Privacy Policy

1. Who We Are

New Steps Independent Living Program (“we,” “us,” “our”) is a Canadian-controlled private corporation located at 431 Thames Avenue, Winnipeg, MB R2L 0V4. We provide housing, independent living support, and family reunification services to youth and families in the child welfare system.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website and submit information through our online forms.

2. Laws That Govern How We Handle Your Information

We are a private, for-profit corporation. The privacy rules that bind us are:

• PIPEDA — the Personal Information Protection and Electronic Documents Act (Canada). This is the federal private-sector privacy law that applies to us. It sets the fair-information principles we follow, and under section 10.1 it requires us to report a breach of our security safeguards to the Privacy Commissioner of Canada and to notify you, if the breach creates a real risk of significant harm to you.
• The Child and Family Services Act (Manitoba), s. 76 — a record made under that Act is confidential, and it may only be disclosed as that section allows. We hold CFS-origin records as a person retained or consulted by an agency (s. 76(3)(d)), and we share information from them only on a lawful basis.
• PHIA-equivalent safeguards — we are not a “trustee” under The Personal Health Information Act (Manitoba), so PHIA does not bind us. We apply safeguards equivalent to PHIA's to any health information we hold.

3. What Information We Collect

We collect personal information only when you voluntarily provide it through the following channels:

a) Intake / Housing Application Form

Required: your name, your age, how you'd like us to contact you, a description of your situation, and your confirmation that you understand how we use this. Everything else is optional.

• Your name
• Your age
• Phone number (optional) and email address (optional)
• How you'd prefer to be contacted (phone, email, text, or any)
• Gender identity, including a self-description if you choose to give one (optional)
• Your community (optional)
• What's going on for you right now — a free-text description in your own words
• Whether you are involved with CFS — yes, no, or not sure (optional)
• Your caseworker's name, phone number, and email address (optional)
• Your confirmation that you understand how we use this

We do not ask for your date of birth, a mailing address, or an emergency contact on this form.

b) Professional Referral Form

• Referring professional's name, agency, role, phone number, and email address
• Youth's name and age
• Youth's gender (optional)
• The youth's current housing situation
• Whether the youth is involved with CFS — yes, no, or unknown
• Reason for the referral and relevant background — a free-text description written by the referring professional
• Placement timing — whether the referrer is planning ahead, looking within the next few months, or hoping for a room as soon as one is open
• The referring professional's confirmation that they have the youth's consent or the legal authority to make the referral

This form does not collect the youth's own phone number, email address, or mailing address.

c) Contact Form

• Name and email address
• Who you are — youth, family member, professional, volunteer, donor, or other
• Message content

This form does not collect a phone number.

d) Automatic Website Data

This happens only if you accept analytics on the cookie banner. If you decline, or accept only what is necessary, neither analytics service is loaded at all and none of the information below is collected. If you do accept, Google Analytics and Vercel Analytics collect page views and basic technical information — the page address you visited, page title, referring website, browser and device details, language, screen size, a visitor identifier, and your IP address. We do not use this data to identify individual visitors, and we do not combine it with anything you submit through a form. Both services process this data in the United States. Section 10 sets out exactly what each service receives and how to change your choice.

4. How We Use Your Information

• Assess your eligibility for housing and programs
• Contact you about your application or referral
• Coordinate services with referring professionals (with your knowledge)
• Schedule and manage facility tours
• Respond to your inquiries
• Comply with legal and reporting obligations
• Improve our programs and website

We will never sell your personal information. We will never use it for marketing purposes without your explicit consent.

5. Who Has Access to Your Information

Access to your personal information is strictly limited to:

• New Steps ILP staff directly involved in intake, housing, and program delivery
• Referring professionals only to the extent necessary to coordinate your care
• Authorized third-party service providers who help us operate the website and deliver your submission to us — Sections 6 and 10 name them and say where they process your information
• Government or regulatory bodies only when required by law

6. How We Store and Protect Your Information

• Encryption in transit: Form submissions are transmitted using SSL/TLS encryption (HTTPS)
• Access controls: Submissions are delivered to a monitored New Steps ILP staff mailbox. Only staff who need the information to do their job have access to it
• Physical security: Paper records are stored in locked filing cabinets in secure offices
• Staff training: All staff with access to personal information receive privacy and confidentiality training

Where your information is processed

We want to be straightforward about this, because it matters. Your information is not processed or stored in Canada on its way to us. This website runs on Vercel Inc. and our form submissions are delivered by Resend Inc. — both United States companies:

• Vercel (United States): hosts this website. When you submit a form, it is received and processed by a Vercel server in Washington, D.C.
• Resend (United States): delivers the submission to our staff mailbox as an email. The email carries everything you entered on the form. Resend processes and stores it on servers in Northern Virginia. Resend does not offer a Canadian processing region.
• Google Analytics and Vercel Analytics (United States): process website usage data — but only if you accept analytics on the cookie banner. See Sections 3(d) and 10.

