Privacy Policy
Effective Date: September 15, 2026
Last Updated: September 15, 2026
​
Pathways Support Services (“Pathways,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.
This Privacy Policy explains how Pathways Support Services collects, uses, discloses, protects, retains, and manages personal information in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), where applicable.
This Privacy Policy applies to information collected through our website, by email, telephone, in person, and through our service-related activities.
​
1. Our Commitment to Privacy
Pathways Support Services is responsible for the personal information under its control.
We are committed to:
-
Collecting only information that is reasonably necessary for identified purposes;
-
Explaining why personal information is collected before or when it is collected;
-
Obtaining meaningful consent where required;
-
Using and disclosing information only for identified purposes, unless otherwise permitted or required by law;
-
Keeping personal information accurate and up to date;
-
Protecting personal information using appropriate safeguards;
-
Retaining information only as long as reasonably necessary;
-
Providing individuals with access to their personal information as required by law; and
-
Providing a process for privacy questions, concerns, and complaints.
These commitments reflect the 10 fair information principles under PIPEDA.
​
2. Privacy Officer
Pathways has designated a person responsible for privacy compliance and the management of personal information.
Privacy Officer: [NAME OR TITLE]
Organization: Pathways Support Services
Email: [PRIVACY EMAIL]
Telephone: [PHONE NUMBER]
Mailing Address: [BUSINESS ADDRESS]
Questions, concerns, access requests, and privacy complaints may be directed to the Privacy Officer.
​
3. Personal Information We May Collect
Depending on how you interact with Pathways, we may collect personal information such as:
-
Name and contact information;
-
Mailing or service address;
-
Telephone number;
-
Email address;
-
Information provided through website contact forms;
-
Information necessary to determine or coordinate services;
-
Information about individual goals, preferences, support needs, or service requirements;
-
Information provided by a family member, caregiver, substitute decision-maker, or authorized representative where appropriate;
-
Billing and payment information;
-
Information relating to funding or service arrangements;
-
Correspondence and communications with Pathways;
-
Information required to administer, coordinate, or deliver services; and
-
Other information reasonably necessary for an identified and legitimate purpose.
Pathways will not collect more personal information than is reasonably necessary for the purposes identified at the time of collection.
​
4. Sensitive Personal Information
Some information provided to Pathways may be sensitive, including information relating to disability, health, support needs, finances, or other personal circumstances.
We recognize that more sensitive information requires stronger safeguards.
Where required, Pathways will obtain express consent before collecting, using, or disclosing sensitive personal information.
​
5. How We Collect Personal Information
We may collect personal information:
-
Directly from you;
-
From a parent, guardian, caregiver, substitute decision-maker, or authorized representative;
-
Through our website or online forms;
-
By email or telephone;
-
During meetings or consultations;
-
Through service documentation;
-
From organizations or professionals where you have authorized the disclosure or where disclosure is otherwise permitted by law; and
-
From other lawful sources where permitted by applicable privacy legislation.
Whenever reasonably possible, we will collect personal information directly from the individual to whom it relates.
​
6. Why We Collect Personal Information
Pathways may collect personal information for purposes including:
-
Responding to inquiries and requests for information;
-
Assessing and coordinating support services;
-
Understanding individual goals and support requirements;
-
Providing and administering services;
-
Communicating with individuals, families, caregivers, or authorized representatives;
-
Administering funding and payment arrangements;
-
Preparing invoices and processing payments;
-
Maintaining service and business records;
-
Managing appointments and communications;
-
Meeting contractual, legal, regulatory, and reporting requirements;
-
Managing complaints and resolving concerns;
-
Protecting the safety and security of individuals, staff, and our operations; and
-
Other purposes that are identified to you at or before the time information is collected.
We will identify a new purpose and obtain additional consent where required before using personal information for a purpose that was not previously identified.
​
7. Consent
Pathways generally obtains meaningful consent before collecting, using, or disclosing personal information.
Depending on the circumstances and sensitivity of the information, consent may be express or implied where permitted by law.
