Definition of “Personal Information”
Personal information is any information about a specific, identifiable individual, including such commonly available details as name, address and telephone number. Exceptions to this definition include information that is available in the public domain – for example, business contact information. Despite the fact that some personal information is widely available (for example, through telephone directories or public databases), we consider our stakeholders’ information always to be personal information, and do not use or disclose it without their consent.
Our Privacy Principles
Hypertension Canada gathers and uses personal information during the course of our activities. For example, we gather information when an individual becomes a member, makes a donation, registers for our congress or otherwise engages with us. Anyone from whom we collect personal information should expect that it is carefully protected and that its use is subject to the individual’s consent.
1. Our accountability
We are responsible for the protection of your personal information collected through our activities. This responsibility extends to cases in which personal information is transferred to or collected by third parties on our behalf; for example, an agency contracted to plan a conference for us.
2. Identification of the purposes for collecting personal information
Before we collect any personal information from you, unless it is clear by the nature of the contact – for example, your completion of an online learning module’s registration form – we’ll tell you why we’re collecting it. A statement of purpose will be communicated wherever possible.
3. Your knowledge and consent
We will only collect personal information with your knowledge and consent. This may be with your expressed consent – for example, where you voluntarily provide information on a form for a clear purpose, such as a member sign-up – which can be given orally, electronically or in writing. Consent may also be implied, meaning reasonably inferred from an individual’s action or inaction – such as inferred when we send a current member notice of an upcoming conference. At any time, you can withdraw your consent to the collection, use or disclosure of your personal information. We will at such time advise you of any limitations to our ability to provide you with services that result from the withdrawal of your consent.
4. Limiting information collection
We only collect personal information relevant and necessary to our programs and services, which include:
- Membership with Hypertension Canada, upon sign-up;
- Our monthly electronic newsletter, eINFO, upon sign-up;
- Our professional education programs, upon registration:
- Professional Education Program
- TTT (Train the Trainer) sessions and local workshops
- Our annual Canadian Hypertension Congress, upon registration or abstract submission;
- Our educational materials, upon placing an order; and
- Donations made via Canada Helps, upon donation.
We collect information fairly and lawfully, and directly from individuals wherever possible to ensure we do so accurately. At this time, we collect personal information through the activities listed above, through the method(s) you choose (via website, mail, phone, fax or verbal request) to request them.
5. Limiting information use and disclosure
We only use or disclose your personal information for the purposes we have identified to you. Additionally, certain of the services made available through our website and by Hypertension Canada more generally are provided by third-party service providers and their agents (collectively, “Third-Party Providers”) of Hypertension Canada. Such Third-Party Providers may have access to personal information in order to provide the services, including our email communications via Constant Contact and TD Canada Trust for payment collection services when individuals take out a membership or register for a professional education module.
Any Third-Party Providers that have access to personal information are chosen carefully by Hypertension Canada and are required to have privacy and security standards that meet Hypertension Canada’s strict requirements.
Hypertension Canada uses contracts and other measures with its Third-Party Providers to maintain the confidentiality and security of your personal information and to prevent personal information from being used for any other purpose, including for any advertising or other commercial purposes.
6. Email and online communications
In order to provide our members, volunteers, donors, clients, employees and other stakeholders with publications, information or requested services, visitors may voluntarily submit personal information to us for such purposes as subscribing to or downloading publications, participating in a seminar or other event, participating in surveys or asking a question. We use the personal information you provide only for the purpose for which you have provided it. If a subscriber or visitor has subscribed or attended a seminar or other event in the past, we may combine the information with information submitted on the website. We provide an ongoing opportunity to unsubscribe or opt-out of contact from us by email to [email protected] or by telephoning 905-943-9400.
We may send email communications to subscribers or other individuals in our contact database to advise of medical or scientific developments, distribute publications and advise of events or seminars, or of educational opportunities. Each email includes an opt-out feature and instructions on how to unsubscribe if you do not wish to receive future emails from us for these purposes.
7. How we collect personal information through automatic means
Our website uses Google Analytics to help us analyze how visitors use the site. This tool uses “cookies”, which are text files placed on your computer, to collect standard Internet log information and visitor use information in an anonymous form. The information generated by the cookie about your use of the website, including your IP address, is transmitted to Google and compiled with all other visitors’ information in a statistical report about our website that tells us, for example, which are our most popular pages or our most downloaded resources, or when our website is most often visited.
We will never, and will not allow any third party to, use the statistical analysis tool to track or collect any personal information of visitors to our site. Google will not associate your IP address with any other data held by Google. Neither we, nor Google, will link or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any personal information from any source, unless you explicitly submit that information via a fill-in form on our website.
8. Accuracy of your personal information
Virtually all of the personal information that we collect comes directly from individuals themselves, and so we generally consider it to be accurate. We encourage you to review, correct and update your personal information to help us ensure our best possible service to you.
9. Safeguards on your personal information
We keep in confidence all personal information we gather and the security of your personal information is important to us. We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.
Third-Party Providers performing services on behalf of Hypertension Canada may store or process personal information on servers located outside of Canada, in jurisdictions (including the United States) whose data protection laws differ from those of Canada. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third-Party Providers to maintain protections on personal information that are equivalent to those that apply in Canada.
13. Retention and disposal
We retain your personal information only as long as is necessary to fulfill those purposes or as is required by law. We have retention standards, which meet these requirements. We destroy your information when it is no longer needed, or we remove your name from the information.
We are open about our policies and procedures. We make reasonable efforts to inform individuals about our policies and procedures, the purposes for which we collect, use or disclose personal information, and how to access one’s personal information, as outlined in this Policy.
15. Your access to your personal information
You can learn more about your privacy and your rights with regard to your personal information by visiting the website of the Privacy Commissioner of Canada at www.privcom.gc.ca.
Approved by the Board of Directors
September 21, 2017