WHITBY VISION CARE
PERSONAL INFORMATION PROTECTION POLICY
At Whitby Vision Care, we are committed to providing our users with exceptional service. Privacy of personal information is an important principle to Whitby Vision Care. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide.
We will inform users of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a matter that a reasonable person would consider appropriate in the circumstances. The document below describes our privacy policies.
What is Personal Information: Personal information is information about an identifiable individual. Personal information does not include contact information. It relates to their personal characteristics (i.e age, gender, health history, home address or phone number). Personal information is to be contrasted with business information ( i.e: an individuals business address and telephone number, which is not protected by privacy legislation)
Contact Information: Contact information means information that would enable an individual to be contacted at a place of business, and includes name, position name or title, business telephone number, business address, business email. Contact information is not covered by this policy or PIPEDA & PHIPA.
Privacy Officer: Privacy officer refers to the individual designated responsibility for ensuring that Whitby Vision Care complies with this policy and PIPEDA & PHIPA. The privacy officer is Maureen McConkey, and can be reached at (905) 666-4848, extension 114, to address any questions or concerns.
WHO WE ARE
Whitby Vision Care is an organization that consists of four partners (Dr Pamela Schmitz, Dr Linda Sujo, Dr Pamela Andrews, and Dr Sivasegaran), five associate optometrists and 15 support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, cleaners and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
POLICY 1 – COLLECTING PERSONAL INFORMATION
1.1Unless the purposes for collecting personal information are obvious and the user voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect user information that is necessary to fulfill the following purposes:
- to verify identity
- to identify user preferences
- to deliver requested products and services
- to enrol a client in a program
- to send out association membership information
- to ensure a high standard of service to our users
- to meet regulatory requirements
- to contact the user (if requested) via the information provided
For our patients, the primary purpose for collecting personal information is to provide optometric treatment. We collect information about a patients health history, including their family history, to help us assess what their health needs are, to advise them of their options and then to provide the health care they choose to have. A secondary primary purpose is to obtain a baseline of ocular health so that in providing ongoing services, we can identify changes that are occurring over time. It would be rare for us to collect such information without the patients express consent, but this might occur in an emergency ( the client is unconscious) or where we believe the patient would consent if asked and it is impractical to obtain consent.
POLICY 2 – CONSENT
2.1 We will obtain user consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided directly or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious, and the user voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a user is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the user does not opt-out.
2.4 Subject to certain exceptions (i.e the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), users can withhold or withdraw their consent for Whitby Vision Care to use their personal information in certain ways. A users decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the user in making the decision.
POLICY 3 – USING AND DISCLOSING PERSONAL INFORMATION
3.1 We will only use or disclose user personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- to contact our users directly about products and services that may be of interest
3.2 We will not use or disclose user personal information for any additional purpose unless we obtain consent to do so.
POLICY 4 – RETAINING PERSONAL INFORMAITON
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies.
4.1 Patient files are kept for 10 years from their last examination date, and ten years once they turn 18 years of age.
4.2 Subject to policy 4.1, we will retain user personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
POLICY 5 – ENSURING ACCURACY OF PERSONAL INFORMATION
5.1 We will make reasonable efforts to ensure that user personal information is accurate and complete where it may be used to make a decision about the user or disclosed to another organization.
5.2 Users may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify their personal information and the correction being sought.
POLICY 6 – SECURING PERSONAL INFORMATION
6.1 We are committed to ensuring the security of user personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that user personal information is appropriately protected:
- secure transmission of data
- appropriate encryption of stored data
- paper information is either under supervision or secured in a restricted area
- electronic hardware is either under supervision, or secured in a restricted area
- all computers have passwords
6.3 We will use appropriate security measures when destroying users personal information, such as shredding printed documents and securely erasing digital information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
6.6 On our website, we only collect (with the exception of cookies), the personal information you provide and only use that information for the purpose you gave it to us (i.e to respond to your email message). Cookies are only used to help you navigate our website and are not used to monitor.
POLICY 7- PROVIDING USERS ACCESS TO PERSONAL INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (i.e short forms, medical language). We will need to confirm your identify before providing you with this access.
7.1 Users have a right to access their personal information, subject to limited exceptions. Requests must be made in writing and directed to the privacy officer.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell users have we use their personal information, and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension, where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the user of the cost and request further direction from the user on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the user in writing, providing the reasons for refusal and the recourse available to the user.
7.7 If the user believes there is a mistake in the information, the user has the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask the user to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from the user on the point and we will forward that statement to anyone else wo received the earlier information.
POLICY 8 – REPORTING OF BREACHES OF SECURITY AND SAFEGUARDS
8.1 A breach of security safeguards is defined in PIPEDA as: the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of our security safeguards.
8.2 Any breach of security safeguards involving personal information under our control, if it is reasonable in the circumstances to believe that the breach of security safeguards creates a real risk of significant harm to an individual, will be reported to the affected individuals as soon as feasible.
DO YOU HAVE A QUESTION?
Our information officer is Maureen McConkey. She can be reached at (905) 666-4848 extension 114. If you wish to make a formal complaint about our privacy policies, you may make it in writing to our information privacy officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at 112 Kent St, Ottawa, Ontario. Phone (613) 995-8210/Toll Free 1(800) 282-1376 and Fax (613) 947-6850.