Effective: January 11, 2008
Pursuant to the Personal Information protection and Electronic Documents Act (PIPEDA).
Protecting the privacy of your personal information is important to us.
We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the optometric services that we provide.
We are committed to being open and transparent about how we handle your personal information. This document describes our privacy policies.
Effective Date and Changes
What is Personal Information?
Personal information is information about an identifiable individual that relates to any personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status), health (e.g. health history, health conditions, health services received) or activities and views (e.g. religious or political affiliations) of that individual.
Personal information does not include your business address and telephone number, which are not protected by privacy legislation.
Who We Are
‘Fusion Eyecare Doctors of Optometry’ includes all affiliated optometrists and health care professionals, as well as all employees, staff and student trainees and who are bound by our confidentiality policies and thereby authorized to collect, use or disclose personal information about our patients.
We employ and communicate with a number of consultants and agencies that may, in the course of their work for us, have limited and necessary access to personal information we hold. These include, but are not limited to; ophthalmologists and other health professionals with whom we have a co-management relationship, third party insurers, contact lens companies, lens manufacturing companies, opticians, computer consultants, office security and maintenance personnel, bookkeepers and accountants, credit card companies, collection agencies, website managers and lawyers.
In all cases, we restrict third party access to any personal information we hold as much as is reasonably possible.
Our Primary Purpose for Collecting Personal Information
Fusion Eyecare Optometry collects, uses and discloses personal information in order to serve our patients. For patients, the primary purpose for collecting personal information is to provide optometric services. For example, we collect information about your health history, including family history, physical condition and function, and social history as necessary to help us assess your eye care needs and provide appropriate recommendations.
We may communicate this information to other regulated health practitioners, technicians or individuals authorized to work in our practice as part of your continuing care. It would be rare for us to collect information without the patient’s written, oral or implied consent, but this could occur in an emergency (e.g. the patient cannot communicate) or where we believe you would consent if asked and it is impractical to obtain consent (e.g. a family member passing a message on regarding a patient where we have no reason to believe that the message is not genuine).
On our website we only collect the personal information you provide and only use that information for the purpose for which it was provided (e.g. to respond to your email message, to order contact lenses, to schedule an appointment).
About Contract Staff, Volunteers and Students:
For people who are contracted to do work for us (e.g. temporary workers), our primary purpose for collecting your personal information is to ensure we can contact you in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending our paycheques, year-end 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 (e.g. a SARS outbreak) or to investigate a possible breach of law (e.g. if a theft were to occur in the office).
Related and Secondary Purposes for Collecting Personal Information:
We may also collect, use and disclose information for purposes related to or secondary to our primary purposes. You can choose to be excluded from some of these related or secondary purposes (e.g. by declining to receive notice of special events or opportunities, or by paying for your services in advance).
The most common examples of our related and secondary purposes are as follows:
To invoice patients for optometric services, products or treatments that were not paid for at the time the service was provided, to process credit card payments or to collect unpaid accounts either ourselves or through a collection agency or lawyer.
To apply for a benefit on your behalf when the cost of some optometric services, products or treatments provided by the practice to patients is paid for by third parties (e.g. First Nations Health Insurance Board, the Ministry of Human Resources).
To advise you, by telephone, mail or email that your vision and eye care needs or treatment should be reviewed (e.g. to schedule an appointment, to ensure that your eye glasses and/or contact lenses are still functioning properly and appropriate for your current needs and to consider modifications ore replacement).
To advise patients, prospective patients 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 office reviews patient and other files for the purpose of administration, business planning and ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g. auditors, lawyers, practice consultants, quality assurance assessors) may, on our behalf, do audits and continuing quality improvement reviews of our practice, including reviewing patient files and interviewing our staff. In rare cases, our practice or our consultants may make inquiries to verify that the information we have about you is accurate.
Optometrists are regulated by the College of Optometrists of British Columbia, which may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we have a duty to report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Sometimes these reports may necessarily include personal information about our patients, or other individuals, to support the concern . Also, various government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, et cetera) may claim 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) regarding our legal obligations to comply,
In the event that Fusion Eyecare or its assets were to be sold, the prospective purchaser would expect to conduct a “due diligence” review of the practice records to ensure that it is a viable business that has been honestly portrayed to the prospective purchaser information. The prospective purchaser would not be allowed to remove or record personal information and, before being provided a review of the clinical files and records, the prospective purchaser would be required to provide a written promise to keep all personal information confidential. Only a reputable purchaser who has already agreed to purchase the practice or its assets would be provided, at closing, complete access to personal information. The purchaser would be required to maintain the same principles of privacy as established under the present privacy legislation.
Protecting Personal Information
We understand the importance of protecting your personal information.
For that reason we have taken the following steps:
Paper records are either under supervision or secured in a locked or restricted area. Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies or collected by the patient who asks for the information.
Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. Electronic information is transmitted either through a direct line or is anonymized or encrypted.
Verbal personal information is collected and used in such a manner that other persons do not hear the exchange of the information.
External consultants and agencies with access to personal information must enter into privacy agreements with us.
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 we provided to you and for our own accountability to external regulatory bodies. In compliance with the requirements of other legislation, we keep our patient files and records for a minimum of ten (10) years.
You can ask us, in writing, to restrict our uses and disclosures of personal information at any time. We will also discontinue to use or to disclose your personal information after a written revocation of your implied or informed consent is received, unless we have already acted in reliance upon this consent. 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 information on the hard drive is destroyed.
You Can Look At Your Information
With rare exceptions, you have the right to see what personal information we hold about you. 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, et cetera).
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. We may ask you to put your request in writing. If we cannot give you access, we will notify you within thirty (30) days if at all possible and provide the reason, as best we can, as to why we cannot give you access. If you believe there is a mistake in the information we have about you, 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 incorrect. Where a mistake has been made, we will make the correction and notify anyone to whom we sent this information. If we do not agree that a mistake has been made, we will 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 Privacy Officer, Dr. Rebecca Counts, can be reached in writing at 4609 Park Avenue, Terrace BC, or by phone at 250-638-2020. She will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices or the application of those practices, you may make it in writing to our Privacy Officer. She 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.
This policy is made pursuant to 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. The Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at: 112 Kent Street, Ottawa, Ontario, K1A 1H3 Phone (613) 995-8210 / Toll-Free 1-800-282-1376 Fax (613) 947-6850 / TTY (613) 992-9190 , web site www.privcom.gc.ca