04. Confidentiality Policy

  1. Members of Committees, the Board of Directors and Staff, as well as all members of the Co-op, shall maintain in strict confidence, all materials of private and/or personal nature pertaining to names, unit numbers and circumstances of members; including but not limited to the following:
  • a) Breaches of the Occupancy Agreement, Bylaws, policies, procedures, rules, regulations or agreements of any kind.
  • b) Unit Inspection reports.
  • c) Internal Subsidy Program.
  • d) Housing Charge payments, or the status thereof.
  • e) Salary figures plus other financial data.
  1. Anyone aware of a violation of (1) above shall report the violation to the Board.
  1. Any report of a violation of confidentiality considered by the Board of Directors must be investigated sufficiently to determine whether or not the report is valid. The investigation will include the following:
  • a) An interview with the person reporting the violation
  • b) An interview with the person allegedly in violation of the Confidentiality Policy
  • c) Interviews with any other persons, obviously implicated or who have relevant knowledge of the situation
  • d) Assessment of any pertinent information, confidential or otherwise, including but not limited to, the following: member files, credit check information, income data, appeal materials, and correspondence.
  1. Interviews will be, conducted by two members of the Board. Members of the Board will decline from sitting on an interview team where a bias may affect their objectivity and fair judgement of the matter (e.g. where a close friend or family member is the person accused of the violation).
  1. If from its investigation the Interview Team determines that, a member has breached confidentiality. The Team will recommend, in writing, to the Board of Directors, that the member who committed the offence is removed from, and become ineligible to hold, any position which requires any degree of confidentiality for a period of two (2) years.
  1. If any accused person feels that they have been unjustly treated or charged, they may appeal to the Board of the Directors in accordance with the General Appeals Policy.
  1. Contact by the Board with all parties, during the course of the investigation, shall be handled in an objective, and considerate manner. All matters related to the investigation shall be kept confidential.
  1. If violation of the Confidentiality Policy is by a member of the Board; then the matter will be dealt with by the Executive Committee of the Board in accordance with the procedure outlined above. Until the matter of the violation has been resolved, the alleged offending Board member must take a leave of absence from the Board of Directors. If the Board member has been found violating any Rainbow Housing Policy or By-law, the offending Board member must resign and not run for the Board for a period of two years. The decision of the Executive Committee can only be appealed by a Special Members Meeting or to the Registrar in accordance with the Co-operatives Act.