WHAT IS PERSONAL INFORMATION?
WHO WE ARE
COLLECTION OF PERSONAL INFORMATION:
WE COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES
- To invoice clients for goods or services, to process credit card payments or to collect unpaid accounts.
- To advise clients that their product or service should be reviewed (e.g., to ensure a product is still appropriate for their then current needs and to consider modifications or replacement).
- To advise clients and others of special events or opportunities that we have available.
- Naturopaths are regulated by the College of Naturopaths who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. Osteopaths are governed by their College, as are Registered Massage Therapists, Psychotherapists and Chiropractors. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information & Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
- The cost of some goods/services provided by Cornerstone Health Centre to clients is paid for by third parties (e.g., private insurance). These third-party payers often have your 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 ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory Board also requires us to retain our client records).
- If Cornerstone Health Centre or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Centre’s records 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 provided 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 (e.g., by declining to receive notice of special events or opportunities, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION
- Paper information is either under supervision or secured in a locked or 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. All of our cell phones are digital, as such signals are more difficult to intercept.
- 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
YOU CAN LOOK AT YOUR INFORMATION
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