Privacy of personal information is an important principle to the Davis Drive Animal Clinic. We are committed to collecting, using and disclosing personal information responsibly and only to the extent 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 Personal Information?
Personal Information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, home address or phone number, family status). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number).
Who We Are
Our organization, Davis Drive Animal Clinic, includes at the time of writing 4 veterinarians and 6 support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers 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.
We Collect Personal Information: Primary Purposes
Like all veterinarians, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide veterinary services. For example, we collect information about your animal’s history, physical condition and function in order to help us assess what their needs are, to advise you of your options and then to provide the veterinary care you choose. A second primary purpose might be to obtain a baseline of health information so that in providing ongoing veterinary services you can identify changes that are occurring and a third primary purpose is to meet regulatory requirements.
It would be rare for us to collect such 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 to obtain consent (e.g., 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
For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of veterinary service in general or our clinic in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.
On our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message). Cookies are only used to help you navigate our website and are not used to monitor you.
We Collect Personal Information: Related and Secondary Purposes
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 and to ensure a service that was performed has a proper outcome, is still appropriate for the current situation and to consider modifications or replacement where necessary.
- To advise clients and others of special events or opportunities (e.g., a seminar, 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 (e.g., auditors, lawyers, practice consultants, accreditation programs) may on our behalf do audits and continuing quality improvement review of our Clinic, including reviewing client files and interviewing our staff.
- Veterinarians are regulated by the College of Veterinarians of Ontario 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 behaviour 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 (e.g., improper services). Also, like all organizations, various government agencies (e.g., 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 (e.g., lawyers, and accountants) who will investigate the matter and report back to us.
- The cost of some goods/services provided by the Davis Drive Animal 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 in order to demonstrated 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 year s for which our previous records were 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 College also requires us to retain our client records).
- If the Davis Drive Animal 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 (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
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information is either under supervision or secured in a restricted area.
- Electronic hardware is either under supervision or secured in a restricted are at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted through a direct line.
Retention and Destruction of 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 external regulatory bodies. However, we don not want to keep personal information too long in order to protect your privacy.
We keep our client files for about five years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can 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 destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we will ensure that the hard drive is physically destroyed. Alternatively, we may send some or all of a client file to our client.
You Can Look at Your Information
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.) We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
If there is a problem we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best as 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. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
Do You Have a Question?
Our Information Officer, Dr. Jennifer Murray, can be reached at:
Davis Drive Animal Clinic
891 Davis Drive
Newmarket, Ontario, L3Y 2R6
She will attempt to answer any questions or concerns you might have.
If you have a concern about the professionalism or competence of our services we would ask you to discuss those concerns with us.
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 set out here. There are some rare exceptions to the commitments set out above.