The following information is intended to assist Fleming College employees maintain professional and privacy obligations when working off-site.
Working on-site or off-site, all College employees are expected to uphold their professional and privacy obligations. Department Heads are ultimately responsible for creating and maintaining their own Department(s) process(es) for protection of personal information and records maintenance, retention and disposal within the provisions of FIPPA / PHIPPA, the College’s Access to Information and Protection of Privacy policies and the College’s Remote Access Operating Procedure #OP 6-601A.
General Recommendations for Working Off-site
- Manage your physical space – especially if living with other people. Try to have your computer screen and/or physical files away from other’s sight-lines. If possible, consider an anti-glare or privacy screen for your devices.
- Be aware of your surroundings when discussing personal/confidential information. Before you discuss personal/confidential information, prompt the person(s) you are meeting with so they can also make adjustments to their surroundings as needed.
- If possible, avoid accessing personal/confidential information on a personal device. Advise your Department Head in advance if you are planning to use a personal device to access confidential College records. If you must access personal/confidential information on a personal device:
- use a VPN (virtual private network) and/or the College’s VDI (virtual desktop infrastructure);
- avoid downloading any records that contain personal/confidential information on your personal device. If you must download a document(s) containing personal information ensure you delete all locally saved copies (delete from applicable folder(s) and from the trash/recycle bin);
- password protect your login and limit use of device by others if possible; and
- consider changing your Fleming College password so that it is different from other passwords that you use to access social media/other programs/websites on your personal device.
- If you record any hand-written notes or print any documents containing personal/confidential information while working off-site they should be treated like any other College record: stored securely (locked cabinet/room/drawer); kept confidential; and, only destroyed in accordance with your department processes and/or relevant legislation.
- Try to avoid storing any files on a USB or external hard drive as they are easily lost. If you must store private/personal information on a USB drive or external hard drive it is recommended that you password protect/encrypt the files and delete from the drive after use.
If you have questions or concerns pertaining to information technology and privacy please contact Fleming College’s Information Technology directly at firstname.lastname@example.org.
General Recommendations for Taking Hard-copy Records Off-site
- Before hard-copy (i.e. paper) records containing personal information are taken off-site, the determination should be made as to whether the records need to be taken off-site at all. The Department Head should be consulted. If it is determined that hard-copy records containing personal information need to be taken off-site the documents must be kept secure and remain in the possession of the staff member responsible for them.
- Department Heads should develop a plan to safeguard hard-copy records and ensure there is a department log to record all hard-copy records removed off-site. The log should include at minimum: record description; date of removal; staff member authorized to remove; and, date returned
- Hard-copy records should be returned on-site as soon as is practically possible.
Suspected Privacy Breach
- Privacy breaches are any instance of “theft, loss, and collection, use, retention, disclosure or destruction of personal information that is not consistent with privacy law, whether intentional or in error.”
- If you think there has been a breach of personal information please report it immediately. The College has a detailed procedure available at: https://department.flemingcollege.ca/foi/policies-and-procedures/