Privacy Policy

1. Who we are and what this policy covers

This Privacy Policy explains how Hispir Consulting Ltd. (operating as "Hispir Care", "we", "us", "our") handles personal information. It applies to the families and children we support, our care and behavioural aides, and visitors who use our website and care platform at [website URL]. We follow Alberta's Personal Information Protection Act (PIPA) as our minimum standard, and we voluntarily apply the higher protections of Alberta's Health Information Act (HIA) to the children's health information we hold. [If you are an FSCD-funded family, this policy works alongside — and does not replace — the privacy terms in your service agreement with us.]

2. What information we collect

We collect only the information we need to deliver and administer care. Depending on your relationship with us, this may include:

• Guardian/family information:[names, relationship to child, phone, email, mailing address, emergency contacts].
• Child information:[child's name, date of birth, FSCD file/agreement details, service details].
• Health and behavioural information:[describe exactly what you collect, e.g. care needs, behavioural support plans, allergies, therapy goals]. We treat this as the most sensitive information we hold.
• Service and scheduling records:[appointment times, visit logs, aide assignments, service notes].
• Aide and staff information:[name, contact details, qualifications, availability, certifications].
• Website and platform information:[account email, sign-in records, and the limited technical data described under "Cookies and analytics" below].

We do not collect more information than is reasonable for these purposes.

3. How we collect your information

We collect information in the following ways:

• Directly from you, when you sign up, complete onboarding forms, accept agreements, or contact us through our platform, by phone, or by email.
• From our care and behavioural aides, as part of documenting the services delivered to your child.
• During the course of providing care, such as visit logs and service notes.
• From documents you provide to us, such as [FSCD agreements or program paperwork].

[If applicable: In some cases we may receive information about a child from a referring agency or Alberta FSCD, with the family's knowledge.] Wherever practical, we collect information directly from you.

4. Why we collect it

We collect, use, and keep personal and health information for these purposes:

• To provide, coordinate, and document home-care and behavioural support for your child.
• To match families with suitable aides and to schedule and manage visits.
• To meet the requirements of Alberta's FSCD program and related funding, reporting, and contractual obligations.
• To communicate with you about your child's care, appointments, and account.
• To keep children and aides safe and to maintain accurate care records.
• To operate and secure our website and care platform and manage your account.
• To meet our legal, regulatory, insurance, and audit obligations.

We will not use your information for a new purpose that is materially different from these without telling you and, where required, getting your consent.

5. Consent and how to withdraw it

We collect, use, and disclose personal information with your consent, except in the limited situations where PIPA allows or requires us to act without consent (for example, to respond to an emergency, to comply with the law, or for an investigation).

Because we support children, a parent or legal guardian provides consent on the child's behalf. When you accept an agreement in our care platform, we record that acceptance; for accountability, these acceptance records are kept and cannot be edited or deleted.

You may withdraw your consent at any time by contacting our Privacy Officer (below), giving reasonable notice. We will explain what withdrawing consent means before it takes effect. Please note that if you withdraw consent we may no longer be able to provide some or all of the care, and we may still need to keep certain records to meet our legal, funding, and FSCD obligations. [Legal review: add wording on mature-minor consent for health-information disclosure.]

6. How we use your information

We use personal and health information only for the purposes described in "Why we collect it" above. Inside Hispir Care, access is limited to staff and aides who need the information to do their jobs — for example, an aide can see the care details for the child they are assigned to. We do not sell your personal information, and we do not use it for advertising.

7. When and with whom we share it

We share personal and health information only as needed, and only with:

• Alberta's FSCD program / Government of Alberta, to administer funding and meet program and reporting requirements.
• Our care and behavioural aides, limited to the families and children they are assigned to support.
• Service providers who help us run our platform, such as [hosting / database / error-monitoring providers], under agreements that require them to protect your information and use it only on our instructions.
• Others where you have consented, or where the law requires or permits it (for example, to protect a child's safety or to comply with a legal request).

We do not sell personal information. [State whether all service providers store and process data in Canada. If any provider operates outside Canada, you MUST list the country and the purpose here.] Questions about our service providers can be directed to our Privacy Officer, named below.

8. Where your data is stored and how we protect it

All personal and health information we collect is stored on servers located in Canada. We do not store your data outside Canada.

We protect your information with safeguards appropriate to how sensitive it is:

• Technological:[encryption of data, password-protected accounts, role-based access so people only see what they need].
• Administrative:[confidentiality agreements with staff and aides, privacy training, internal access controls and policies].
• Physical:[secure facilities and devices].

No system can be guaranteed to be perfectly secure, but we work to protect your information and to limit who can access it. If a privacy breach occurs that poses a real risk of significant harm, we will notify the Office of the Information and Privacy Commissioner of Alberta without unreasonable delay, and we will notify affected individuals as required by law.

9. How long we keep it and how we dispose of it

We keep personal and health information only as long as we reasonably need it for the purposes described above, and to meet our legal, insurance, and FSCD record-keeping obligations. [Where you can state specific periods, e.g. "care records are retained for X years after services end".] When we no longer need information, we securely destroy or anonymize it. Certain records, such as agreement-acceptance and audit-log entries, are retained as required and are not altered or deleted.

10. Children's information

The children we support are minors, so a parent or legal guardian provides and manages consent on the child's behalf. We treat children's personal and health information as the most sensitive information we hold:

• We collect only what we need to support the child's care.
• We strictly limit who can see a child's information — generally only the assigned aide(s) and the staff who coordinate that child's care.
• We never sell children's information and never use it for advertising or marketing.

If you are a guardian and want to review or update your child's information, contact our Privacy Officer below. [Legal review: confirm how requests are handled where a mature minor's own consent is required under PIPA.]

11. Your rights: access and correction

Under Alberta's PIPA, you have the right to:

• Ask what personal information we hold about you (or, as a guardian, about your child) and how we have used and shared it.
• Ask us to correct information that is wrong or incomplete.

To make a request, contact our Privacy Officer in writing using the details below. We will respond within 45 days, as PIPA requires (we will let you know if we need an extension for a large or complex request). There is no charge to correct your information. If we are unable to make a correction you have asked for, we will note your request on the relevant record.

12. Cookies, analytics, and tracking

This website uses minimal tracking. [State the truth, e.g. "We do not use advertising or third-party tracking cookies on this site."]

Our care platform uses a sign-in session cookie that is necessary to keep you securely logged in — it is not used to track you across other websites. [If applicable, name any analytics or error-monitoring tools used in the platform and what they do at a high level.] We will update this section if our use of cookies or analytics changes.

13. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and change the "Last updated" date at the top. If we make a significant change to how we handle your or your child's information, we will take reasonable steps to let you know directly.

14. Contact us and our Privacy Officer

If you have questions about this policy, want to access or correct your information, withdraw consent, or raise a privacy concern, contact our Privacy Officer:

We will do our best to answer your questions and resolve any concerns.

15. How to make a complaint

If you have a privacy concern, please contact our Privacy Officer first (above) so we can try to resolve it. If you are not satisfied with our response, you have the right to make a complaint to the Office of the Information and Privacy Commissioner of Alberta (OIPC). The OIPC currently asks that you give an organization a reasonable opportunity (at least 30 working days) to respond before bringing a complaint to them.