personal information and personal health information are to be encrypted.

Auditing

All new programs that will collect or manage personal information should be evaluated; Privacy Impact Assessments and Threat and Risk Assessments should be conducted before any new processes are implemented.

Training

Training and awareness programs will include specific guidance on detection of potential security hazards, allowing them to be fixed before an issue escalates.

Third-party vendors

Review all contracts as well as the security measures used by data processors to ensure that they have all appropriate physical, logical, and IT controls.

Complaint management

Kids Help Phone responds to privacy and policy complaints within twenty-eight calendar days of initial receipt. The public is asked to send their privacy-related complaints to [email protected] or via letter addressed to: Privacy Officer, Kids Help Phone, National Office, 300‐439 University Avenue, Toronto, ON M5G 1Y8.

Donors can send requests for changes or complaints via email, telephone, or regular mail addressed to: Privacy Officer, Kids Help Phone, National Office, 300‐439 University Avenue, Toronto, ON M5G 1Y8, or through the online form visible at kidshelpphone.ca.

Service-related complaints are addressed in our complaints policy, available on the web at https://en-khp-rebranding.4dconnect.com/kids-help-phones-complaints-policy/.

Operating procedures

Kids Help Phone has practices and procedures in place to ensure that it meets all provincial and federal privacy regulations. The Privacy, Security, and Risk Program at Kids Help Phone administers and manages privacy, security, and risk processes.

Web-tracking disclosure statement

The Kids Help Phone website uses cookies, web beacons, and tagging technologies, in order to improve usability, evaluate content popularity, personalize service user experience, improve the quality of our chatbot recommendations, and measure the advertising return on investment. Our AI processes also analyze the conversations between service users and the Kids Help Phone chatbot and create internal tags for each conversation.

Newsletter Tracking

Kids Help Phone may sometimes use an online external platform to send out newsletters to those who have signed up for news at Kids Help Phone. This platform tracks users’ interaction with the newsletter, includingdelivery and open and click rates, and can generate reporting on which device readers are using to open the newsletters.

By communicating with us through our website, you are providing us, our agents or partners, or other third parties (e.g., Google Analytics) with your information, and are thus consenting to the collection, use, and disclosure of your information in accordance with this Privacy Policy.

The website Terms of Service are posted at https://en-khp-rebranding.4dconnect.com/terms-service/.

If you have questions about your personal data

If you want to view your personal information or personal health information, or have any concerns about the way in which your personal data is used or disclosed, please contact the Kids Help Phone Privacy Officer at:

Privacy Officer
Kids Help Phone, National Office, 300‐439 University Avenue, Toronto, ON M5G 1Y8

Toll Free Number: 1-800-268-3062

Email: [email protected]


We will make every effort to address your concerns. Concerns and complaints may also be addressed to the Information and Privacy Commissioner of Ontario.