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Privacy and Use of Confidential Information

Statement of Confidentiality

Accessible Learning collects, stores, and uses personal and health information as is reasonably required to provide disability-related services under the legal authority of the Wilfrid Laurier University Act (1973, amended 2001) and in accordance with the Freedom of Information and Protection of Privacy Act (RSO 1990, c. F. 31).

Accessible Learning collects information from students about their disability, functional limitations stemming from their disability, and other disability-related information sufficient to support accommodation planning for studies at university.  Accessible Learning also collects information about the student's academic studies at Laurier, including academic status, as well as identifying information such as name, birthdate, contact information, and emergency contact details.  

Accessible Learning collects this information to provide accommodation services and supports to students with disabilities.  Examples of supports and services include determining a student’s eligibility for accessibility services, developing individualized accommodation plans, determining eligibility for university and government bursaries, facilitating referrals to on and off-campus supports and services, and supporting informal or formal academic appeals. 

Further information about how the university collects, uses, and discloses personal information can be found in Laurier’s Notice of Collection, Use or Disclosure of Personal Information and Policy 10.1 Privacy Protection and Information Access.

Collection of Personal Information

Accessible Learning primarily collects information through the disability documentation it requires from students when registering with the service. Information is also collected directly from students through in-person, phone or video meetings, email communications, and from their Laurier student account through LORIS. 

Students are required to submit their disability documentation to Accessible Learning via upload to our secure server. 

Students are advised not to submit their disability documentation to Accessible Learning using email as secure transmission using this medium is not guaranteed. 

Indirect Collection 

Accessible Learning does not permit indirect collection of personal information from third parties or family members without the student's explicit knowledge.  Personal information submitted to Accessible Learning without the student’s direct knowledge will not be accepted.  

Confidentiality and Protection of Personal Information

The University is committed to maintaining confidentiality to the greatest extent possible when providing academic accommodation and related support services to students with disabilities. All information provided by students, including written documentation related to their disability and information disclosed by students to Accessible Learning personnel during in-person, phone, or video meetings, or in email communication, is held in strictest confidence. Accessible Learning ensures that the personal information collected from students is protected from unauthorized access, modification, use, disclosure, or destruction. Accessible Learning’s collection, use and maintenance of student personal information is monitored and managed according to the University’s policies and service standards and in compliance with privacy legislation.   

Accessible Learning collects and maintains student electronic records through the Accessible Information Management (AIM) solution. As per Policy 9.5 External Information Technology and Cloud Services Policy, a Privacy and Security Impact Assessment was completed on AIM and approved its use for confidential internal and restricted information, which includes personal health information.  Users should be aware that AIM is a cloud-based solution and that the data they submit to Accessible Learning through AIM is encrypted and stored on AIM servers outside of the university.   

Accessible Learning also maintains records in hard copy for students who registered with Accessible Learning before January 2019. These files are kept in locked filing cabinets housed within Accessible Learning spaces on Waterloo and Brantford campuses. Only Accessible Learning personnel is authorized access to student records that are collected and maintained by Accessible Learning. 

File Destruction Schedule

In accordance with the following file maintenance schedule, students can request electronic copies of their information with Accessible Learning even after leaving Laurier:

  • Paper Files - Files created for students who registered with Accessible Learning before 2019 are maintained for eight (8) years after they first registered, or one (1) year after they leave Laurier if they were registered with Accessible Learning for longer than eight (8) years.
  • Electronic Files - Files created for students in our electronic client management system after 2019 are maintained for eight (8) years after their last contact with Accessible Learning.

Once these time periods have passed, Accessible Learning electronically deletes or shreds files via a confidential shredding service.  

Privacy Breach Protocol

In accordance with the University’s Privacy Breach Protocol, Accessible Learning is obligated to notify the Privacy Office of any confirmed or suspected breaches of personal privacy, including accidental or unauthorized disclosure, access, theft or loss.

Use and Disclosure of Personal Information

Accessible Learning does not share information about a student's disability with anyone else within or external to Wilfrid Laurier University without the student's explicit consent. Accessible Learning personnel will communicate with others about a student’s disability in relation to their need for accommodation, such as with parents or health care providers, only at the student’s explicit request and their written consent. Information about accommodations will be shared as noted below. 

Students are not required and are advised not to share any information about their disability with anyone outside of Accessible Learning for the purposes of obtaining academic accommodations including with instructors or staff within academic departments.   

Information about a student's disability, their registration with Accessible Learning, and/or their receipt of academic accommodations does not appear on any official file with the University, including transcripts, LORIS accounts, or degree documents. 

Exceptions

There are some exceptions where the University may be required to disclose personal information about students with others. These exceptions include but are not limited to: 

  • In accordance with University policy 
  • If there is a known risk of serious harm to the student or another person 
  • In the case of apparent, reported, suspected or potential child abuse or neglect 
  • In response to a court order or summons for records or testimony 
  • If a student reports sexual abuse by a Regulated Health Care Professional 
  • In compassionate circumstances, to facilitate contact with a spouse, a close relative or a friend of an individual who is injured, ill, or deceased 
  • To an institution or a law enforcement agency in Canada if: 
    • the disclosure is to aid in an investigation undertaken by the institution or the agency with a view to a law enforcement proceeding, or 
    • there is a reasonable basis to believe that an offence may have been committed and the disclosure is to enable the institution or the agency to determine whether to conduct an investigation 

Sharing of Accommodation-Related Information

Letter of Accommodation

Accessible Learning issues to all students a valid Letter of Accommodation (LoA) once their accommodation plan has been finalized. 

The LoA serves as a written agreement between Wilfrid Laurier University and the student outlining the academic accommodations for which they have been approved. No information pertaining to the student's disability is reproduced on the LoA. 

Accessible Learning works with students to communicate the accommodation information contained in their LoA to instructors, teaching assistants, academic departmental staff and administrators, practicum and field placement staff, and others as required.  Communication of accommodation information is essential to ensuring that all accommodations are properly implemented in a timely fashion for students with disabilities at Laurier. WLU also shares accommodation information using direct electronic feeds with departments such as Online Learning, and other units involved with arranging student academic accommodations for final exams. 

In all these communications, Accessible Learning shares accommodation information only on a need-to-know basis sufficient to facilitate implementation of the student's accommodations. No information about the student's disability or the reason for their registration with Accessible Learning is ever shared in these communications. 

Student Queries 

Student may speak with the Manager of Academic Accommodations regarding any questions or concerns they have about how their personal information is collected, used, stored, shared, or disclosed by Accessible Learning.