3.1 Confidentiality of Information

Updated: August 2024

It is the policy of Crescent School (the “School”) to ensure all records, correspondence, and information relating to operations and business affairs are kept confidential to the greatest extent possible. As an employee of the School, you will acquire information that is confidential to the School.

All information in any form, whether written, electronic, or oral, about or owned, used or licensed by the School that is not generally and lawfully available to the public is considered “Confidential Information.” This includes information relating to the School’s students and the parents or families of its students. This also includes information relating to the School and its employees, operations, and business affairs, such as salaries, expenses, contracts, IT systems and security protocols. Confidential Information does not include information that has been lawfully made publicly available by the School or a third party, such as a parent. An employee who is uncertain whether information is Confidential Information or not is expected to treat it as Confidential Information.

Employees may only access, use or disclose Confidential Information if, and to the extent, the information is needed:

to perform employment duties;
to address immediate health and safety concerns (such as sharing personal health information of a student to assist emergency medical personnel);
by the employee's financial advisor or immediate family member, to assist with the employee's personal financial planning or decision-making (such as disclosing one's salary to an accountant or spouse); or
by the employee's legal advisor, to determine the employee's legal rights.

In all other circumstances, the access, use or disclosure of Confidential Information is prohibited, except with the express permission of the School or where required under applicable laws.

If you are required to disclose Confidential Information under applicable laws or in a legal proceeding, you will provide the School with as much advance notice as lawfully possible to enable the School to have the opportunity to consider opposing or limiting the disclosure order or to obtain a protective order. It is expected that you will cooperate with the School in any efforts to safeguard the confidentiality of Confidential Information or mitigate a situation where Confidential Information has been disclosed without proper authorization. An employee found in violation of this Policy may be subject to disciplinary action up to and including termination of employment.

The “Personal Information Protection and Electronic Document Act” (PIPEDA) was originally passed by the federal Parliament in April 2000, and extended in January 2004 to include every organization that collects, uses or discloses personal information in the course of a commercial activity within a province. PIPEDA imposes strict limits on access to personal information and its dissemination.

All personal information entrusted to the School by parents is governed by PIPEDA. This includes but is not limited to, addresses, telephone numbers, and email addresses of the parents’ home or business.
You must not share personal information contained in the School’s databases with other parents, students, alumni or the general public.

To help ensure information is kept confidential:

Take all reasonable precautions to safeguard Confidential Information from unauthorized access, use or disclosure and to ensure all sensitive Confidential Information is kept in secure locked cabinets or password-protected computer folders and/or systems.
When sending an email containing Confidential Information, review the recipients and the Confidential Information being shared.
When sending an email to multiple external recipients who are not employees of the School, such as a group of parents, send the email to yourself (in the “To” field) and put the external email addresses in the “Bcc” field. This way you are not inadvertently sharing private email addresses with all recipients.
When photocopying, ensure that the original and all copies are removed from the copier and the room. Shred or otherwise destroy copies or originals that you do not intend to use.
Avoid email for the communication of sensitive or private information. Private information when not communicated verbally should be marked “Private and Confidential” and placed in a sealed envelope. Where possible this information should be hand-delivered.
Any computer logged into one of the School’s databases must not be left unattended.
Any questions regarding information covered under PIPEDA should be addressed to the School’s designated Privacy Officer: the Director of Communications and Marketing