We will make reasonable efforts to ensure that individuals understand:
-
What information is being collected;
-
Why it is being collected;
-
How it will be used;
-
When it may be disclosed; and
-
The consequences of providing or withholding consent, where applicable.
Consent will not be required where collection, use, or disclosure is otherwise permitted or required by law.
Where consent is required, individuals may withdraw their consent, subject to legal or contractual restrictions and reasonable notice.
Withdrawal of consent may affect our ability to provide certain services.
​
8. Website Contact Forms
If you submit information through a Pathways website form, we may collect information such as your name, email address, telephone number, and the contents of your message.
We use this information to respond to your inquiry and for the purpose identified on the form.
Please do not submit highly sensitive personal, medical, financial, or identifying information through a general website contact form unless Pathways specifically instructs you to do so.
Where sensitive information is required, Pathways will provide an appropriate method for securely providing that information.
​
9. Website Analytics, Cookies and Similar Technologies
Our website may use cookies, analytics tools, or similar technologies to help us understand website traffic, improve website functionality, maintain security, and improve the user experience.
Depending on the technologies used on our website, information may include:
-
IP address;
-
Browser and device information;
-
Pages visited;
-
Date and time of visits;
-
Referring website;
-
General geographic information; and
-
Other technical information generated through use of the website.
Where required, Pathways will provide appropriate notice and obtain consent for non-essential cookies or tracking technologies.
You may be able to control cookies through your browser settings. Disabling certain cookies may affect website functionality.
Website-specific note: Before publishing this policy, Pathways should identify the actual analytics, cookie, advertising, booking, form, or other tracking services installed on the website and update this section accordingly.
​
10. Use of Personal Information
Pathways will use personal information only for the purposes for which it was collected, for purposes that an individual would reasonably expect, with consent where required, or where otherwise permitted or required by law.
We will not sell personal information.
We will not use personal information for unrelated marketing purposes without obtaining the appropriate consent where required.
​
11. Disclosure of Personal Information
Pathways may disclose personal information where reasonably necessary to provide services or administer our operations.
Depending on the circumstances, information may be disclosed to:
-
Authorized family members, caregivers, or representatives;
-
Funding bodies or program administrators where authorized or required;
-
Service providers assisting Pathways with business operations;
-
Information technology, website, hosting, email, payment, accounting, or administrative service providers;
-
Professional advisors where reasonably necessary;
-
Government or regulatory authorities where required or permitted by law; and
-
Emergency services or other parties where disclosure is necessary to address an emergency or protect health or safety, where permitted by law.
Pathways will limit disclosures to information reasonably necessary for the identified purpose.
Where a third party processes personal information on our behalf, Pathways will take reasonable steps to ensure that the third party provides an appropriate level of protection.
​
12. Service Providers and Information Outside Canada
Pathways may use third-party service providers for services such as website hosting, email, cloud storage, technology, payment processing, accounting, scheduling, or other administrative functions.
Some service providers may store or process information outside Canada.
Where personal information is transferred to a service provider for processing, Pathways remains responsible for the information under its control and will take reasonable steps to ensure appropriate contractual, organizational, and technical safeguards are in place.
Individuals may contact our Privacy Officer for information about our use of service providers and, where appropriate, the jurisdictions in which personal information may be processed.
​
13. Retention of Personal Information
Pathways retains personal information only for as long as reasonably necessary to fulfill the identified purposes, provide services, satisfy legal and contractual obligations, resolve disputes, maintain appropriate business records, and meet applicable regulatory or funding requirements.
When personal information is no longer required, Pathways will securely destroy, erase, or anonymize it in accordance with our records-retention and destruction procedures.
Information subject to an access request, complaint, investigation, dispute, or legal requirement may be retained for as long as reasonably necessary to address the matter.
​
14. Accuracy of Personal Information
Pathways makes reasonable efforts to ensure that personal information in our custody or control is accurate, complete, and up to date where necessary for the purposes for which it is used.
Individuals may request correction of inaccurate or incomplete personal information.
Where appropriate, corrected information will be communicated to parties to whom the information was previously disclosed, subject to applicable legal requirements.
