The privacy of all our clients’ personal information is important to the Jasper and Valemount Veterinary Clinic. Above all else we strive to provide compassionate, skilled and accessible veterinary care to all our patients. In doing so we are committed to collecting, using and disclosing personal information responsibly and only when necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.
What is considered your 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. health history, health conditions, health services received by them), or their activities and views (i.e. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Business information (i.e. an individual’s business address and telephone number), is not considered personal information and is not protected by privacy legislation.
Who we are and who may have access to the information you give us:
The Jasper and Valemount Veterinary Clinic includes two Veterinarians and eight support staff. We use a few consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include, [computer consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies and lawyers]. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
The main reasons why we collect personal information:
About our clients:
Like all veterinarians, we collect, use and disclose personal information in order to better serve our clients.
The primary reason we collect 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 to provide the veterinary care they choose.
The second reason is to obtain a baseline of an animals’ health so that in providing ongoing veterinary services we can identify changes that are occurring and offer better options of care
The third reason is to meet regulatory requirements for operating a veterinary clinic in our provinces and country.
It would be rare for us to collect 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 or impossible 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).
About Members of the General Public:
Our reason for collecting personal information of people who are not our clients is to provide notice of special events (i.e. obedience classes) or to make them aware of veterinary services.
On our website we do not collect any personal information. On our Facebook page we only collect the information that is publicly available and stored by Facebook (i.e. name, profile picture, any comments that are made on our posts/photos) and we only use this information for interactions on Facebook.
About Contract Staff, Volunteers and Students:
For people who are contracted to do work for us (i.e.temporary workers), our reason for collecting personal information is to ensure we can contact them in the future (i.e. for new assignments) and for necessary work-related communication (i.e. sending out pay cheques, yearend tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency or to investigate a possible breach of law (i.e. if a theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work-related performance and provide a report to them.
Secondary reasons why we collect and use personal information:
Like most organizations, we also collect, use and disclose information for purposes 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 (i.e. Annual Exams, Vaccinations)
· To advise clients and others of special events or opportunities (i.e. obedience classes, 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, lawyers, 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 (ABVMA) who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behavior to the authorities. External regulators have their own strict privacy obligations. Sometimes these 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 a part of their mandates. In these circumstances, we may consult with professionals (i.e. lawyers, accountants) who will investigate the matter and report back to us.
· The cost of some goods/services provided by the Jasper and Valemount Veterinary Clinic to clients may be paid for by third parties (Insurance Companies). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information (i.e. medical records/invoices) 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 Alberta Veterinary Medical Association (ABVMA) also requires us to retain our medical records).
· If the Jasper and Valemount Veterinary Clinic or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’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 (i.e.: 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 (i.e.: external regulation required by the AVMA)
How we protect your 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 secured staff only area.
· Electronic hardware is either under supervision or in a secured staff only area at all times. In addition, passwords are used on computers.
· We do regular PCI compliance audits as mandated to ensure the security or our hardware, software and any information on it.
· Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
· External consultants and agencies with access to personal information must enter into privacy agreements with us.
How long we retain and how we destroy 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 Alberta Veterinary Medical Association (ABVMA). However, we do not want to keep personal information too long in order to protect your privacy.
We keep our client files for a minimum of five years after the last contact. Our client and contact directories are much more difficult to systematically destroy, so we remove such information as possible 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) for about six months.
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 have the right to look at your information:
With only a few exceptions, you have the right to see what personal information we hold about you. All you have to do is ask. We will also try to help you understand any information you do not understand (i.e. short forms, technical language, etc.). If you would like help better understanding the information, please give us some advanced warning so we can set aside the time to properly answer any questions you may have. If we do not know you, we will need to confirm your identity before providing you with this access.
If there is a problem, we may ask you to put your request in writing. If we cannot give you access, if possible we will tell you within 30 days and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information.
Do you have any questions?
We can be reached by E-Mail at firstname.lastname@example.org or by phone at 780-852-5551
We will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our receptionist. They 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.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body at:
The Alberta Veterinary Medical Association (ABVMA)
Building 3, Elm Business Park
Suite 104, 9452 – 51
Avenue Edmonton, Alberta
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 out here. There are some rare exceptions to the commitments set out above.