Information held in the United States may be accessible to U.S. authorities under U.S. law. This website does not run a database or a case-management system — your submission is delivered as an email and is not stored by the website itself.

7. Data Retention

What is true today: the schedule above is the standard we apply to our program records. Information you send through this website currently reaches us as an email and is held in a New Steps ILP staff mailbox, and by our email provider, as described in Section 6. We are building the record system that will apply this schedule to website submissions automatically. Until it is in place, ask us and we will tell you what we hold and delete what we can — see Section 8.

8. Your Rights

To use any of these rights, email our Operations Manager at admin@newstepsilp.com (Section 11). We will respond within 30 days of receiving your request. If we need more time, we will tell you why and how long we need.

• Access: You can ask us what personal information we hold about you
• Correction: You can ask us to correct any inaccurate information
• Withdrawal of consent: You can withdraw your consent by emailing the address above. Tell us what you want us to stop doing and we will confirm what we have done. Withdrawing consent may affect your ability to participate in programs
• Deletion: You can request deletion of your personal information, subject to legal retention requirements and to the limits described in Section 7
• Complaint: You can complain to us directly using the address above. You can also file a complaint with the Office of the Privacy Commissioner of Canada, which oversees PIPEDA (Section 11)

9. Consent

For youth ages 16–17: We recognize that youth in CFS care may not have a parent or guardian readily available to provide consent. We follow the guidance of the Office of the Privacy Commissioner of Canada on meaningful consent, which treats a young person's own consent as valid where they can understand the nature and consequences of what they are agreeing to. We use clear, plain language in our forms so that youth can provide meaningful consent.

For youth ages 18–21: You provide your own consent.

For professional referrals: The referring professional warrants that the youth is aware of and consents to the referral, or that the referral is made under lawful authority.

10. Cookies and Tracking

Nothing is loaded and nothing is sent until you choose “Accept All.” Both analytics services below are held back by the cookie banner. If you choose “Decline All” or “Accept Necessary,” or make no choice at all, neither script is requested, no analytics cookie is created, and no record of your visit — including the address of the page you are reading — is transmitted to either company.

This Site uses the following third-party services:

• Google Analytics (GA4): website analytics, loaded only after you choose “Accept All.” It also runs under Google Consent Mode v2, which is set to denied by default as a second safeguard. If you accept, Google receives, for each page you view: the page address and page title, the referring website, your browser, device, and operating system, your language and screen size, a randomly generated visitor ID stored in a cookie on your device, and your IP address. Google processes this in the United States.
• Vercel Analytics: page-view and performance monitoring provided by our hosting platform (Vercel Inc., USA), loaded on the same condition — only after you choose “Accept All.” It is cookieless: it stores no identifier on your device, and a visit is identified by a hash of the incoming request that Vercel discards after 24 hours. If you accept, it receives, for each page you view: the page address and route pattern, the referring page, filtered query parameters, an approximate location (country, region, city) derived from your IP address, and your browser, operating system, and device type.
• Resend: Email delivery service (Resend Inc., USA) used to deliver your submission to our staff and to send you a confirmation email. The entire contents of your form submission are transmitted to and processed by Resend in the United States — not just your name and email address. For an intake submission, that includes your age, contact details, gender identity, community, whether you are involved with CFS, your caseworker's name and contact details, and everything you wrote in your own words. For a referral it includes the youth's name and age and the full referral narrative. See Section 6.

Our fonts are served from this website, not from Google. We do not use advertising cookies or tracking pixels, and we do not engage in behavioural advertising.

How to change your mind

The cookie banner appears on your first visit and stores your choice in your browser. To change it, use the Cookie preferences button at the bottom of every page, or the button below. Either one erases your stored choice and re-opens the banner so you can choose again. You do not need to clear your browser data. Withdrawing takes effect immediately — analytics stop and load no further — but page views recorded before you withdrew have already been sent and cannot be recalled.

For anything else — including withdrawing consent to information you have already sent us — email us at admin@newstepsilp.com.

11. Privacy Contact

Our Operations Manager is accountable for privacy at New Steps ILP and is the person who answers access, correction, withdrawal, deletion, and complaint requests. We respond within 30 days.

If you are not satisfied with our answer, you can complain to the regulator that oversees PIPEDA:

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top will reflect the most recent revision. We encourage you to review this page periodically.