BIENVENIDO A VITA MEDICAL

Su clínica médica privada sin cuota de membresía

Clínica médica privada - na división de CMIPQ

514-292-0801

Privacy policy of the private clinic Vita Medical, a division of CMIPQ

Effective Date: April 2023, last updated December 4, 2023

  • Policy Objectives
  • Why we collect personal information
  • What personal information do we collect?
  • Who can see your personal information?
  • How do we protect your personal information?
  • Consent
  • Retention and Destruction of Personal Information
  • Access and correction of personal information
  • Our roles and responsibilities
  • Monitoring and Evaluation
  • Related Reference Documents
  • Questions or complaints

Policy objectives

In carrying out our mandate under the Privacy Act and the Personal Information Protection and Electronic Documents Act (PIPEDA), we, Vita Medical, a division of CMIPQ, collect personal information as required by section 4 of the Private Sector Privacy Act. Vita Medical, a division of CMIPQ, is committed to protecting the privacy rights of all individuals for whom it has collected personal information. Our employees’ personal information is subject to the Vita Medical Employee Privacy Policy, a division of CMIPQ, and not this policy.

This policy respects the Privacy Act and the principles of natural justice.

Why we collect personal information

We collect personal information for a variety of reasons. In general, the information collected relates to our business needs for each division. We may also collect information for administrative purposes, for example, to send results to a professional partner. Information may also be collected as part of internal statistics.

We may only use your personal information for the purposes for which it was collected or for a use consistent with those purposes, or for the purposes listed in section 8 of the Private Sector Privacy Act.

What personal information do we collect?

We only collect personal information that is directly related to our activities. Where possible, this information will be collected directly from the individual. The amount and type of information collected will be limited to what is necessary for the identified purposes. We only collect what we need.

For example, we may ask for your name, date of birth, contact information, identity card number, or collect your opinion through a survey.

Sometimes we get more information than we need. For example, some people indicate their social insurance number on their request for general information. We strongly encourage you not to provide information beyond what is necessary.

The personal information described is used or available for administrative purposes or is classified so that it can be retrieved as efficiently as possible, by the name of the individual, a file number.

Who can view your personal information?

We will not disclose your personal information without your consent, unless authorized by subsection 8(2) of the Private Sector Privacy Act. In the case of an authorized disclosure, we will attempt to disclose only the specific information that is necessary in the circumstances and, to the extent possible, we will inform the individual of the disclosure.

Access to personal information at the Vita Medical private clinic, a division of CMIPQ, will be limited to employees who need the information to perform their duties. These employees will treat the information as strictly confidential and will not give access to the information to any unauthorized person. The level of access to personal information will be granted to employees on a need-to-know basis.

Any person we hire under contract or otherwise to perform duties on our behalf must comply with the provisions of the Private Sector Privacy Act, and this policy and related internal procedures. Any breach of any part of the contractual agreement may result in the cancellation of the contract.

How do we protect your personal information?

Failure to protect personal information in any organization can increase the risk of a privacy breach. These breaches can lead to various problems such as damaging the reputation of the person or allowing fraud or identity theft.

We will protect personal information from loss or theft, unauthorized access, use or disclosure, modification or destruction, through appropriate administrative, technical and physical security and protection measures. The level of protection afforded to personal information depends on:

The sensitivity of the personal information;
Quantity, distribution and format of information;
The method of preservation.

We adhere to the Government of Canada Security Policy and all other information technology security directives and guidelines adopted by relevant federal and provincial agencies.

Consent

Where possible, we try to obtain the consent of the individual before collecting their personal information. The form of consent may vary depending on the circumstances and type of information sought. Consent may be express or implied and may be provided directly by the individual or their authorized representative.

We prefer to obtain express consent, whether verbally, electronically or in writing. Implied consent may reasonably be inferred from an individual’s action or inaction, for example, providing a name and address to receive a publication or a name and telephone number to obtain an answer to a question.

In determining the appropriate type of consent, we consider the sensitivity of the personal information involved, the purposes for which it is collected, and the reasonable expectations of the individual. If we want to use the personal information for a new purpose, we will describe the intended use and seek consent again.

It is not always possible during the investigation to obtain the consent of the individual to collect, use or disclose their personal information. Both the Privacy Act and PIPEDA allow the disclosure of personal information for the purposes of an investigation if it is necessary for the investigation.

We will not use your personal information without your consent, except:

Whether they are to be used for the same purposes for which the information was originally collected or compiled;
If the use is compatible with this purpose;
If they are to be used for a purpose under subsection 8(2) of the Privacy Act.

Retention and Destruction of Personal Information

We need to ensure that all personal information is treated in a predetermined life cycle. In accordance with the Privacy Act and Regulations, the personal information we use to make a decision about an individual will be retained for at least two years after that decision. This period is sufficient to allow someone to take legal action and exercise all their rights under the Privacy Act.

We will retain personal information in accordance with the recommended maximum retention periods.

