Privacy Policy

1 Commitment to Privacy Protection

At Divine Fingers Health Care Services Inc. ("Divine Fingers", "we", "us", or "our"), safeguarding the confidentiality, integrity, and security of personal information and personal health information (PHI) is a fundamental organizational mandate.

This Privacy Policy outlines how we collect, use, disclose, retain, and protect information across our website (divinefingershealthcareservice.ca), staff onboarding systems, facility staffing portals, and dispatch operations. We adhere strictly to the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada and Ontario’s Personal Health Information Protection Act, 2004 (PHIPA).

2 Categories of Information We Collect

Depending on your relationship with Divine Fingers, we collect only the minimum necessary information required to deliver certified staffing and care solutions:

• Healthcare Job Seekers & Caregivers: Full legal name, contact details, curriculum vitae, College of Nurses of Ontario (CNO) registration numbers, nursing education credentials, CPR/First Aid certifications, immunization & TB screening history, Vulnerable Sector Police Screening results, government-issued photo ID, and direct deposit payroll details.
• Healthcare Facility Clients: Organization name, clinical facility address, administrative contact person, telephone lines, billing emails, shift coverage requisitions, specialized unit clinical requirements, and facility-specific orientation acknowledgments.
• Website Visitors & Inquiries: Contact form submissions (name, email, phone, message contents), IP address, browser user-agent string, and essential session authentication cookies.

3 Purpose of Collection & Use

Information collected by Divine Fingers is used strictly for legitimate healthcare recruitment, operational dispatch, and clinical compliance purposes, including:

• Verifying professional nursing licenses in good standing with the CNO and credentialing bodies.
• Matching qualified RNs, RPNs, and PSWs with appropriate clinical facility shift requests and patient care needs.
• Processing payroll, direct deposits, CRA tax reporting, and employment documentation.
• Dispatching critical operational notifications (e.g., shift assignments, 2-hour emergency surge shift relief, portal security one-time passcodes).
• Maintaining corporate compliance under Ontario Ministry of Health and Long-Term Care staffing guidelines.

4 Personal Health Information (PHI) & PHIPA Safeguards

When Divine Fingers provides nursing and personal support services to hospitals, retirement residences, and long-term care homes (who act as Health Information Custodians under PHIPA):

• Our dispatched clinicians are bound by strict professional confidentiality obligations and PHIPA standards regarding all resident/patient medical records encountered during shift duty.
• Divine Fingers does NOT store or host resident personal health records or patient clinical charts on its public website servers.
• Shift requests submitted by facilities identify staffing requirements, units, and ratios without transmitting unnecessary identifiable patient health information over unencrypted web channels.

5 Technical & Organizational Security Defenses

We maintain physical, technical, and administrative safeguards designed to protect your data against accidental loss, unauthorized access, and cyber threats:

• In-Transit Encryption: All web traffic is strictly encrypted using Transport Layer Security (TLS 1.3 / HTTPS) with modern cipher suites.
• Database Encryption & Credential Hashing: Sensitive database records are stored in managed cloud infrastructure with TLS database connections and password credentials protected by salted 12-round bcrypt cryptography.
• Multi-Factor Authentication (MFA): Administrative and operational accounts are protected by rolling Time-based One-Time Passwords (RFC 6238 TOTP) and mandatory email verification OTP codes.
• Role-Based Access Control (RBAC): Employee access to applicant resumes, police checks, and client contracts is strictly segregated based on minimum operational clearance.

6 Data Retention & Secure Disposal

We retain personal information only for as long as necessary to fulfill the operational purposes for which it was gathered, or as mandated by Canadian statutory retention periods (such as employment records and payroll tax filings mandated for 7 years by the Canada Revenue Agency). When records exceed their required statutory retention window, they are destroyed through cryptographically verified digital wiping and secure media shredding.

7 Your Privacy Rights & Access Requests

Under PIPEDA and applicable provincial privacy legislation, individuals have the right to:

• Request access to the personal information held by Divine Fingers concerning them.
• Request corrections or updates to inaccurate, incomplete, or outdated credentials.
• Withdraw consent for optional non-essential communications (such as our healthcare industry newsletter).