Publication/Effective Date: May 30, 2011
Previous Publication Dates: NEW Policy
- Accountability: organizations are accountable for the personal information they collect, use, retain and disclose in the course of their commercial activities, including, but not limited to, the appointment of a Chief Privacy Officer (in this instance, the owner of VETS)
- Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection and can only be used for thosepurposes;
- Consent: organizations must obtain an Individual’s express or implied consent when they collect, use, or disclose the individual’s personal information;
- Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
- Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes, and must not be disclosed to third parties unless the Individual consents to the alternative use or disclosure;
- Accuracy: organizations are required to keep personal information in active files accurate and up-to-date;
- Safeguards: organizations are to use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure.
- Openness: organizations must inform their clients and train their employees about their privacy policies and procedures;
- Individual Access: an individual has a right to access personal information held by an organization and to challenge its accuracy if need be; and
- Provide Recourse: organizations are to inform clients and employees of how to bring a request for access, or complaint, to the Chief Privacy Officer, and respond promptly to a request or complaint by the individual.
“Personal information” means any information about an identifiable individual. It includes, without limitation; information relating to identity, nationality, age, gender, address, telephone number, e-mail address, Social Insurance Number, date of birth, marital status, education, employment health history, assets, liabilities, payment records, credit records, loan records, income and information relating to financial transactions as well as certain personal opinions or views of an Individual.
“Business information” means business name, business address, business telephone number, name(s) of owner(s), officer(s) and director(s), job titles, business registration numbers (GST, RST, source deductions), financial status. Although business information is not subject to PIPEDA, confidentiality of business information will be treated with the same security measures by VETS staff, as is required for individual personal information under PIPEDA.
“Individual” means the client owner(s) or shareholders, co-signers, and/or any guarantor associated with a client.
“File” means the information collected in the course of processing an application, as well as information collected/updated to maintain /service the account.
“Express consent” means the individual signs the application, or other forms containing personal information, authorizing VETS to collect, use, and disclose the individual’s personal information for the purposes set out in the application and/or forms.
“Implied Consent” means the organization may assume that the individual consents to the information being used, retained and disclosed for the original purposes, unless notified by the individual.
“Third Party” means a person or company that provides services to VETS in support of the programs, benefits, and other services offered by VETS, such as other lenders, credit bureaus, persons with whom the individual or VETS does business, but does not include any Government office or department to whom VETS reports in the delivery of such programs, benefits or services.
1.16.3 What Personal Information does VETS collect?
1.16.4 Why does VETS collect your Personal Information?
VETS collects your Personal Information for the purposes listed below:
- to disclose to third parties – such as labs, animal control and the police; and
- to request your feedback and/or suggestions for VETS via occasional questionnaires and polls.
In addition, from time to time, VETS may use your Personal Information for the following purposes:
- To understand your needs and preferences, including to contact and communicate with you and to conduct
surveys, research and evaluations;
- To engage in business transactions, including the purchase and/or sale of merchandise involving VETS;
- And for any other purpose that VETS may indicate to you from time to time.
1.16.5 How does VETS collect your Personal Information?
Electronically through our website, or in person at the hospital.
1.16.6 Information Sharing and Disclosure
VETS may disclose your Personal Information to third parties for the reasons set forth below.
- Disclosure to Third Parties:
In some situations, VETS may also disclose Personal Information of Users to third parties – such as labs, animal control, and the police. In such instances, this will only be done if the third parties agree to use such information solely for specific, proposed activities and in accordance with this Policy. Information provided by a third party to VETS will be treated in accordance with this Policy. However, VETS bears no responsibility for any other use of such Personal Information by that third party.
Please note that there are circumstances where the use or disclosure of Personal Information may be justified or permitted or where VETS is obliged to disclose information without consent. Such circumstances may include:
- Where VETS believes in good faith that the law requires it;
- Where VETS believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to protect the rights or property of VETS and collect any money owing; or
- Where the information is public.
Where obliged or permitted to disclose information without consent, VETS will not disclose more information than is required. VETS does not sell or otherwise disclose to third parties any Personal Information that it has obtained.
1.16.7 Maintenance and Security of Personal Information
VETS retains Personal Information about users as long as VETS believes it is necessary to fulfill the purpose for which it was collected. Currently, VETS holds the Personal Information in the City of Toronto. Personal Information about users that is maintained on our systems is protected using industry standard security measures. However, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure and transmission of information over the Internet is susceptible to possible loss, misrouting, interception and misuse.
1.16.8 Control of your Personal Information
At VETS, we want you to be able to maintain control over how your Personal Information is used. In particular:
You can “opt in” to some or all of the identified purposes, uses and disclosures listed above. If, at a later date, you wish to “opt-out”, please contact us directly.
You always have the option to instruct us not to use your name, address, e-mail address, etc. beyond providing you with the service or information you requested.
All E-mail communications sent by VETS will include the identification of the sender and information on how to “Unsubscribe” from future emails by calling the hospital. If VETS determines not to provide you access to your Personal Information, we will provide an explanation.
Individuals may request the correction of their Personal Information, and VETS will make the necessary correction(s) and will contact all third parties with whom a customer’s Personal Information has been disclosed to request that they make those corrections requested.
1.16.9 How do we protect your Personal Information?
We make every reasonable effort to protect against the loss, misuse, and alteration of Personal Information under our control.
Only authorized employees and suppliers have access to your Personal Information.
VETS retains your Personal Information for as long as it is necessary to fulfill the identified purpose or as otherwise required or allowed by law. When that need has ended, your Personal Information will be removed from our system and destroyed in a manner that ensures your security.
If an individual believes that their Personal Information of file is not correct, they may request an update of that information by sending a request to the person indicated below. VETS reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. An individual may also request that VETS delete an individual’s Personal Information from VETS’s system and records. However, due to technical constraints and the fact that VETS backs up its systems, Personal Information may continue to reside in VETS’s systems after deletion. Individuals, therefore, should not expect that their Personal Information would be completely removed from VETS’s systems in response to an accepted request for deletion.
VETS reserves the right to decline access to Personal Information where the information requested:
1. Would disclose the Personal Information of another individual or of a deceased individual;
2. Would disclose business confidential information that may harm VETS or the competitive position of a third party;
3. Is subject to solicitor-client or litigation privilege;
4. Could reasonably result in:
a)serious harm to the treatment or recovery of the individual concerned;
b)serious emotional harm to the individual or another individual; or
c)serious bodily harm to another individual;
5.May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions;
6.Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information; or
7. Does not exist, is not held, or cannot be found by VETS.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure. Where information will be disclosed, VETS will endeavour to provide the information in question within a reasonable time and no later than thirty (30) days following the request. VETS will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, VETS will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information.
To guard against fraudulent requests for access, VETS will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
Your provision of Personal Information to VETS means that you agree and consent that VETS may collect, use and disclose your Personal Information in accordance with this Policy. If you do not agree with these terms, you are requested not to provide any Personal Information to VETS. Certain services can only be offered if you provide Personal Information to VETS. Consequently, if you choose not to provide us with any required Personal Information, VETS may not be able to offer you certain services.
If you do not wish to receive information regarding the products and services offered by VETS and its trusted affiliates, independent contractors and business partners please contact the hospital.
Amendment of practices and this Policy
This statement is in effect and was last revised as of May 1, 2011. VETS will from time to time review and revise its privacy practices and this Policy. In the event of any amendment, an appropriate notice will be posted on this website. Policy changes will apply to the information collected from the date of posting of the revised Policy to VETS’s website as well as to existing information held by VETS.