ALGONQUIN VETERINARY PROFESSIONAL CORPORATION,
operating as Algonquin Animal Hospital and Bracebridge
Animal Hospital
PERSONAL INFORMATION POLICY
INTRODUCTION
The Personal Information Protection and Electronic Documents Act ("PIPEDA")
is federal legislation which came into effect on January 1, 2001. Algonquin
Veterinary Professional Corporation 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.
Algonquin Veterinary Professional Corporation collects personal information
about its clients for purposes of effectively communicating with, and providing
veterinary medical services to, its clients. This veterinary facility also
collects personal information about its employees for purposes of personnel
management and administration.
The principals established in the personal information policy of Algonquin
Veterinary Professional Corporation conform with the fundamental requirements
with PIPEDA. This personal information policy may be amended if the province of
Ontario enacts privacy legislation in the future, to ensure that this policy
conforms with such legislation.
POLICIES
1. Accountability
Algonquin Veterinary Professional Corporation is responsible for all personal
information under its control. An owner of Algonquin Veterinary Professional
Corporation will designate an individual who will be accountable for compliance
with the personal information policy and procedures. The individual will be
known as the "Privacy Officer". Dr. Jason McLeod has been appointed as Policy
Officer.
Algonquin Veterinary Professional Corporation is committed to protecting
personal information, and accordingly will include an appropriate level of
protection in any dealings with third parties who receive personal information
from Algonquin Veterinary Professional Corporation.
Algonquin Veterinary Professional Corporation will ensure that its clients,
employees and other interested individuals have the opportunity to review and
update their personal information on file with Algonquin Veterinary Professional
Corporation. All such persons will be advised that questions and concerns can be
directed to the Privacy Officer.
2. Identifying the Purposes for Collection of Personal Information
Algonquin Veterinary Professional Corporation will identify the purposes for
which it collects, uses or discloses personal information. The primary purposes
for such collection, use or disclosure of personal information will relate to
the delivery of quality veterinary medical services to our clients.
Common purposes for the collection, use or disclosure of personal information
include:
to maintain complete and accurate client files, and to comply with all
requirements of the College of Veterinarians of Ontario and the Veterinarians
Act and regulations thereto;
to provide goods and services to our clients, to communicate effectively with
our
clients, and to communicate and work with third parties providing veterinary
medical or other services to our clients (including insurance companies which
pay for all or part of the cost of such services);
to bill for goods and services and to collect unpaid accounts;
to permit a potential buyer of Algonquin Veterinary Professional Corporation
to carry out due diligence to confirm factual and other information about our
business;
to comply with lawful requests from governmental agencies such as local
public health officials, Canada Customs and Revenue Agency and the Ontario Human
Rights Commission; and
to maintain complete and accurate personnel files.
Algonquin Veterinary Professional Corporation may identify additional
purposes that arise for the collection, use of disclosure of personal
information. Algonquin Veterinary Professional Corporation will communicate such
additional purposes to its clients and interested individuals, if it is
practical or appropriate in the circumstances to do so.
3. Consent
Algonquin Veterinary Professional Corporation will obtain the consent from
individuals for the collection, use or disclosure of their personal information.
Algonquin Veterinary Professional Corporation will make every effort to obtain
the express consent from an individual in writing through the use of a retainer
or engagement agreement or other written document. There may be situations where
implied consent is given by an individual. Implied consent will not be in
writing, but the circumstances relating to the provision of 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.
4. Limitations on the Collection of Personal Information
Algonquin Veterinary Professional Corporation will only collect personal
information which is necessary for the purposes which have been identified.
Personal information shall be collected by fair and lawful means, and will not
be collected for unspecified or improper purposes.
5. Limitation 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 personal
information or except where use or disclosure is required by law. Algonquin
Veterinary Professional Corporation will establish appropriate criteria for the
retention of personal information.
6. Accuracy
Algonquin Veterinary Professional Corporation 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. Algonquin Veterinary Professional Corporation will on an ongoing
basis make every effort to ensure the accuracy and completeness of personal
information under its control.
7. Safeguards
Algonquin Veterinary Professional Corporation shall safeguard and protect
personal information under its control by implementing security measures
appropriate to the sensitivity of the information.
Algonquin Veterinary Professional Corporation shall ensure that its employees
keep all personal information confidential and comply with the security
standards established by Algonquin Veterinary Professional Corporation.
Algonquin Veterinary Professional Corporation shall require third parties to
whom personal information is disclosed to commit to an appropriate level of
security (which may include execution of a confidentiality covenant) in
protection of such information to satisfy the standards established by Algonquin
Veterinary Professional Corporation.
On the disposal or destruction of personal information, Algonquin Veterinary
Professional Corporation shall take the necessary precautions to prevent third
parties from accessing such information and to maintain the confidentiality of
such information.
8. Transparency
Algonquin Veterinary Professional Corporation will make available to any
interested individual specific information about Algonquin Veterinary
Professional Corporation's policies and procedures relating to personal
information which is under the control of Algonquin Veterinary Professional
Corporation. Algonquin Veterinary Professional Corporation will facilitate
access to its personal information policies and procedures, and will make
available information concerning the identity of its Privacy Officer, and the
means by which a person can communicate with the Privacy Officer. Algonquin
Veterinary Professional Corporation will also ensure that individuals are aware
of the means of gaining access to their personal information.
9. Individual Access to Personal Information
An individual providing personal information to Algonquin Veterinary
Professional Corporation will be informed about the existence of this personal
information policy, and the use and disclosure of his or her personal
information, and will be given access to and the right to ensure the accuracy
and completeness of such information. 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.
Algonquin Veterinary Professional Corporation will respond promptly to any
request by an individual for access to his or her personal information.
Algonquin Veterinary Professional Corporation will maintain a complete record
of third parties to whom personal information has been disclosed, and will make
such record available to an individual whose personal information has been so
disclosed.
10. Questions and Concerns Regarding Compliance with this Policy
An individual providing personal information to Algonquin Veterinary
Professional Corporation may address any question, concern or complaint
regarding Algonquin Veterinary Professional Corporation's compliance with this
personal information policy to the Privacy Officer.
Algonquin Veterinary Professional Corporation will establish a procedure for
processing any complaint about the personal information policy to ensure that
all complaints are dealt with in an objective, fair and expeditious manner.
Dated the 1st day of June , 2005.