The retention, disposal and destruction of personal information is carried out in accordance with the privacy practices recommendations of the Government of Canada and Quebec.

Access to and correction of personal information

You can access or correct your personal information informally without using the Privacy Act. However, you have the right to formally request access to or correct your personal information under the Privacy Act. You also have the right under the Access to Information Act to formally request access to information contained in the records of the private clinic Vita Medical, a division of CMIPQ that may include your personal information.

Only formal requests for access to personal information under the Privacy Act give you the right to make a complaint to the Privacy Officer if you are not satisfied with the original decision. Similarly, you may request a correction of your personal information only if it was provided under a formal request for access under the Privacy Act. In addition, only formal access requests under the Access to Information Act give you the right to make a complaint.

Employees of the private Vita Medical Clinic, a division of CMIPQ, must refer individuals who formally wish to access or correct their personal information.

We make every effort to ensure that the information used in making a decision directly about an individual is as accurate, up-to-date and complete as possible. This also applies to information disclosed to third parties.

Our roles and responsibilities

We are responsible for personal information collected, retained, used, disclosed and destroyed in the course of carrying out our mandate. We will continue to develop policies and practices to ensure that this information is treated in strict compliance with the Private Sector Privacy Act. The Privacy Officer at Vita Medical Private Clinic, a division of CMIPQ, is responsible for monitoring the application of these policies and practices to ensure compliance, including:
  • Providing the same training to all clinic staff (including temporary employees)
  • Ensuring open, complete and timely communication with employees and others about the clinic’s policies, practices and expectations regarding the handling of personal information;
  • Establishing standards for the classification of the sensitivity of personal information to determine the appropriate level of protection for that information;
  • Implementing systems that ensure that only employees whose duties require access to personal information are authorized to have access to the information in question;
  • By including specific provisions in contracts or other arrangements with third parties that require compliance with the Private Sector Privacy Act;
  • Ensuring that procedures are in place for individuals to request access to and correction of their personal information, and to file complaints about the management of their personal information;
  • Ensuring that procedures are in place to advise individuals of any inappropriate collection, retention, use, disclosure or destruction of their personal information;
  • Monitoring compliance with this policy and, if necessary, taking action to correct any deficiencies.
Employees — Personnel who collect personal information on behalf of the Vita Medical Private Clinic, a division of CMIPQ, will be required to explain the purposes for which the information is obtained. If they cannot, they will be required to refer the person to another employee who can explain the reason for the collection. It is the responsibility of each employee of Vita Medical Private Clinic, a division of CMIPQ, to inquire about their obligations under this policy and the Private Sector Privacy Act. Employees must report any violations of the Policy or the Act to their manager or Privacy Officer.
Managers and Supervisors – In addition to the above responsibilities, managers and supervisors must inform their employees of the obligation to comply with the Policy and the Act. They must also examine or investigate any matter brought to their attention regarding the Policy or the Act. If necessary, managers and supervisors should advise the Director to work with him or forward certain questions.
Privacy Officer— The Privacy Officer will provide advice and direction to senior management and employees regarding the clinic’s handling of information personal. It will also serve as the first point of contact for individuals seeking information on the handling of their personal information by the private clinic Vita Medical, a division of CMIPQ or having concerns in this regard.
Director — In addition to all of the above responsibilities, the Director of the Vita Medical Private Clinic, A division of CMIPQ is required to properly enforce the Privacy Act and policies relating to personal information and access to information.

Any breach of this policy, whether intentional or negligent, may result in disciplinary action up to and including termination. Legal sanctions may also be taken, if necessary.

Monitoring and evaluation

Our internal audit program also includes verification of compliance with this policy. We conduct periodic audits of all our programs and services. The results of internal audits are forwarded to the Director and the Privacy Officer.

Related reference documents

The following legislation, policies and guidelines should be read in conjunction with this policy:
  • Privacy Act and Regulations
  • Access to Information Act and Regulations
  • Library and Archives of Canada Act
  • Privacy Policy
  • Policy on Government Security
  • Directive on Privacy Practices
  • Directive on Personal Information Requests and Correction of Personal Information
  • Directive on Privacy Practices – Appendix E: Web Analytics Privacy Standard
  • Directive on Privacy Practices – Appendix B: Mandatory Procedures for Privacy Breaches

Queries or complaints

Questions or complaints can be brought to the attention of any employee of the private Vita Medical clinic and the CMIPQ. If the employee is unable to assist, the matter should be assigned to their immediate supervisor or management.

If you have any questions about this policy or how we manage personal information, you may also contact:

Responsible for the protection of personal information C.M.I.P.Q

cmipq.com
3e étage, Montréal H3H 1L9

(514) 931-0801

When a person is dissatisfied with the measures that may have been taken by Vita Medical, a division of CMIPQ to correct the situation or explanations provided, they are informed of their right to file a complaint under the Privacy Act and are given instructions on how to do so. Please note that we do not investigate the compliance of our own measures with the Privacy Act. Any complaints about this are investigated independently by the Special Privacy Commissioner.