Policy Directive: 003-15 Modernized Fasttrack Information System Policy on Security and sharing of Information among Children’s Aid Societies



Effective Date

This Policy Directive is effective December 1, 2015.

This policy directive, now issued under s. 20.1 of the Child and Family Services Act (CFSA), replaces the “Child Protection FastTrack Information System Policy on Security and Sharing of Information among Children’s Aid Societies,” revised February 2010.

All Children’s Aid Societies (CASs) are required to use FastTrack in accordance with this policy directive, including CASs that are using the Child Protection Information Network (CPIN).

Introduction

The modernized Child Protection FastTrack Information System (FastTrack) is a database application containing the names of children and families:

  1. Who are receiving or who have received a child protection service from an Ontario Children’s Aid Society (CAS); or
  2. Who are the subjects of records extracted from a CAS’s online case management system.

The information in the FastTrack database is drawn directly from the files of Ontario CASs, and is a limited subset of that information.

FastTrack allows a CAS to determine, through a database search, whether or not a person is currently receiving a child protection service from a CAS, is the subject of a record extracted from a CAS, or is the subject of a Child Protection Alert. CASs are required, within 24 hours after receiving information that a child is or may be in need of protection, to search FastTrack for information that may be relevant in determining whether or not there are reasonable and probable grounds to believe that the child or any other child in the same family is in need of protection (Ontario Regulation 206/00).

This directive now requires CASs to use FastTrack to perform child welfare records checks for Caregiver Applicants, as defined in section 4, below. Please note that this directive provides direction specific to the use of FastTrack; it does not provide comprehensive direction about caregiver screening. Applicable regulations, policies, guidelines and/or tools should be consulted for direction about other steps involved in screening prospective caregivers.

CASs have a duty to protect the privacy of clients’ personal information. CASs are expected to have written policies regarding the collection, use, access and disclosure of personal information that are consistent with the principles and provisions of applicable privacy legislation and policy.

FastTrack is intended to provide a CAS worker with enough information to assist in making a decision about action to be taken immediately; however, its primary purpose is to direct CAS staff to the CAS which has more complete information about the child and/or family.

FastTrack is a database of information extracted from CAS records about individuals associated with child protection investigations and individuals who are the subject of a Child Protection Alert. It is not intended to include information about individuals who have contacted the CAS for other reasons (e.g., request for counselling; volunteer services; references). In terms of the Ontario Child Welfare Eligibility Spectrum, this means that when a case/referral is coded as being eligible for a protection investigation, information about individual members of this case will be extracted to FastTrack.

FastTrack was created in 1999-2000; records dating back to 1990 (and sometimes earlier) are contained in FastTrack. When there is reason to believe that a prospective caregiver may have a record with another CAS that may not be in FastTrack (e.g., a record prior to 1990, before which time records are not consistently found in FastTrack), or a record from another province, the CAS should take steps to follow up with the relevant CAS or other child welfare authority in accordance with the relevant regulation, policy or tool. In such cases where a repeat check is required after the FastTrack Policy Directive has been implemented, FastTrack should be used for this purpose, even if it was not used for the initial or previous child welfare records check.

FastTrack receives extracts of information from CAS databases through an extraction routine each business day, which includes any modifications to existing records since the previous extraction as well as any new records. As there is a time-gap between the time when a file may be added or modified (at the CAS) and the time when the daily extraction upload to FastTrack takes place, there is the possibility that some essential information may not be present in FastTrack when staff are conducting a search.

Because the information on FastTrack is a subset of CAS files, clients wishing access to FastTrack information are directed back to the originating CAS.

Principles

The following principles will guide the sharing of information among CASs:

  • The best interests, protection and well-being of the child are paramount as set out in the CFSA.
  • Unless prohibited by court order or legislation, CASs have the responsibility to share information for the purpose of protecting children.
  • CASs must share information among themselves in a consistent manner.