​
15. Safeguarding Personal Information
Pathways uses safeguards appropriate to the sensitivity of the personal information we hold.
These may include:
-
Physical security measures;
-
Restricted access to personal information;
-
Password protection and access controls;
-
Encryption where appropriate;
-
Secure electronic systems;
-
Secure storage and disposal procedures;
-
Staff privacy and confidentiality practices;
-
Privacy training and awareness;
-
Monitoring and review of privacy practices; and
-
Contracts and other safeguards for third-party service providers.
No method of electronic transmission or storage can be guaranteed to be completely secure. However, Pathways takes reasonable steps to protect personal information against loss, theft, unauthorized access, use, disclosure, copying, modification, or destruction.
​
16. Privacy Breaches
Pathways maintains procedures for responding to privacy incidents and breaches.
If a breach involving personal information occurs, Pathways will assess the incident and take appropriate steps to contain it, investigate it, reduce potential harm, and prevent recurrence.
Where required by law, Pathways will notify affected individuals and the appropriate privacy regulator of a breach that creates a real risk of significant harm.
Pathways will maintain appropriate records of privacy breaches as required by applicable law.
​
17. Access to Personal Information
Individuals generally have the right to request access to their personal information held by Pathways, subject to applicable legal exceptions.
An access request should be submitted in writing to our Privacy Officer and should include sufficient information to identify the individual and the information being requested.
Pathways will:
-
Acknowledge the request;
-
Verify the identity of the requester where appropriate;
-
Locate the relevant personal information;
-
Review the information for applicable legal restrictions or exceptions;
-
Provide access where required; and
-
Explain any applicable refusal or limitation.
Requests may be subject to applicable legal timelines and permitted fees.
​
18. Correcting Personal Information
If you believe that information Pathways holds about you is inaccurate or incomplete, you may request a correction.
Requests should be submitted to our Privacy Officer and should identify the information believed to be inaccurate and, where possible, provide the correct information.
​
19. Withdrawing Consent
Where Pathways relies on consent to collect, use, or disclose personal information, an individual may withdraw consent by contacting our Privacy Officer.
Withdrawal of consent does not affect information already collected, used, or disclosed based on valid consent before the withdrawal, unless otherwise required by law.
In some circumstances, withdrawing consent may prevent Pathways from providing or continuing certain services.
​
20. Privacy Complaints
If you have a question, concern, or complaint about Pathways’ handling of your personal information, we encourage you to contact our Privacy Officer first.
We will investigate complaints and respond within a reasonable period.
Privacy Officer
Pathways Support Services
[NAME OR TITLE]
[EMAIL]
[PHONE]
[MAILING ADDRESS]
If you are not satisfied with our response, you may have the right to bring your concern to the Office of the Privacy Commissioner of Canada or another applicable privacy regulator, depending on the circumstances and legislation that applies.
​
21. Children’s Privacy
Our website is not intended to knowingly collect personal information from children without appropriate authorization.
Where Pathways provides services to children or individuals who require a representative to provide consent, we will follow applicable legal requirements concerning consent, representation, and privacy.
​
22. Third-Party Websites
Our website may contain links to third-party websites.
Pathways is not responsible for the privacy practices, security, or content of third-party websites.
We encourage users to review the privacy policies of any third-party website before providing personal information.
​
23. Changes to This Privacy Policy
Pathways may update this Privacy Policy from time to time to reflect changes in our practices, services, technology, or applicable legal requirements.
The updated version will be posted on our website with a revised “Last Updated” date.
Where required, Pathways will provide additional notice or obtain consent for material changes to how personal information is collected, used, or disclosed.
​
24. Contact Us
For questions about this Privacy Policy, access requests, correction requests, consent withdrawals, or privacy complaints, please contact:
Pathways Support Services
Privacy Officer: [NAME OR TITLE]
Email: [PRIVACY EMAIL]
Telephone: [PHONE NUMBER]
Mailing Address: [FULL BUSINESS ADDRESS]
Effective Date: September 15, 2026
Last Updated: September 15, 2026