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 0R4. We provide housing, independent living support, and family reunification services to Indigenous 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 committed to complying with all applicable privacy legislation, including:

• PIPEDA — Personal Information Protection and Electronic Documents Act (Federal Canada)
• FIPPA — The Freedom of Information and Protection of Privacy Act (Manitoba)
• PHIA — The Personal Health Information Act (Manitoba)

3. What Information We Collect

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

a) Intake / Housing Application Form

• Full name, date of birth / age, gender identity (optional)
• Contact information (phone, email, mailing address)
• Current housing situation
• CFS involvement status and history
• Cultural/community background (voluntarily provided)
• Emergency contact information

b) Professional Referral Form

• Referring professional's name, title, organization, and contact information
• Youth's name and contact information (with the youth's knowledge)
• Reason for referral and relevant background information

c) Contact Form

• Name, email address, phone number (optional)
• Message content

d) Automatic Website Data

When you visit our Site, we may automatically collect browser type, pages visited, referring website, and IP address (anonymized where possible). We use this data in aggregate to improve the Site and do not use it to identify individual visitors.

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 (contractually required to protect your information)
• Government or regulatory bodies only when required by law

6. How We Store and Protect Your Information

• Encryption: Form submissions are transmitted using SSL/TLS encryption (HTTPS)
• Access Controls: Only authorized staff can access personal information, using role-based access controls
• Secure Storage: Digital records are stored on encrypted, access-controlled systems hosted in Canada
• 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

7. Data Retention

8. Your Rights

• 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 at any time (this may affect your ability to participate in programs)
• Deletion: You can request deletion of your personal information, subject to legal retention requirements
• Complaint: You can file a complaint with the Office of the Privacy Commissioner of Canada or the Manitoba Ombudsman

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. Under PIPEDA, a minor's consent is valid if the individual understands the nature and consequences of the collection, use, or disclosure. 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

This Site uses the following third-party services:

• Google Analytics (GA4): Website analytics to understand how visitors use the Site. Operates under Google Consent Mode v2 — analytics data is only collected after you accept cookies. Google may process data in the United States.
• Vercel Analytics: Privacy-focused performance monitoring provided by our hosting platform (Vercel Inc., USA). Collects anonymized page view data.
• Resend: Email delivery service (Resend Inc., USA) used to send confirmation emails when you submit a form. Your name and email address are transmitted to Resend for delivery purposes only.
• Google Fonts: Typography served by Google. Your browser makes requests to Google servers to load fonts.

We do not use advertising cookies or tracking pixels. We do not engage in behavioural advertising. Cookie preferences can be managed through the consent banner displayed on your first visit.

11. Privacy Contact

If you have questions about this Privacy Policy or want to exercise your privacy rights, contact:

You may also contact:

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.