Privacy of personal information is an important principle to Belle Rive Pet Hospital Ltd. We are committed to collecting, using and disclosing person 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 person 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 (i.e.: gender, age, income, home address or phone number, ethnic background, family status), their health (i.e.: religion, politics, opinions expressed by and individual, an opinion or evaluation of an individual), and their animal’s health. Personal information is to be contrasted with business information (i.e.: an individual’s business address and telephone number), which is not protected by privacy legislation.
Who We Are:
Our organization, Belle Rive Pet Hospital, includes Veterinarians, Animal Health Technologists, Veterinary Assistants and Receptionists. 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, accountants, temporary workers to cover holidays, credit card companies, Alberta Veterinary Medical Association auditors, cleaners and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible.
We Collect Personal information: Primary Purposes
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 the animal’s history, physical condition and function in order to help us assess what their needs are, to advise clients of their options and then to provide the veterinary care they chose. A second primary purpose might 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 (i.e.: a family member passing a message on from our client and we have no reason to believe that the message is not genuine).
We Collect Personal Information: Related and Secondary Purposes
Like most organization, we also collect, use and disclose information for purposed 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 service that was performed has a proper outcome, is still appropriate for the current situation and to consider modification or replacement where necessary.
□ To advise clients and others of special events or opportunities (i.e.: 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 our staff. In addition, external consultants (i.e.: auditors, layers, practice consultants, accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our Clinic, including reviewing Client files and interviewing our staff.
□ Veterinarians are regulated by the Alberta Veterinary Medical Association (AVMA) who may inspect our records and interview our staff as part of their regulatory activities in the public interest. In addition, as professional, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes regulators have their own strict privacy obligations. Sometimes their reports include personal information about our clients, or other individuals, to support the concern (i.e.: improper services). Also, like all organizations, various government agencies (i.e.: 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 part of their mandates. In these circumstances, we may consult with professional (i.e.: lawyers, accountants) who will investigate the matter and report back to us.
□ The cost of some good/services provided by Belle Rive Pet Hospital to clients may be paid for by third parties (Insurance Companies). These third-party payers often have our 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 of five years after the last contact to enable us to respond to those questions and provide these services (our regulatory body – the AVMA also requires us to retain our client records).
□ If Belle Rive Pet Hospital Ltd or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’s record 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 organization’s business or its assets would be provide 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 (i.e.: by declining to receive notice of special events or opportunities). We do not, however, have much choice about some of these related or secondary purposes (i.e.: external regulation required by the AVMA).
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 in a 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.
□ 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.
□ 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 the AVMA. 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 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. Alternatively, we may send some or all of the client file to our client.
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 do not understand (i.e.: short forms, technical language, etc.). We will need to confirm you identity, if we do not know you, before providing you with access. We reserve the right to charge a nominal fee for such requests.
Contact us if you have any questions.
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.
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 our 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 of Alberta can be reached at:
Information and Privacy Commissioner of Alberta
410, 9925 109 Street
Phone: (780) 422-6860
Fax: (780) 422-5682