Personal Information Protection & Electronic Documents Act

• What is this new legislation?
• What is your privacy policy?

The Personal Information Protection & Electronic Documents Act (PIPEDA) is federal legislation which came into effect on January 1, 2004. It requires all companies to have a policy in place to protect a person's personal information.

Clarkson Village Animal Hospital (CVAH) complies with PIPEDA and is committed to respecting the privacy rights of all individuals, including clients and employees, by ensuring that their personal information is collected, used and disclosed in an appropriate manner.

CVAH is a companion animal veterinary facility. We collect personal information about our clients for purposes of effective communication and providing veterinary medical services. We also collect personal information about our employees for purposes of personnel management and administration.

The principles established in the personal information policy of this veterinary facility conform with the fundamental requirements of PIPEDA. If the province of Ontario enacts privacy legislation in the future this personal information policy may be amended to ensure that it continues to conform with the legislation.

Personal information is information about an identifiable individual. Personal information includes information that relates to personal characteristics (eg. gender, age, home address or phone number etc).

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual providing the personal information or where use or disclosure is required by law.

Personal information shall be collected by fair and lawful means, and will not be collected for unspecified or improper purposes.

Like all veterinarians, we collect, use and disclose personal information in order to serve our clients and patients and to meet regulatory requirements. We collect information about your pet’s history and physical condition in order to:

• Assess your pet's needs;
• Advise you of your options;
• Obtain a baseline of health information so that any changes can be identified; and
• Provide the necessary veterinary care
  

Common purposes for the collection, use or disclosure of personal information include but are not limited to:

• Maintain complete and accurate client files, and to comply with all requirements of the College of Veterinarians of Ontario and the Ontario Veterinarians Act and Regulations;
• Advise clients that their pets are due for scheduled veterinary services;
• Provide goods and services to our clients, communicate effectively with our clients including contacting clients to schedule appointments and follow-up on patient treatment, and billing for goods and services;
• Notifying clients about new services, special events, promotional offers and educational materials;
• Communicate and work with third parties providing veterinary medical or other services to our clients including other veterinary facilities, pet recovery services and insurance companies (upon client’s request);
• Bill for goods and services, process credit card payments and collect unpaid accounts;
• Review client and other files for the purpose of ensuring the quality of our services;
• Comply with lawful requests from governmental agencies such as the Canada Customs and Revenue Agency and the Ontario Human Rights Commission; and
• Maintain complete and accurate personnel files (this includes employees, contract staff, volunteers and students) for necessary work-related communication; and
• Use information collected from our website only for the purpose in which it was given (eg. to respond to an e-mail message). Cookies are only used to navigate our website and are not used for monitoring purposes.
  

This veterinary facility will only collect personal information which is necessary for the purposes which have been identified. We may identify additional purposes and will communicate these purposes if it is practical or appropriate in the circumstances to do so.

CVAH will make an effort to obtain the express consent from an individual in writing through the use of a written document for the collection, use or disclosure of their personal information.

There may however be situations where implied consent is given by an individual. Implied consent shall be such that a reasonable person would conclude that the individual has consented, or would consent, if asked, to the collection, use or disclosure of his or her personal information. There may be situations where consent is given verbally, either in person or over the telephone. Individuals providing personal information to us through a website or email communication will be considered to have consented to the collection, use or disclosure of such information in accordance with this policy.

The consent of an individual, whether express or implied, may be withdrawn at any time and we will explain the ramifications of this decision.

CVAH safeguards and protects personal information under our control by implementing security measures appropriate to the sensitivity of the information. All staff members who come in contact with your personal information are aware of the sensitive nature of the information and are trained in the appropriate uses and protection of your information. We ensure that our employees keep all personal information confidential and comply with established security standards.

• Paper information and electronic hardware is either under supervision or secured in a restricted area.
• Passwords are required for computer access.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• External agencies with access to personal information must enter into privacy agreements with us committing to an appropriate level of security to satisfy our standards.
  

We need to retain personal information to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. We therefore keep our client information for a minimum of 8 years after the last contact date.

Upon the disposal or destruction of personal information, CVAH shall take the necessary precautions to prevent third parties from accessing such information and to maintain the confidentiality of such information. As such, paper files containing personal information are destroyed by shredding, electronic information is deleted, and hardware is physically destroyed.

We will ensure that our clients and employees have the opportunity to review and update their personal information. We reserve the right to confirm your identity and ask for the request in writing.

CVAH will make every reasonable effort to ensure that the personal information collected initially, and on an ongoing basis, will be as accurate, complete and up-to-date as possible for the purposes for which the information will be used.

An individual will be able to address the accuracy and completeness of his or her personal information and have it amended, if inaccurate or incomplete. This applies to factual information and not to any professional opinions. When we agree that an error has been made, we will make the correction and notify anyone with whom we shared this information.

We will maintain a complete record of third parties to whom personal information has been disclosed, and will make such record available.

Questions or concerns regarding this veterinary facility can be directed to the Privacy Officer.

Our Privacy Officer is Dr. Mudrick. He can be reached at:

Clarkson Village Animal Hospital
1659 Lakeshore Road West
Mississauga, ON
L5J 1J4
905-855-2100

If you wish to make a formal complaint about our privacy practices, you may address it in writing. He will acknowledge receipt of the comment, ensure it is investigated and that you are provided with a formal written decision to ensure that all complaints are dealt with in an objective, fair and expeditious manner.

This policy is made under the Personal Information Protection and Electronic Documents Act. For 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 an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

Information & Privacy Commissioner
112 Kent Street
Ottawa, ON
K1A 1H3
1-800-282-1376
www.privcom.gc.ca

Dated this first day of April, 2004.