Policy

  1. Notice of Collection of Information:
    Prior to the conclusion of an investigation, persons who were the subjects of a child protection investigation shall be informed that information regarding the investigation will be placed on FastTrack.
  2. Child Protection Investigations: In response to information received by a CAS that a child is or may be in need of protection, a child protection worker shall, within 24 hours, conduct a Prior Contact Check (defined as searching FastTrack for a record of prior contact between an individual and any CAS in Ontario) to determine whether there is information on FastTrack about prior contact between any CAS and:
    1. the child(ren)
    2. any member of the child’s family (where relevant in assessing child protection concerns);
    3. the alleged perpetrator; and
    4. any other person having access to or charge of the child (where relevant in assessing child protection concerns).
  1. The relevant information from the Prior Contact Check is recorded in the case record. The child protection worker also obtains the relevant detailed case information from the other CAS(s), in accordance with the procedures section of this policy and without any requirement of client consent, prior to initiating contact with the subject family or as soon as possible thereafter.
  2. Screening of prospective caregivers:
    For the purposes of satisfying the regulatory and policy requirements listed below, and as part of the process of screening prospective caregivers, designated CAS staff will conduct a Prior Contact Check of the following types of Caregiver Applicants, defined throughout this policy as:
    1. Prospective Kin Service providers, including other adults (defined in this policy as individuals ages 18 and over) living in the home (as required by Ontario Regulation 206/00);
    2. Prospective Place of Safety providers, pursuant to s.37(5)(b) of the CFSA, including other adults living in the home (as required by Ontario Regulation 206/00 and Ontario Regulation 70);
    3. Prospective CAS Foster Care[1] , Kin Care, Formal Customary Care and Public Adoption applicants / caregivers, in all cases including other adults living in the home (as required by Policy Directive 001-09, which mandates the use of the SAFE Homestudy Tool for these prospective caregiver types).
    4. Private Adoption Applicants (which includes Private Adoption Applicants for international adoptions, and includes other adults living in the home of the applicant) consistent with the terms and conditions of private adoption licenses, which require the use of the SAFE Homestudy Tool for private adoption applicants.

    Retroactive use of FastTrack for caregivers already assessed is not permitted, meaning FastTrack should not be searched as part of a caregiver assessment which is completed prior to the implementation of this policy.

    The only exception to this would be where a requirement exists to repeat the check after a certain period of time. For example, if there is reason to believe that a prospective caregiver may have a record with another CAS that may not be in FastTrack (e.g., a record prior to 1990, before which time records are not consistently found in FastTrack), or a record from another province, the CAS should take steps to follow up with the relevant CAS or other child welfare authority in accordance with the relevant regulation, policy or tool. In such cases where a repeat check is required after the FastTrack Policy Directive has been implemented, FastTrack should be used for this purpose, even if it was not used for the initial or previous child welfare records check.

Note: The remainder of this section (sections 5-6) does not apply to the screening of private adoption applicants. See sections 18-20 for procedures relating to the screening of private adoption applicants.

  1. CASs will not conduct Prior Contact Checks of any Caregiver Applicant without the consent of the Caregiver Applicant. Caregiver Applicants should be informed by the CAS, as part of giving consent, that:
    1. a search of their name will be conducted on FastTrack, a provincial database application which extracts records from all CASs across Ontario, including both open and closed records;
    2. in providing consent for a search of their name in FastTrack, they are also consenting to the CAS following up with any other CAS to request its record, in accordance with this policy; and,
    3. the existence of a record in FastTrack will not necessarily preclude them from being approved to become a caregiver. Previous child welfare involvement is one of a number of factors in the assessment of an applicant’s ability to provide care.
  2. Where FastTrack indicates there has been prior contact between a CAS and a Caregiver Applicant, the relevant information from FastTrack concerning the contact is included in the case record. The CAS worker also obtains the relevant detailed case information from the other CAS(s) in accordance with the applicable regulation or policy directive, and in accordance with the procedures section of this policy directive.
  1. Requesting information and responding to requests pursuant to a FastTrack check:
  2. Each CAS must follow the procedures outlined in this policy directive in requesting information pursuant to a Prior Contact Check, and in responding to requests for information from another CAS pursuant to a check of FastTrack.
  3. Prior to responding to a request for information from another CAS, the responding CAS worker will review the record to determine whether it may be subject to any legislative or court ordered restrictions on disclosure.

