Personal Information Protection Policy
Personal Information Protection Policy
At Image Optometry we are committed to providing our customers and patients with professional service. As providing this service involves the collection, use, and disclosure of some personal information about our customers and patients . . . protecting their personal information is one of our highest priorities.
While we have always respected our customers’ and patients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on 01 January 2004, sets out the ground rules for how businesses and not-for-profit organizations in British Columbia may collect, use, and disclose personal information.
We will inform our customers and patients of why and how we collect, use, and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’ and patients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ and patients’ personal information and allowing our customers and patients to request access to, and correction of, their personal information.
Personal Information – means information about an identifiable individual (example: name, home address, home phone number, date of birth, MSP Healthcare card number, medical information, etc.). Personal information does not include contact information (described below).
Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position or title, business telephone number, business address, business email address or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Image Optometry complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer and patient voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customer and patient information that is necessary to fulfill the following purposes:
to verify identity;
to provide optometric services;
to provide opticianry services;
to ensure a high standard of service to our customers and patients;
to meet regulatory requirements; and
to collect Medical Services Plan payments.
Policy 2 – Consent
2.1 We will obtain customer and patient consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the customer and patient voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer and patient is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the customer and patient does not opt-out.
2.4 Subject to certain exceptions (example: the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers and patients can withhold or withdraw their consent for Image Optometry to use their personal information in certain ways. A customer’s and patient’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer and patient in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s and patient’s knowledge or consent in the following limited circumstances:
when the collection, use or disclosure of personal information is permitted or required by law;
in an emergency that threatens an individual’s life, health, or personal security;
when the personal information is available from a public source (example: a telephone directory);
when we require legal advice from a lawyer;
for the purposes of collecting a debt; or
to protect ourselves from fraud.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer and patient personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
to conduct customer and patient member surveys in order to enhance the provision of our services; or
to contact our customers and patients directly about products and services that may be of interest.
3.2 We will not use or disclose customer and patient personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer and patient lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use customer and patient personal information to make a decision that directly affects the customer and patient, we will retain that personal information for at least one year so that the customer and patient has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer and patient personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that customer and patient personal information is accurate and complete where it may be used to make a decision about the customer and patient or disclosed to another organization.
5.2 Customers and patients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing to the Privacy Officer and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customers’ and patients’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer and patient personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer and patient personal information is appropriately protected: physically securing offices where personal information is held; and the use of passwords, encryption, and firewalls for electronic data.
6.3 We will use appropriate security measures when destroying customer’s and patient’s personal information such as shredding physical documents, and deleting electronically stored information.
6.4 We will periodically review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Customers and Patients Access to Personal Information
7.1 Customers and patients have a right to access their personal information, subject to limited exceptions as can be found in section 23 of PIPA.
7.2 A request to access personal information must be made in writing to the Privacy Officer and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell customers and patients how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer and patient of the cost and request further direction from the customer and patient on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer and patient in writing, providing the reasons for refusal and the recourse available to the customer and patient.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Image Optometry’s compliance with this policy and the Personal Information Protection Act.
8.2 Customers and patients should direct any complaints, concerns or questions regarding Image Optometry’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer and patient may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Image Optometry’s Privacy Officer:
Attention: Kevin J. Bossons, General Legal Counsel
#101 – 2764 Barnet Highway
Coquitlam, British Columbia, Canada V3B 1B9