We respect the privacy of everyone who visits this site – eyeTrust.ca Corporation
While we have always respected our clients, customers, and member’s privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients, customers, members 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’, customers’, members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’, members’ personal information and allowing our clients, customers, members to request access to, and correction of, their personal information.
SPECIAL NOTICE – IF YOU ARE UNDER 18 YEARS OLD
eyeTrust.ca Corporation does not intentionally collect personal data of persons under 18 years old. If you are under 18 years old please do not send us your personal information (for example, your name, address and email address). If you are under 18 years old and you wish to ask a question or use this Website in anyway which requires you to submit your personal information please get your parent or guardian to do so on your behalf.
Personal Information – means information about an identifiable individual [Name, age, birth date, address, phone number, martial status, medical information, employment information, health card information]. 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 name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that eyeTrust.ca Corporation complies with this policy and PIPA
POLICY 1 – COLLECTING PERSONAL INFORMATION
1.1 Unless the purposes for collecting personal information are obvious and the client, customer, member 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, customer, member information that is necessary to fulfill the following purposes:
- To respond to queries or requests submitted by you;
- To process orders submitted by you;
- To administer or carry out our obligations in relation to any agreement you have with us;
- To anticipate and resolve problems with any products or services supplied to you;
- To better tailor and improve the features of products and services;
- To create products or services that may meet your needs;
- To verify identity [including name, birth date, address, telephone number and email address];
- To verify credit worthiness;
- To identify [client, customer, member] preferences;
- To understand the [financial, banking, insurance] needs of our [clients, customers, members];
- To open and manage an account or patient file submitted by you;
- To deliver requested products and services;
- To guarantee benefits from eyeTrust, each other and our external partnerships;
- To process an online newsletter subscription;
- To provide [eye care, optical, business] services;
- To enroll the client in the eyeTrust rewards program;
- To send out association membership information;
- To contact our [clients, customers, members] for fundraising;
- To ensure a high standard of service to our [clients, customers, members];
- To meet regulatory requirements;
- To assess suitability for tenancy;
- To collect and process applicable payments;
POLICY 2 – CONSENT
2.1 We will obtain client, customer, member 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, electronically (e-mail), or written 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, customer, member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client, customer, member 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. The client, customer, member can also give consent to 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), clients, customers, members can withhold or withdraw their consent for eyeTrust.ca Corporation to use their personal information in certain ways. A client’s, customer’s, member’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, customer, member in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s, member’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- 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
From time to time we would like to use your personal information for purposes other than as set out in the above sections.
We believe that these additional uses will be of benefit to you. However, we understand that you may not wish us to use your information in this way.
We will not use your information for the purposes set out below if you have indicated that you do not wish us to use your information in this way when submitting the information.
Additionally, if at any time you wish us to stop using your information for any or all of the below purposes, please let us know (see contact information below).
We will take the necessary steps to stop the use of your information for such purposes with immediate effect.
In such case we will, however, continue to use your personal data for the purposes set out in the above section for as long as necessary to achieve such purposes.
3.1 We will only use or disclose client, customer, member 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, customer, member surveys in order to enhance the provision of our services;
- To contact our [clients, customers, members] directly about products and services that may be of interest;]
- To contact [clients, customers, members] directly about matters that may be of interest
- To conduct market research and tracking of sales data
3.2 We will not use or disclose client, customer, member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, customer, member lists or personal information to other parties [unless we have consent to do so].
POLICY 4 – RETAINING PERSONAL INFORMATION
4.1 If we use client, customer, member personal information to make a decision that directly affects the client, customer, member, we will retain that personal information for at least one year so that the client, customer, member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, customer, member 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, customer, member personal information is accurate and complete where it may be used to make a decision about the client, customer, member or disclosed to another organization.
5.2 Clients, customers, members 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, e-mail, or orally 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’, customers’, members’ correction request in the file.
POLICY 6 – SECURING PERSONAL INFORMATION
We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use and will update these measures as new technology becomes available, as appropriate.
6.1 We are committed to ensuring the security of client, customer, member 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, customer, member personal information is appropriately protected:
- The use of locked filing cabinets
- Physically securing offices where personal information is held
- Use of user IDs and passwords
- Restricting employee access to personal information as appropriate
6.3 We will use appropriate security measures when destroying client’s, customer’s, member’s personal information such as [shredding 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 CLIENTS, CUSTOMERS, MEMBERS ACCESS TO PERSONAL INFORMATION
7.1 Clients, Customers, Members have a right to access their personal information, subject to limited exceptions (A full listing of the exceptions to access can be found in section 23 of PIPA).
7.2 A request to access personal information must be made in writing, e-mail or orally and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell clients, customers, members 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, customer, member of the cost and request further direction from the client, customer, member 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, customer, member in writing, providing the reasons for refusal and the recourse available to the client, customer, member.
POLICY 8 – QUESTIONS AND COMPLAINTS: THE ROLE OF THE PRIVACY OFFICER OR DESIGNATED INDIVIDUAL
8.1 The Privacy Officer is responsible for ensuring eyeTrust.ca Corporation’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients, Customers, Members should direct any complaints, concerns or questions regarding eyeTrust.ca Corporation’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer, member may also write to the Information and Privacy Commissioner.
Contact information for eyeTrust.ca Corporation’s Privacy Officer:
We may store some information (commonly known as a “cookie”) on your computer when you look at our Website. We are able to read these cookies for information purposes when you revisit our Website.
The type of information we collect as a result of a cookie being accepted by you is specific to your PC and includes the IP address, the date and time the PC visited the Website, what parts of our Website were looked at and whether the web pages requested were delivered successfully. This information is anonymous; it represents a computer rather than a person.
We use the cookie information to improve our knowledge of the use of our Website and to enable us to be able to ascertain whether the Website is operating at an optimal level. This allows us to enhance our web offerings to you and to provide an enjoyable and an innovative online experience.
You can erase or block this information by changing the settings on your computer (please refer to your help screens or manuals). If you do erase or block this information you may not be able to utilize some features of the Website.
E-MAIL, FEEDBACK AND FORUM FACILITIES
USE OF YOUR PERSONAL INFORMATION SUBMITTED TO OTHER WEBSITES
We cannot be responsible for the privacy policies and practices of other websites even if:
- You accessed the third party website using links from our Website;
- You linked to our Website from a third party website;
We recommend that you check the policy of each site you visit and contact the owner or operator of such website if you have any concerns or questions.
SUBMISSION OF OTHERS PERSONAL INFORMATION
© eyeTrust.ca Corporation April 2015