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INTRODUCTION
The ODHA is committed to respecting the privacy rights of all individuals,
including ODHA members and employees, by ensuring that their personal
information is collected, used and disclosed in an appropriate manner.
The Personal Information Protection and Electronic Documents Act ("PIPEDA")
is federal legislation that came into effect on January 1, 2001. In the absence
of corresponding provincial legislation, PIPEDA will apply to ODHA effective
January 1, 2004. This personal information policy may be amended if provincial
privacy legislation is enacted in the future, to ensure that this policy
conforms to such legislation.
ODHA collects personal information about its members for purposes of effectively
communicating with, and providing services to, its members. ODHA also collects
personal information about its employees for purposes of personnel management
and administration.
The principals established in the personal information policy of ODHA correspond
to the principles set out in the Canadian Standard Association's Model Code for
the protection of personal information, and conform to the requirements with
PIPEDA.
POLICIES
1. Accountability
ODHA is responsible for all personal
information under its control. The board of directors designate an individual
who will be accountable for compliance with the personal information policy and
procedures of ODHA. The individual appointed to be accountable for ODHA's
compliance will be known as the "Privacy Officer". The Executive Director of
ODHA shall be the Privacy Officer.
ODHA is committed to protecting personal information, and accordingly will
include an appropriate level of protection in contractual arrangements with
third parties (or obtain appropriate assurances from third parties) who receive
personal information from ODHA.
ODHA will ensure that its members, employees and other interested individuals
have the opportunity to review and update their personal information on file
with ODHA. All such persons will be advised that questions and concerns can be
directed to the Privacy Officer.
2. Identifying the Purposes for Collection of Personal Information
ODHA will identify the purposes for
which it collects personal information at or before the time the information is
collected. Written notification of such purposes will be used when it is
feasible to do so, but ODHA may elect to identify such purposes verbally.
Common purposes for the collection of personal information include:
i. Enabling a dental hygienist to make application to become a member of ODHA.
ii. Enabling an existing member to renew his or her membership with ODHA.
iii. Enabling ODHA to communicate effectively with its members and to provide
services to its members - including, but not limited to:
a. information related to benefits, products, services, professional
development and employment opportunities;
b. mailings by third parties;
c. contacts for members of the public seeking dental hygiene services; and
d. lists of members to provincial dental hygiene societies.
iv. Enabling ODHA to recruit new members, or to communicate with former members.
v. Enabling ODHA to draw upon members with the skill set or identified interests
for assistance or input.
vi. Enabling ODHA to effectively provide a liaison between members and
provincial dental hygiene societies.
vii. Enabling ODHA to respond to requests for speakers, community outreach and
access to dental hygiene services.
viii. Enabling ODHA to respond to requests for statistical data about members
related to health human resources, skill sets, and identified interests.
ODHA will identify additional purposes that arise for the collection of personal
information. ODHA will communicate such additional purposes to its members and
interested individuals, if it is appropriate in the circumstances to explain
the purpose for which the personal information is collected.
3. Consent
ODHA will obtain the consent from
individuals for the collection, use or disclosure of their personal
information. ODHA will make every effort to obtain the express consent from an
individual, although there may be circumstances where ODHA will determine that
consent has been implied by an individual. Express consent must be in writing;
implied consent will not be in writing, but the circumstances relating to the
provision of implied consent shall be such that a reasonable person would
conclude that the individual has consented to the collection, use or disclosure
of his or her personal information.
There may be situations where consent is given verbally, either in person or
over the telephone. If ODHA obtains verbal consent from a member or employee, a
note of that consent must be included in the file of the member or employee
providing such verbal consent.
ODHA shall include on the membership application and renewal form an express
statement that the individual signing the form is consenting to the collection,
use and disclosure of his or her personal information. It is recognized that
there will be situations where the applicant, or the member renewing his or her
membership, fails to execute the form as evidence of his or her consent. If the
form is otherwise properly completed, ODHA may imply the consent of the
individual to the collection, use and disclosure of his or her personal
information.
The consent of an individual may be withdrawn at any time. ODHA generally
requires such withdrawal to be in writing, but will recognize verbal
communication of withdrawal of consent when it is appropriate to do so in the
circumstances.
4. Limitations on the Collection of Personal Information
ODHA will only collect personal information that is necessary for the purposes
that have been identified. Personal information will not be collected for
unspecified or improper purposes.
5. Limitation on the Use, Disclosure and Retention of Personal Information
Personal information will not be used or disclosed for purposes other than those
for which it was collected, except with the consent of the individual providing
the personal information. ODHA will establish appropriate criteria for the
retention of personal information.
