1. Introduction:

The Canadian Association of Schools of Nursing (CASN) is the national voice for nursing education. Its mandate is to promote high-quality nursing education among its member schools and foster nursing scholarship. It offers services, programs, and activities that foster excellence in nursing education including accreditation, continuing education to faculty, certification exams related to pedagogy, publication of nursing education textbooks, conferences, and the CASN Residency and International Educated Nurse (IEN) mentorship programs.

Personal information is collected that is voluntarily provided by individuals for purposes related to CASN’s activities. This may include, but is not limited to: names, contact information, membership details, and event participation records. CASN does not sell, trade, or otherwise transfer personal information to external parties without the consent of the individuals, except as required by law. Care is taken to ensure that the collection of data does not mislead and also that both the manner data are collected and the purpose of collecting data are reasonable.

This policy applies to all individuals whose personal information is collected by CASN.

2. Collection of Personal Information:

Personal information collected by CASN includes data on applicants for positions at CASN and CASN employees. Employee data categories include salary, pension, annual leave, and performance assessments.

Data is also collected to identify heads of CASN member schools, registrants in CASN programs, and volunteers who contribute to the delivery of CASN programs such as the accreditation program, and data on nurse residents in the CASN residency program. Payment information such as credit cards and banking information is also collected. Data is collected directly from individuals.

3. Legal Basis for Processing:

As CASN is a national organization, the legal basis for processing personal information is governed by federal law, the Personal Information Protection and Electronic Documents Act (PIPEDA). It applies to private sector organizations, including not-for-profit associations.

PIPEDA includes a provision that allows for the collection, use, and disclosure of personal information without consent to carry out the work of a not-for-profit organization, where obtaining consent is impractical. Information is not used or disclosed for purposes other than the purpose for which it was collected.

4. Purpose and Use of Personal Information:

The specific purposes for collecting personal information at CASN include the following:

Employees

• Recruitment, hiring, and management of employees, including the administration of payroll and benefits.

Membership

• Managing and maintaining records of member schools.

Legal and regulatory obligations

• Fulfilling legal and regulatory obligations, including tax reporting, compliance with industry standards, or responding to legal requests.
• Implementing security measures to protect against unauthorized access, fraud, or other security threats.
• Meeting reporting requirements to government agencies or authorities, as mandated by law.

Communication

• Facilitating communication with individuals, including newsletters, updates, and important announcements.
• Promoting CASN documents, services, or causes.
• Maintaining subscriptions for online platforms and services.
• Managing relationships with clients, customers, suppliers, or partners as part of contractual agreements.

Events

• Planning and organizing events, courses, conferences, seminars, or workshops, including registration and attendance tracking.

Fundraising

• Managing donations and financial contributions from supporters or members.

Research

• Conducting research, surveys, and data analysis to develop knowledge products, and improve services or organizational effectiveness.

Accreditation Programs

• Managing and maintaining records of accreditation reviews.

Residency Program

• Maintaining records of nurse graduates and preceptor-mentors enrolled in CASN’s residency program.

Education and evaluation

• Providing educational services and certification exams, including tracking academic or exam results.
• Customizing services, recommendations, or content based on individual preferences and behaviour.
• Verifying the identity of individuals for security or access control purposes.

5. Accountability

CASN designates the Managing Director of each section of the organization as the person responsible for the following in their sector:

• implementing procedures to protect personal information.
• establishing procedures to receive and respond to complaints and inquiries.
• training staff and communicating to staff information about the policies and practices.
• developing information to explain the policies and procedures.
• ensuring that the purpose for collecting personal information is explained to individuals.
• Specifying the duration for which personal information will be retained.
• Safeguarding the security of personal information.
• Ensuring that the disposal of personal information protects its security.

6. Consent:

Obtaining the consent of individuals is a fundamental principle under privacy laws and generally, CASN seeks the informed and voluntary consent of individuals before collecting their personal information. Information is typically voluntarily provided by the subject person. References, however, for applicants to CASN positions are from referees identified by the applicant and are contacted with the consent of the applicant.

According to PIPPED, however, an organization “shall not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfil the explicitly specified, and legitimate purposes.” Thus, it allows for the collection, use, and disclosure of personal information without consent for the purpose of carrying out the work of a not-for-profit organization, where obtaining consent is impractical and the information is not used or disclosed for purposes other than the purpose for which it was collected.

Formal, signed consent forms are used in the accreditation programs, the residency program, and the IEN mentorship program.  CASN informs individuals of their right to withdraw consent at any time.

7. Security safeguards

Personal information is protected by security safeguards appropriate to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Some personal data on employees is shared with Universities Canada, the organization contracted to provide CASN with human resource services; some personal data of employees and service providers are shared with Andrews & Co, an accounting firm contracted to provide CASN with accounting services; and, some personal data is shared with NOVA, a company providing CASN with digital and computer support services.

Depending on the nature of the personal data, the methods of protection include the following:

• Physical measures, including locked filing cabinets and restricted access to offices. Security clearances and limiting access on a “need-to-know” basis.
• Technological measures, including the use of passwords and encryption.
• Staff training on maintaining the confidentiality of personal information.
• Ensuring that the methods of disposal or destruction of personal information prevent unauthorized parties from gaining access to the information (i.e. use of shredders, deleting credit card and banking information once it is no longer needed, etc.)

8. Access and correction

Upon request, an employee will be informed of the existence, use, and disclosure of personal information and will be given access to that information. An individual shall be able to challenge the accuracy and completeness of this information and have it altered.

9. Revisions

The privacy policy will be reviewed every five years and may be updated as needed.

10. Contact Information:

For further information, questions or concerns about this Privacy Policy or our data practices, please contact CASN Executive Director, Cynthia Baker, at cbaker@casn.ca, 613.235.3150

Updated and Approved: March 20, 2024
Supersedes policy dated May 2004