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Privacy Policy
Privacy of personal information is an important principle to the Brantford Veterinary Clinic. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies. What is Personal Information?Personal information is information about an identifiable individual. Personal information includes information that is related to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g. health history, health conditions, health services received by them) or their activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual), and their animals health. Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation. Who we are.Our organization, The Brantford Veterinary clinic includes at the time of writing 1 full time veterinarian and 6 support staff as well as part time students. We use a number of locums, consultants and agencies that may in the course of their duties, have access to personal information we hold. These include computer consultants, maintenance, accountants, temporary workers to cover holidays, credit card companies, 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. We collect personal information:Primary purposes:Like all veterinary hospitals, we collect, use and disclose personal information in order to serve our clients. Brantford Veterinary clinic collects personal information about its clients for purposes of effectively communicating with, and providing veterinary medical services to its clients. Examples of the type of personal information we collect for those purposes include the name, address, telephone number and email address of clients as well as alternate phone numbers and emergency contact information. We collect information about your animal’s history, physical condition and function in order to help us assess what their needs are, to advise you of your options and then to provide the veterinary care you choose. A second primary purpose might be to obtain a baseline of health information so that in providing ongoing veterinary services you can identify changes that are occurring and a third primary purpose is to meet regulatory requirements. It would be rare for us to collect such information without the client’s express consent, but this might occur in an emergency or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our client and we have no reason to believe that the message is not genuine). Secondary purposes:To invoice clients for goods/services that are not paid for at the time, to process credit card payments and to collect unpaid accounts. To advise clients that their animals are due for scheduled veterinary services and to ensure that a service that was performed has a proper outcome, is still appropriate for the current situation and to consider modifications or replacement where necessary. To advise clients and others of special events and opportunities (e.g. Open House, new programs or special services available). Our organization, or its professional staff, is regulated by the College of Veterinarians of Ontario who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us. The cost of some goods/services provided by the Brantford Veterinary Clinic to clients may be paid for by third parties (e.g., private insurance, government funding). These third party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding. Clients or other individuals we deal with may have questions about our goods/services after they have been received. We also provide ongoing services for many of our clients over a period of months or years for which previous records are helpful. We retain our client information for a minimum of 5 years after the last contact to enable us to respond to those questions and provide these services. We destroy our information 5 years after the last entry. If the organization or its assets were to be sold, the purchaser would want to contact a “due diligence” review of the organization’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase. Protecting personal informationWe understand the importance of protecting personal information. For that reason, we have taken the following steps:v Paper information is under supervision in a restricted areav Electronic hardware is in a restricted area. In addition, passwords are used on computers.v Paper information is transmitted through sealed, addressed envelopes by reputable companies.v Electronic information is transmitted through a direct line.v Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy. Retention and destruction of personal informationWe 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 the College of Veterinarians of Ontario. However, we do not want to keep personal information too long in order to protect your privacy. We keep our client files for about 5 years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and when the hardware is discarded, we ensure that the hard drive is physically destroyed. You can look at your informationWith 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 (e.g. short forms, technical language etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests. If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access. If you believe there is a mistake in the information, you have 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 you to provide documentation that our files are wrong. Where we agree that we made an error, 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 you on the point and we will forward that statement to anyone else who received the earlier information. Do you have a concern?Our Information Officer, Kathy Holden can be reached at: 277 King George Rd., Brantford ON N3R 5L1 (519) 756-2390to address any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information 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. If you have a concern about the professionalism or competence of our services, or the mental or physical capacity of any of our professional staff, we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body: College of Veterinarians of Ontario 2106 Gordon Street Guelph ON N1L 1G6 www.cvo.org 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 Street, Ottawa, ON K1A 1H3 Phone: (613) 995-8210 Toll-Free 1 (800) 282-1376 Fax: (613) 947-6850 TTY: (613) 992-9190 www.privcom.gc.ca
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