Privacy

Privacy of personal information is an important principle to VSTEP. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.

WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).

Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

WHO WE ARE
Our organization, VSTEP, is a not-for-profit corporation operated with the support of the College of Veterinarians of Ontario, the Ontario Veterinary Medical Association and the Ontario Veterinary College of the University of Guelph. VSTEP operates using funding received from the Ontario Ministry of Citizenship and Immigration and the tuition fees of program participants. VSTEP uses consultants and agencies that may, in the course of their duties, have access to personal information we hold. These include The Purple Grove Group Ltd which operates and manages the program, BDO Dunwoody Chartered Accountants which audits the financial statements of the program and an assortment of veterinary practitioners and veterinary academics who provide training to the participants of the program. These may also include information technology consultants hired from time to time by VSTEP. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles or, in the case of the veterinary practitioners that they are bound to protect the confidentiality of your information in accordance with their responsibilities described in the Veterinarians Act and Regulations.

PRIMARY PURPOSES FOR THE COLLECTION OF PERSONAL INFORMATION:
We collect, use and disclose personal information in order to communicate with those enrolled in the program, those providing services to the program (instructors) and to the College of Veterinarians of Ontario which may wish to confirm the status of individuals enrolled in the  program for licensure purposes. For applicants to the program, examples of the type of personal information we might collect include name, mailing address, telephone number, e-mail address, education, social insurance number, ethnicity and the date of passing some or all of the licensing examinations.

When interested parties and other member of the public contact VSTEP in order to receive information regarding the program, we will collect personal information without their consent so that we can communicate with them by e-mail, fax, regular mail or telephone.

For contract staff (e.g., field placement practitioners and academic educators) our primary purpose for collecting personal information includes the need to communicate, correspond and make contact with them. Examples of the type of personal information we might collect for these purposes include name, mailing address, telephone number, e-mail address, and the names and addresses of other practitioners serving as references, whose information we collect without their express consent.

RELATED AND SECONDARY PURPOSES FOR THE COLLECTION OF PERSONAL INFORMATION:
Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

To invoice for goods or services and to collect unpaid accounts.
To measure satisfaction rates of participants following the conclusion of the program. We may collect information by way of a survey in an anonymous format. In this way the information collected cannot be connected to any particular person and no consent will be obtained.

To provide notification of special events and opportunities.
We may notify individuals involved in VSTEP of special events or gatherings related to the program. No additional personal information will be collected other than what is collected for primary purposes. An opportunity will be provided to opt out of such notification.

To communicate with government ministries.
Representatives of government ministries may want to meet individuals involved in VSTEP. No additional personal information will be required for this purpose, though some may voluntarily disclose information at the point of contact.

PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:

Paper information is either under supervision or secured in a locked or restricted area. Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.

Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies. Electronic information is transmitted through a digital subscriber line.

Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy. External consultants and agencies with access to personal information must enter into privacy agreements with us.

Our web site contains links to other web sites. We have not taken any steps to confirm the privacy policies of organizations sponsoring these web sites nor do we assume any responsibility for the privacy practices or the content of such other sites.

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 provided. However, we do not want to keep personal information too long in order to protect your privacy.

We keep our participant files for about five years. Our contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not participants, newsletters, seminars and marketing activities for about 6 months after the newsletter, seminar or marketing activity is over.

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 the hard drive is physically destroyed.

YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you. Often 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, etc.). 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.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access. If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to 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 CONCERN?
Our Information Officer, Dr. Alec Martin, can be reached at

VSTEP
100 Stone Road West – Suite 110
Guelph, Ontario. N1G 5L3
519-767-6564

to address any questions or concerns you might have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He 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.

For more general inquiries, the Information and 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
www.privcom.gc.ca