Designation and authorization to use FastTrack:

  1. Each CAS must designate specific CAS employees to receive information requests and coordinate responses to requests for information pursuant to checks of FastTrack.
  2. Prior Contact Checks must only be conducted by a CAS child protection worker, by a supervisor of the authorized staff member or by a CAS employee designated by the local CAS to perform Prior Contact Checks.
  3. On a quarterly basis, the ministry, through FastTrack Support in the Children, Youth and Social Services I&IT Cluster (CYSSC), will send to each CAS a list of all GO-PKI certificate users, identifying those who have not accessed the FastTrack Information System in the past 3 months.
    1. On the basis of its review, the CAS will determine which GO-PKI Certificates are no longer required and submit revocation requests to CYSSC Security for processing. (Forms available at FastTrack). Where a Certificate has not been accessed within the past 3 months, but the CAS does not want the Certificate deleted (e.g., where an employee is on temporary leave), CASs are required to request that access to FastTrack be suspended for that employee. Suspended access can later be reactivated at the request of the CAS.
    2. All CASs are expected to confirm in writing to FastTrack Support that a review has taken place, even if there are no changes. CASs are to send a copy of this written confirmation to their Program Supervisor.

Monitoring and auditing:

  1. Use of FastTrack for purposes other than conducting Prior Contact Checks in response to information received by a CAS that a child is or may be in need of protection or for the screening of Caregiver Applicants (as defined in section 4) is prohibited.
  2. Use of FastTrack will be monitored and audited periodically to ensure that use of FastTrack complies with this policy directive.
  3. Note: The Child Abuse Register (CAR) is a separate and distinct database from FastTrack, and nothing in this policy authorizes access to CAR; the use of CAR is governed by ss.75-76 of the CFSA, Regulation 71, and ministry policies specific to CAR. The use of CAR is monitored and audited periodically.

Procedures

Child Protection Investigations – Procedures:

  1. Prior Contact Checks must be made within 24 hours after receiving information that a child is or may be in need of protection.
  2. Where FastTrack indicates that there has been prior contact with one or more other CASs, the investigating worker must make a request for information to the relevant CAS(s) in order to:
    1. verify that the person(s) identified in FastTrack is/are the person(s) about whom the Prior Contact Check was made;
    2. determine whether the record(s), or part of the record(s), is/are needed;
    3. determine whether the record is subject to any legislative or court ordered restrictions on disclosure

    Where a prior contact with a CPIN CAS has been determined, CPIN CASs should access the records through CPIN, to the extent possible. CPIN CASs should also contact CPIN CASs with records to determine whether the other CPIN CAS has uploaded all records to CPIN and should obtain from the other CPIN CAS any records that are not in CPIN.

  3. Where prior contact has been determined through a FastTrack check, the request for information must be made as soon as possible to an employee in the relevant CAS who is designated to receive such requests. The request may be made by telephone, but must be confirmed in writing as soon as possible and no later than 24 hours. The request must be recorded in the case record of the persons to whom the information relates.

Screening of Caregiver Applicants (excluding private adoption) – Procedures:

  1. Where the FastTrack check indicates there has been previous contact between a CAS and a Caregiver Applicant (excluding Private Adoption Applicants), the worker conducting the Prior Contact Check must make a request for information to the relevant CAS(s), confirming the Caregiver Applicant’s consent has been received in accordance with this policy, in order to:
    1. verify that the person(s) identified in FastTrack is/are the person(s) about whom the Prior Contact Check was made;
    2. determine whether the record(s), or part of the record(s), is/are needed; and,
    3. determine whether the record is subject to any legislative or court ordered restrictions on disclosure.

    Where a prior contact with a CPIN CAS has been determined (for screening of Caregiver Applicants excluding Private Adoption Applicants), CPIN CASs should access the records through CPIN, to the extent possible. CPIN CASs should also contact CPIN CASs with records to determine whether the other CPIN CAS has uploaded all records to CPIN and should obtain from the other CPIN CAS any records that are not in CPIN.

