Governance Commitments

At Stepped Care Solutions, we recognize the growing importance of Environmental, Social, and Governance (ESG) factors in building a sustainable and responsible organization. Our commitment to these principles is embedded in our existing policies and practices.

Environmental Stewardship

Guided by our vision of Wellbeing Everywhere, SCS believes that the wellbeing of individuals is inseparably linked to the health of our communities and the planet. To minimize our environmental footprint, we operate as a fully virtual organization, significantly reducing travel-related emissions and in-office impacts. Our environmental stewardship efforts encourage our workforce to adopt sustainable practices. These efforts reflect our dedication to climate justice as an integral aspect of our organizational principles of social justice and diversity.

Social Responsibility

Our commitment to social responsibility includes prioritizing the wellbeing of our employees, partners, and clients. We promote a diverse and inclusive workplace through our unique approach to social justice and equity, known as Synergy. This approach emphasizes interconnectedness and addresses systemic issues like colonialism, racism, and sexism to foster restorative solutions in mental health care transformation. We have developed various policies and initiatives to promote synergy, ensuring these values are deeply embedded throughout our organization. We are also actively building our team’s capacity to apply synergy in all facets of our work, advancing our goal to be a transformative organization.

Governance Integrity and Framework

SCS is committed to upholding the highest standards of ethical behaviour and corporate governance. Our Board of Directors provides oversight of our corporate strategy, risk management, governance practices, and human capital development. Reflecting our values, the Board prioritizes diversity. It is composed of a diverse group of individuals with a variety of skills, backgrounds, perspectives and lived experiences, each contributing to our mission to improve access to mental health care. With an independent Chair and fully independent committees, our Board’s structure reinforces our dedication to transparency, accountability, and ethical decision-making.

SCS remains committed to reviewing and refining our policies annually, ensuring they reflect our evolving understanding of how we can best contribute to a healthier planet, more equitable society, and responsible governance.

Stepped Care Solutions is dedicated to transforming mental health systems to achieve Wellbeing Everywhere. We believe that the heart of mental health and substance use health systems are people and human connection. We view Artificial Intelligence (AI) as a useful tool in the right context and with the right conditions, and one that cannot replace the value of human capacity.

Our Foundational Principles

Every use of AI at SCS is rooted in our core values and we commit to:

• Human Oversight and Transparency: Every piece of AI-generated work is reviewed and validated by a human professional to ensure it is accurate, safe, and contextually appropriate. Content and images generated by AI are clearly labelled. We adhere to principles of transparency, accuracy, and accountability.
• Social Justice: We are conscious of bias in AI tools, and in alignment with culturally appropriate and social justice oriented work, we use AI with caution and human controls from this vantage point.
• Privacy and Security: We view privacy not just as a compliance requirement, but as a fundamental right and a cornerstone of psychological safety. We commit to using AI frameworks that respect data sovereignty, work to prevent data exploitation, and respect boundaries of confidentiality and data security.
• Lived Experience Integration: In our work to redesign mental health and substance use health systems, a key principle is co-design and we are committed to the engagement of individuals with lived and living experience in the development and review of redesigning systems.

Our Current Approach

Currently, AI is used only for internal tasks such as brainstorming, research, and improving our operational efficiency. While we use AI to help optimize internal processes and condense/summarize analytical reports, we do not use AI for direct, autonomous interactions with the people we serve.

As we look to the future, we will continue to monitor emerging legislation and evolving practices, and continue to find a balanced approach that meets the needs for efficiency, while balancing quality, transparency and human-centered systems.

Last Updated: September 2026

This Privacy Statement explains how Stepped Care Solutions (“SCS,” “we” or “us”) collects, uses, discloses and protects personal information. SCS is a not-for-profit organization that works with partners in Canada and internationally to transform mental health and substance use health systems. We provide implementation support, training, strategy development, and change consultation, and corporate wellbeing strategy development.

