Data processing schedules

Last updated: October 3, 2026 (revision 2)

Section 14 of the terms of use is KeepCount Inc.'s data processing addendum with each organization that uses KeepCount: who decides and who processes, use only on the organization's instructions, confidentiality, service providers and notice of changes, where records are kept, safeguards, breach notice within 72 hours, help with requests, demands from authorities, return and deletion, and inspection. These four schedules form part of it.

Schedule 1. Service providers

KeepCount uses these providers, each bound by written data processing terms that protect the information. The list here and in the privacy notice is always current.

• Notice of changes. Before adding or replacing a provider that would handle an organization's records, we email its administrators at least 30 days ahead. An organization that objects on reasonable privacy grounds may end its plan before the change, and we refund fees paid for the time after that date (terms, 14.4).
• Outside Canada. The records are stored in Canada. Email, card payments, the support mailbox, website delivery and video playback are handled by the providers above, some outside Canada, where the laws of that country apply and its courts and authorities may be able to reach the information.
• Email. No email KeepCount sends names a child or carries a child's health information. Reminders and the weekly summary name staff, providers and what is due. An organization that wants email kept to account messages can pause the reminders and send the weekly summary to nobody in Settings.

Schedule 2. Safeguards

• Everything travels encrypted (TLS) and is encrypted at rest. Children's names, pick-up notes and incident narratives are also encrypted inside the database with a key the application holds.
• Each organization's records are separated in the database itself, on every table. A test that tries every table from a second organization and from each role runs on every change to the code.
• Passwords of at least twelve characters, checked against lists of leaked passwords; a second sign-in step that organizations can require of their administrators, and that KeepCount support always uses; accounts locked for a time after repeated failed sign-ins.
• KeepCount support opens an organization's records only through a support session, for eight hours at a time, recorded in the organization's own activity log. Everyone who works on KeepCount is bound to confidentiality.
• Viewing, printing, exporting or downloading a person's record is written to the organization's activity log.
• Uploaded files are private and opened through links that expire after ten minutes.
• The database is in the Canada (Central) region and is backed up daily; server functions run in the Canadian region.
• Records the regulation requires cannot be deleted before their retention date, and are deleted automatically, with their files, on the date the organization chooses after it.
• A written record of every breach of security safeguards is kept for at least 24 months.

KeepCount may change these safeguards but will not make them materially weaker (terms, 14.6). Once a year, on request, we answer a reasonable written security and privacy questionnaire.

Schedule 3. Public bodies

This schedule applies when the organization is an institution under the Municipal Freedom of Information and Protection of Privacy Act or the Freedom of Information and Protection of Privacy Act (for example, a child care centre operated by a municipality). Where it differs from the rest of section 14, it prevails.

• 3.1 Control. The records in the organization's account are in its custody or under its control for the purposes of the Act. KeepCount holds them as the institution's service provider and claims no right to them.
• 3.2 Use and disclosure. KeepCount collects, uses and discloses the records only to provide KeepCount to the institution, on its instructions, or as Canadian law requires.
• 3.3 Requests under the Act. If KeepCount receives a request for access to or correction of the records, it sends it to the institution within two business days and does not answer it itself. When the institution asks for records to answer a request, KeepCount helps it produce them within ten business days, or sooner where the institution's deadline requires.
• 3.4 Demands from outside Canada. If a court or authority outside Canada demands the records, KeepCount tells the institution at once, unless the law forbids it, and discloses nothing unless a Canadian court requires it.
• 3.5 Breaches. KeepCount tells the institution within 72 hours after it confirms a breach involving the records, and helps it notify the people affected and the Information and Privacy Commissioner of Ontario as the Act and the Commissioner's guidance call for.
• 3.6 Retention. KeepCount keeps the records for at least three years (O. Reg. 137/15 s. 82(1); for a child, three years after the child leaves, s. 72(5)). Where the institution's records retention by-law requires a longer period, it tells us in writing and we set the account's retention period to match, or it exports the records first.
• 3.7 Return and deletion. At the end of the agreement the institution exports the records, and they are deleted on the date it chooses under section 13 of the terms; we confirm the deletion in writing on request.
• 3.8 Disclosure of these terms. KeepCount accepts that the institution may disclose these terms under the Act. Security details we give in confidence (for example, in a questionnaire) are marked as such.
• 3.9 A signed copy. On request, KeepCount signs these schedules as a separate agreement with the institution.

Schedule 4. A notice for families, staff and volunteers

The organization tells the people its records are about that a service provider keeps them (terms, 7(a)). It can adapt this text for its parent handbook, enrolment forms and staff orientation. Remove the parts it does not use, and fill in the brackets.

Copy the notice

Contact

Huphy S. Ghayur, Privacy Officer, KeepCount Inc., 51 Village Centre Place, Mississauga, Ontario L4Z 1V9, [email protected] (put "privacy" in the subject).