At the Animal Emergency Clinic of the Fraser Valley (AECFV), we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.While we have always respected our clients’ 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 January 1, 2004, sets out the ground rules for how BC businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients 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 clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information; and allowing our clients to request access to, and correction of, their personal information.
Personal Information – Information about an identifiable individual (E.g., name, age, home address and phone number, marital status, employment information). Personal information does not include contact information (described below).
Contact Information – Information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client 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 client information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify client preferences;
- To deliver requested products and services;
- To provide veterinary services including boarding;
- To ensure a high standard of service to our clients;
- To meet regulatory requirements;
- To collect and process payments.
Policy 2 – Consent
2.1 We will obtain client 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 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 his or her personal information being used for mail-outs, the marketing of new services or products, fundraising 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 frustrate the performance of a legal obligation), a client can withhold or withdraw their consent for AECFV to use their personal information in certain ways. A client’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 client in making the decision.
2.5 We may collect, use, or disclose personal information without the client’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 (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
Policy 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 or for a purpose reasonably related to those purposes such as:
- To conduct client surveys in order to enhance the provision of our services;
- To contact our clients directly about products and services that may be of interest.
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties.
Policy 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 the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client 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 client 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 A client 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 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 clients’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client 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 client personal information is appropriately protected:
- The use of filing cabinets;
- Physically securing offices where personal information is held;
- The use of user IDs, passwords, encryption, firewalls;
- Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access);
- Contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying client’s personal information such as:
- Shredding/incinerating documents, deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Client Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions such as:
- Doctor-client privilege;
- Disclosure would reveal personal information about another individual;
- Health and safety concerns;
- Services performed were not paid in full.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
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 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 client of the cost and request further direction from the client 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 client in writing, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Audio, Video, and Audio/Video Recording
8.1 We record all incoming and outgoing phone calls and we have 24 hour video and audio/video recording on our premises. All video, audio/video, and audio recording (of premises and phone lines) is collected in compliance with PIPA as described in this document.
8.2 We will limit video, audio, and audio/video collection to capture the least amount of information necessary and will safeguard recording set up from tampering.
8.3 We will communicate the purposes for which information is collected before or at the time of collection unless the purpose is obvious or as indicated herein (8.4).
8.4 We will only collect video and/or audio recordings as is necessary to fulfill the following purposes:
- For the security of our premises;
- For the protection of our staff, especially in confined spaces;
- To deliver agreed upon products and services;
- To ensure a high standard of service to our clients;
- For ongoing staff training;
- For dispute resolution.
8.5 At or before the time of collection, we will obtain client consent to collect, use, or disclose personal information either orally, in writing, electronically, through an authorized representative or when consent is implied when the client voluntarily provides personal information for a purpose which is obvious or when the client is given notice and a reasonable opportunity to opt-out. Visible and clear signage serves as notice of recording on premises so that an individual may opt-out if they do not consent to being recorded.
8.6 Recordings will be stored securely to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. We will limit access to the Hospital Manager only. The Hospital Manager understands their obligations under privacy laws and will only access recordings when necessary and with consent.
8.7 Subject to the parameters noted above, we will, upon request, provide access to recordings of a client, tell a client how we use their personal information, and to whom it has been disclosed, if applicable. Any time recordings regarding an individual are disclosed, we will ensure identifying information about other individuals is protected.
8.8 We will retain recordings only as long as necessary to fulfill identified legal or business purposes and to provide the client a reasonable opportunity to request access to their information. We will use appropriate security measures when deleting recordings when they are no longer needed.
Policy 9 – Questions and Complaints: The Role of the Designated Individual
9.1 The Hospital Manager is responsible for ensuring AECFV’s compliance with this policy and the Personal Information Protection Act.
9.2 Clients should direct any complaints, concerns or questions regarding AECFV’s compliance in writing to the Hospital Manager. If the Hospital Manager is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for AECFV’s Hospital Manager:
Rob Koreman – 604-514-1711 (email: firstname.lastname@example.org)