WINGROVE VETERINARY SERVICES PRIVACY POLICY
Privacy of personal information is an important principle to
Wingrove Veterinary Services. 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 relates
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 or evaluation of an
individual). 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, Wingrove Veterinary Services, includes
at the time of writing four veterinarians and thirteen 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.
WE COLLECT PERSONAL INFORMATION: PRIMARY
PURPOSES
About clients
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. For example, 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 base line 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
clients 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 on a
message from our client and we have no reason to believe that the
message is not genuine).
About members of the general public
For members of the general public, our primary purposes for
collecting personal information are to provide notice of special
events ( e.g., a seminar or conference) or to make them aware of
veterinary services in general or our clinic in particular. For
example, while we try to use work contact information where
possible, we might collect home addresses, fax numbers and email
addresses. We try to obtain consent before using any such personal
information, but where this is not, for any reason, possible, we
will upon request immediately remove any personal information from
our distribution list.
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 (e.g., to respond to your email
message, to register for a course, to subscribe to our newsletter).
Cookies are only used to help you navigate our website and are not
used to monitor you.
About contract staff, volunteers, students
For people who are contracted to do work for us (e.g. temporary
workers).our primary purpose for collecting personal information is
to ensure we can contact them in the future (e.g., for new
assignments) and for necessary work related communication (e.g.,
sending out paycheques, year end tax receipts). Examples of the
type of information we collect for those purposes include home
addresses and telephone numbers. It is rare for us to collect
such information without prior consent, but it might happen in the
case of a health emergency or to investigate a possible breach of
law (e.g., if a theft were to occur in the clinic). If contract
staff, volunteers or a student wish a letter of reference or an
evaluation, we will collect information about their work related
performance and provide a report as authorized by them.
WE COLLECT PERSONAL INFORMATION: Related and Secondary
Purposes
Like most organizations, we also collect use and
disclose information for purposes related to or secondary to our
primary purposes. The most common examples of our related and
secondary purposes are as follows:
❏ To invoice clients for goods or services that were not
paid for at the time, to process credit card payments
or to collect unpaid accounts.
❏ To advise clients that their animals are due for
scheduled veterinary services and to ensure a services 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 or
opportunities (e.g., a seminar, development of a new service,
arrival of a new product) that we have available.
❏ Our clinic reviews client and other files for the
purpose of ensuring the quality of our services, including
assessing the performance of staff. In addition, external
consultants (e.g., auditors, lawyers, practice consultants,
accreditation programs) on our behalf do audits and continuing
quality improvement reviews of our clinic, including client files
and interviewing our staff.
❏ 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. 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
Commisioner, 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 Wingrove
Veterinary Services to clients may be paid for by third parties
(Insurance companies). 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 or 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 our previous
records are helpful. We retain our client information for a minimum
f seven years after the last contact to enable us to respond to
those questions and provide these services ( our regulatory college
also requires us to retain our client records).
❏ If Wingrove Veterinary Services 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 due diligence may involve some review of our accounting and
service files. 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 organizations 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.
You can choose not to be part of some of these related or
secondary purposes (e.g., by declining to receive notice of special
events or opportunities, by paying for your services in advance).
We do not, however, have much choice about some of these related or
secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal
information. For that reason, we have taken the following
steps:
❏ Paper information is either under supervision or
secured in a locked or restricted area.
❏ Electronic hardware is either under supervision or
secured in a locked or restricted area at all times. In addition,
passwords are used on computers. All of our cell phones are
digital, which signals are more difficult to intercept.
❏ Paper information is transmitted through sealed,
addressed envelopes or boxes by reputable companies.
❏ Electronic information is transmitted either through
a direct line or is anonymized or encrypted.
❏ 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 consultants and agencies with access to
personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
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. However, we do not want to keep personal
information too long in order to protect your privacy.
We keep our client files for about seven 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 not be contacting you again. However, if you
ask, we will remove such contact information right away. We keep
any personal information relating to our general correspondence
(i.e., with people who are not clients ) newsletters, seminars and
marketing activities for about six months after the newsletter
ceases publication or a seminar or marketing activity is over.
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 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 may 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 as 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 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 you on the point and we
will forward that statement to anyone else who received the earlier
information.
DO YOU HAVE A QUESTION?
Our Information Officer, Jenifer Casarin, can be reached at:
R.R.#1, Guelph ON N1H 6H7
(510) 856-9541
She will attempt to answer 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 like 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 St.,
Guelph, ON
N1L 1G6
www.cvo.org
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.
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, ON K1A 1H3
Phone (613) 995-8210 / Toll Free 1-800-282-1376 / Fax (613)
947-6850
www.privcom.gc.ca
