At the Clinique Vétérinaire de Hull, we are committed to providing exceptional service to our clients. However, in order to provide this service, we need to collect, use and disclose certain personal information about our clients. Please be assured that the protection of this information is extremely important to us.
While we have always respected the privacy of our clients and taken the necessary measures to protect their personal information, we have strengthened our commitment to do so.
Therefore, we will now inform our clients of why and how we collect, use or disclose their personal information. We will obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Personal information — information about an identifiable individual (name, address, phone number, etc.). Personal information does not include contact information (defined below).
Contact information — information that enables an individual to be contacted at a place of business and includes name, position name or title, business phone number, address, email and fax. Contact information is not covered by this Policy or the legislation.
Privacy Officer — the individual responsible for ensuring that the Clinique Vétérinaire de Hull complies with this Policy and the legislation.
1. Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides their personal information for these purposes, we will clarify the reasons why personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client personal information that is necessary to:
· Verify identity
· Identify client preferences
· Manage client accounts
· Provide veterinary products
· Provide veterinary services
· Send out reminders of services
· Meet our veterinary medical association’s regulatory requirements
· Ensure a high standard of service to our clients
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as mentioned above, we are authorized to do so without consent).
2.2 Consent can be given (orally, in writing, electronically or through an authorized representative) or it can be inferred where the purpose for collecting, using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt out of their personal information being used for mailings and the client does not opt out.
2.4 Subject to certain exceptions (e.g. the personal information is necessary to provide the service or product, or the withdrawal of consent would impede the performance of a legal obligation), clients can withhold or withdraw their consent for the Clinique Vétérinaire de Hull, to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of this personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making an informed decision.
2.5 We may collect, use or disclose personal information without the client’s knowledge or consent in these circumstances:
· When the use of personal information is permitted or required by law
· When the personal information is available from a public source (e.g. a telephone directory)
· When we require legal advice from a lawyer or a regulatory body
· To collect a debt
· To protect ourselves from fraud
3. Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection and for others reasonably related to these purposes such as:
· To conduct client surveys to improve the provision of our services
· To contact our clients about products or services that may benefit their pets
· To contact clients in the event of an emergency regarding their pet
3.2 We will not use or disclose client personal information for any other purposes without their express consent.
3.3 We will not sell client lists or personal information to third parties.
4. Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that they have a reasonable amount of time to request access to it.
4.2 Subject to clause 4.1, we will retain client personal information as long as necessary to fulfill the identified purposes or if required for legal or business purposes.
5. Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients may request corrections to their personal information to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the relevant information and the modifications requested.
5.3 If the personal information is found to be inaccurate or incomplete, we will make the modifications as required and will send the corrected information to any organization to which we disclosed it to the previous year. If the correction has not been made, we will make a note of the client’s correction request in their file.
6. Protection of Personal Information
6.1 We are committed to ensuring the security of client personal information to protect them from unauthorized access, collection, use, disclosure, copying, modification or destruction or any similar risk.
6.2 The following security measures will be taken to ensure that client personal information is well protected:
· Client and patient files are kept in a secure location
· Client electronic records are protected by passwords and firewalls are monitored daily
6.3 We will take appropriate security measures when destroying client personal information such as shredding printed documents and deleting electronic data.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
7. Granting Client Access to their Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions (e.g. solicitor-client privilege or health and safety concerns)
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the relevant information.
7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed, if applicable.
7.4 We will make the requested information available to the client within 30 business days or send a written notice where additional time is required to fulfill the request.
7.5 A nominal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the amount and ask whether we should proceed with the request.
7.6 If a request is refused in whole or in part, we will notify the client in writing and provide the reasons for refusal and the recourse available to them.
8. Questions and Complaints: Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or the Patient Manager is responsible for ensuring that the Clinique Vétérinaire de Hull complies with this Policy and the Personal Information Protection and Electronic Documents Act.
8.2 Clients should direct any complaints, concerns or questions regarding Clinique Vétérinaire de Hull compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the problem, the client may also write to the Information and Privacy Commissioner of Québec.
Contact details for the Privacy Officer or the Patient Manager at the Clinique Vétérinaire de Hull:
546 boulevard Saint-Joseph
Gatineau, Québec J8Y 4A4