The Personal Information Protection and Electronic Documents Act (PIPEDA) is federal legislation. This veterinary facility complies with PIPEDA and is committed to respecting privacy rights of all individuals, including clients and employees. Privacy of personal information is an important principle to the Doncaster Animal Clinic, Steeles Veterinary Service and Landmark Pet Incorporated (referred to in this document as this veterinary facility). 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. POLICIES
1. Accountability This veterinary facility is responsible for all personal information under its control. We have designated an individual to act as our “Privacy Officer” to monitor and ensure proper compliance with the personal information policy and procedures. Any questions or concerns regarding our privacy practice should be directed to our Privacy Officer. Our Privacy Officer is Laura Sutton, RVT. This veterinary facility will ensure an appropriate level of protection in any dealings with third parties that receive personal information from this veterinary facility. This veterinary facility will ensure that our clients, employees and other interested individuals have the opportunity to review and update their personal information on file with us. All such persons will be advised that questions and concerns can be directed to the Privacy Officer.
2. Personal Information Personal information is information about an identifiable individual. Types of personal information collected by this veterinary facility include names, home addresses and phone numbers, email addresses, as well as security camera images. 3. Limitations of the Collection of Personal Information This veterinary facility will only collect personal information that is necessary for the purposes identified in this document. Personal information will not be collected for unspecified or improper purposes. 4. Limitations on the Use, Disclosure and Retention of Personal Information 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 information or where use or disclosure is required by law. Personal information in client file will be retained for a minimum of five years after last contact.
5. Primary Purposes for Collection of Personal Information. Like all veterinarians, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide veterinary services. We collect information in order to communicate effectively with our clients regarding care of their pets, and to communicate and work with third parties providing services for these clients. In referral cases, a client’s personal information will be included in the medical records sent to the referring veterinarian. We are required to maintain complete and accurate client files, in order to comply with all requirements of the College of Veterinarians of Ontario and the Veterinarians Act. On our website we collect, with the exception of cookies, only the personal information provided and we will only use that information for the purpose given to us (e.g., to respond to an email message). Cookies are only used to help one navigate our website and are not used to monitor. Personal information will be collected from employees, contract staff, volunteers and students in order to maintain complete and accurate personnel files. 6. Related and Secondary Purposes for Collection of Personal Information This veterinary facility will also collect, use and disclose information for purposes related to our primary purpose. Personal information is used to invoice clients and to collect unpaid accounts; to advise clients their pets are due for veterinary services, or that a performed service has a proper outcome. Veterinarians are regulated by the College of Veterinarians of Ontario who may inspect our records and interview our staff as part of their regulatory activities in the public interest. We are also obligated to report serious misconduct or incompetence of other practitioners, as well as serious illegal behaviour to the authorities. These reports may include personal information about our clients or other individuals to support the concern. External regulators have their own strict privacy obligations. Various government agencies have the authority to review our files and interview our staff as a part of their mandates. If this veterinary facility or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This may involve some review of our accounting and service files. 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 stated. 7. Consent This veterinary facility will obtain the consent from individuals for the collection, use or disclosure of their personal information. We will make every effort to obtain the express consent form an individual through the use of a written document through which such personal information is obtained. An individual may also give implied consent. Circumstances of implied consent shall be such that a reasonable person would conclude that the individual has consented 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. The consent of an individual may be withdrawn at any time. 8. Accuracy This veterinary facility will make every reasonable effort to ensure that personal information collected by it will be as accurate, complete and up-to-date as possible for the purposes for which the information is to be used. 9. Safeguards This veterinary facility shall safeguard and protect personal information under its control by implementing security measures appropriate to the sensitivity of the information. We shall ensure that our employees keep all personal information confidential and comply with the security standards established. Disposal or destruction or personal information will be done taking necessary precaution to prevent others from accessing the information. Third parties to whom personal information is disclosed to will be required to commit to an appropriate level of security to protect the information. 10. Transparency This veterinary facility will make information about our Privacy Policy available to any interested individual, through our Privacy Officer. 11. Individual Access to Personal Information Individuals who have provided personal information to this veterinary facility have the right to ensure the accuracy and completeness of their information, and have it amended, in inaccurate or incomplete. Any request by an individual for access to his or her information will be responded to promptly. This veterinary facility will maintain a complete record of third parties to whom personal information has been disclosed. 12. Question and Concerns Regarding Compliance with this Policy Our Privacy Officer, Laura Sutton, can be reached at: 99 Henderson Avenue, Thornhill, ON, L3T 2K9 905-881-2922. She will attempt to answer any question or concerns. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy Officer. This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. |