Accountability for Personal Information

SCS has implemented a privacy program for the protection of personal information that includes policies and procedures to address the following: limiting collection, use and disclosure of personal information to the minimum necessary amount; limiting access to personal information to employees who require access for their role; data breach response and mitigation; data retention and secure destruction of personal information; and a process for responding to privacy-related complaints and inquiries. SCS has appointed a Privacy Officer as the person responsible for oversight of our privacy program. All SCS employees are responsible for compliance with our privacy policies and procedures and are required to protect personal information throughout its lifecycle. Employees undergo privacy training and may be subject to disciplinary action for non-compliance with privacy policies and procedures.

Collection and Use of Personal Information

SCS collects and uses limited amounts of personal information in the delivery of our services. Personal information processed may include an email address, a phone number and limited demographic information.

SCS also collects business contact information about individual representatives and employees of the organizations, communities and institutions we work with and/or have developed a relationship with through events or conferences. This may include name, business email address and phone number, business address, and title. This information is used to communicate with these parties if they have agreed to be contacted, and to deliver training through our online learning management system.

In some circumstances, where permitted or required by law, we may process personal information without knowledge or consent. For example, we may be required to use personal information to protect the security or availability of our services, to protect or enforce our legal rights, or to protect the health and safety of individuals.

Disclosures of Personal Information

We only disclose personal information with your consent or when required or permitted by law, including in the following circumstances:

• in response to court orders or other lawful demands;
• to protect the security or availability of our services; or
• to protect the health or safety of individuals.

In each instance, we share the minimum amount of personal information required.

Analytics, Cookies and Other Technologies

Web log files, analytics tools, cookies, web beacons and similar technologies may be used to remember user preferences and obtain information about how the website is used.

Web Log Files

Log files automatically generated records of all website visits and are used to report website trends and identify and troubleshoot issues. Log files include the following information:

• User’s operating system (example: iOS 12),
• IP address,
• Date and time,
• Length of the website visit,
• Pages and documents accessed, and
• Previously accessed website (for example, the search engine that referred the user to the website).

Analytics Tools

We use Google Analytics to help us measure and understand how our website is used. These tools use cookies and similar technologies to collect certain information, including IP addresses, approximate location (such as city, region and country), device or browser types, traffic sources, and activities on the website, such as click rates and bounce rates. To prevent Google Analytics from collecting information about your site use, click here.

Cookies

Cookies are small text files stored on your device that identify your IP address to our servers each time you visit the website.

You can control stored cookies on your device and turn them off through your web browser. To turn off cookies, follow the instructions found in the “Help,” “Tools,” or “Edit” menus in your browser. Our website depends on the use of certain cookies. If you turn off all cookies, you may be unable to use some website features.

Security

We use reasonable administrative, technical and physical safeguards to protect personal information against theft, loss, unauthorized access, use, modification and disclosure. However, despite our efforts, no safeguards can eliminate all security risks.

Data Retention

We retain personal information for only as long as necessary to fulfil the purposes for which it was collected, and as may be required to comply with applicable law. When personal information is no longer required, we make reasonable efforts to ensure all electronic and hard copies of such information are securely destroyed and irreversibly deleted from our systems in accordance with industry standards. However, if the information has been disclosed to third parties for the purposes described above, they may retain the information according to their own retention policies.

Use of Service Providers and Storage of Personal Information

We use third-party providers of services that handle personal information on our behalf. This includes, for example, our learning management system and customer relationship management system.

The personal information we process may be stored on servers or otherwise transferred outside of Canada, and, as a result, your personal information may be subject to the laws of those jurisdictions and could be accessible without notice to you by the courts, law enforcement and national security authorities of those jurisdictions. Notice to Quebec residents: Your personal information may be transferred outside of Quebec, even if it remains in Canada.

Accessing Your Personal Information

If you would like to request access or make corrections to personal information, please contact the Privacy Office at [email protected].

Changes to this Privacy Statement

We may update this Privacy Statement from time to time. The “Last Updated” date above indicates when it was most recently revised. Where appropriate, we may provide additional notice of material changes.

For Further Information

If you have any complaints or questions about this Privacy Statement or our personal information handling practices, please contact the Privacy Office at [email protected].