6. Accuracy
ODHA will make every reasonable effort to ensure that personal information
collected by it will be as accurate, complete and up-to-date as possible for
the purposes for which the information is to be used.
ODHA will, on an ongoing basis, make every effort to ensure the accuracy and
completeness of personal information under its control. Most personal
information will be collected on the membership application and renewal forms,
and the individual providing personal information will have the opportunity to
do so in an accurate and complete manner.
ODHA will develop a procedure to enable members to update personal information
on file. ODHA will review regularly the accuracy and completeness of personal
information on file.
7. Security of Personal Information
ODHA will safeguard and protect personal information under its control by
implementing security measures appropriate to the sensitivity of the
information.
ODHA will ensure that its employees keep all personal information confidential
and comply with the security standards established by ODHA.
ODHA shall require third parties to whom personal information is disclosed to
commit to an appropriate level of security in protection of such information to
satisfy the standards established by ODHA.
On the disposal or destruction of personal information, ODHA will take the
necessary precautions to prevent third parties from accessing such information
and to maintain the confidentiality of such information.
8. Transparency and Openness
ODHA will make available to any interested individual specific information about
ODHA's personal information policies and procedures relating to personal
information that is under the control of ODHA. ODHA will facilitate access to
its personal information policies and procedures, and will make available
information concerning the identity of its Privacy Officer, and the means by
which a person can communicate with the Privacy Officer. ODHA will also ensure
that individuals are aware of the means of gaining access to their personal
information.
9. Individual Access to Personal Information
An individual providing personal information to ODHA will be informed about the
existence, use and disclosure of his or her personal information, and will be
given access to and the right to ensure the accuracy and completeness of such
information. An individual will be able to address the accuracy and
completeness of his or her personal information and have it amended, if
inaccurate or incomplete.
ODHA will respond promptly to any request by an individual for access to his or
her personal information.
ODHA will maintain a complete record of third parties to whom personal
information has been disclosed, and will make such record available to an
individual whose personal information has been so disclosed.
10. Questions and all Concerns Regarding Compliance with this Policy
An individual providing personal information to ODHA may address any question,
concern or complaint regarding ODHA's compliance with this personal information
policy to the Privacy Officer.
ODHA will establish a procedure for processing any complaint about the personal
information policy to ensure that all complaints are dealt with in an
objective, fair and expeditious manner.
11. Visiting the ODHA Web Site
A visitor to the ODHA Web site is not required to reveal any individually
identifiable information, such as name, address, or telephone number. Nor is
such information collected passively by electronic means.
Information is collected when an individual voluntarily completes an online
membership application or renewal form or completes an online survey. This
information is collected, used or disclosed in a manner consistent with this
policy statement. E-mail addresses are also collected during the online
membership application process but applicants may indicate that they do not
wish to receive any unsolicited electronic communication.
Our Web server does not collect visitor information in the form of the visitor's
domain or Internet Protocol (IP) address but does collect information regarding
which pages are accessed. This information is used internally, only in
aggregate form, to better serve visitors by helping us to:
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Manage our site
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Diagnose any technical problems; and
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Improve the content of our Web site.
Following its use, the information collected is not retained but, rather, is
discarded in a secure manner.
Individuals who wish to do business transactions are requested to supply one or
more items of data within the following classes of information:
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Personal Identification Information
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Financial Information (e.g., credit card information, purchase order numbers or
any other payment information for billing purposes); and
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Delivery Information
This information is collected for billing and delivery purposes as well as to
permit ODHA to contact the individual with respect to actions taken by ODHA to
complete the order.
If a purchase is made through the web site using a credit card, the credit card
information is used only for credit card processing purposes.
For the transfer and receipt of certain types of sensitive information such as
financial information, visitors will be re-directed to a secure server and will
not be notified through a pop-up screen on the site.
In browsing the Internet, a technology called "cookies" can be used to provide
specific information from a Web site as well as provide the operator of a Web
site with information about the individual. A "cookie" is an element of data
that a Web site can send to a browser, which may then store it on the system.
An individual can set his or her browser to notify him or her when a cookie is
received, giving the individual the opportunity to decide whether to accept it.
The ODHA Web site does use cookies but only to record session information.
A user of the Web site may access the information held by the ODHA about them in
connection with their visits to this site as well as their account information.
Users may request the correction of any inaccuracies in such information.
Access to and, if required, correction of such information may be arranged by
sending an e-mail message to info@odha.on.ca
, telephoning or writing the ODHA at Suite 201 - 3425 Harvester Road,
Burlington, Ontario, Canada, L7N 3N1, 905.681.8883.
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