Screening of private adoption applicants – Procedures:

  1. A CAS will use FastTrack to conduct a Prior Contact Check of a Private Adoption Applicant at the request of the private adoption practitioner and with the consent of the Private Adoption Applicant. Before conducting a Prior Contact Check of a Private Adoption Applicant, the CAS should ensure that it has received a consent form signed by the Private Adoption Applicant.
  2. After conducting the requested check of FastTrack referred to in section 18, the CAS will respond in writing to the private adoption practitioner within 30 days or as soon as possible, stating the results of the FastTrack search, including:
    1. the name(s) searched in FastTrack (if previous/other names were identified on the consent form, these should all be searched in FastTrack);
    2. whether or not records were found in FastTrack;
    3. if records were found, the name and date of birth associated with any record(s) found, and the name(s) of the CAS(s) holding the record(s);
    4. a statement that the private adoption practitioner is responsible for contacting any other CASs directly to acquire more complete information, as needed;
    5. an indication of any other record system, in addition to FastTrack, which was searched, and the results of this search (e.g., if the CAS has searched FastTrack and its own records system, this should be indicated in the response to the private adoption practitioner); and,
    6. if the CAS conducting the search identifies a record within their own agency, then further information about the contents of the record should be provided.
  3. The CAS will not disclose information from FastTrack to the adoption practitioner about any individual other than the Private Adoption Applicant(s) and not without the Private Adoption Applicant’s signed consent.

General Procedures

NOTE: Sections 21-26 apply both to child protection investigations and to screening of prospective caregivers, excluding Private Adoption Applicants.

  1. The written request for information following a Prior Contact Check should be sent securely and should include the following:
    1. date and time of the verbal request, if applicable;
    2. file number;
    3. name of the requesting CAS;
    4. name and complete contact information of the investigating worker;
    5. confirmation that the information is being requested in order to investigate a child protection concern or to screen a Caregiver Applicant, in accordance with this policy directive;
    6. the names of the persons which FastTrack indicated had prior contact with the CAS; and,
      1. are relevant to investigate the information received by the CAS that a child is or may be in need of protection; or,
      2. are relevant to screen a Caregiver Applicant in accordance with this policy directive;
    7. confirmation that all persons identified in sub-bullet 22.f.ii, above, have provided consent as defined in section 5 of this policy;
    8. the nature of the information requested, and the date/time the information is required.
  1. The designated CAS staff member must respond to a request, or ensure that the relevant worker(s) or supervisor(s) responds, within the time set out in the request, unless otherwise agreed, and in line with any applicable regulation or policy. Documentation of the response must be included in the records of the persons to whom the information relates.
  2. The worker from the responding CAS should use clinical judgment to determine which records are relevant to be shared with the requesting CAS. Records which are relevant must be shared with the CAS requesting the records, except where there are legislative or court ordered restrictions on disclosure.
  3. The information must be sent in a secure manner to the requesting CAS, in a format that the CAS can use, and should include the following:
    1. the name and complete contact information of the person responding;
    2. confirmation that the information being shared is not subject to legislative or court-ordered restrictions on disclosure;
    3. the sections of the record being provided.

    Where a prior contact with a CPIN CAS has been determined, CPIN CASs should access the records through CPIN, to the extent possible. CPIN CASs should also contact CPIN CASs with records to determine whether the other CPIN CAS has uploaded all records to CPIN and should obtain from the other CPIN CAS any records that are not in CPIN.

  4. The information that a CAS receives from another CAS pursuant to a Prior Contact Check becomes part of the receiving CAS's record; the receiving CAS may share this information with a third CAS pursuant to a future prior contact check.
  5. CASs will record, transmit and manage the information received from another CAS with the same level of security and confidentiality as is required for their own files and in accordance with this policy directive.

Effective Date

This Policy Directive is effective December 1, 2015.

Issuance of Policy Directive CW003-15: December 1, 2015

Original signed by:

Jennifer Morris
Assistant Deputy Minister (A)
Policy Development and Program Design Division
Ministry of Children and Youth Services

Rachel Kampus
Assistant Deputy Minister
Service Delivery Division
Ministry of Children and Youth Services

Footnotes

[1] For the purposes of this directive, a person who is 18 or older and under the age of 21 is defined as a "youth".

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