PRIVACY
Diabetes Care Community adheres to the privacy regulations as laid out in the Federal Privacy Act and the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and any other Provincial Statutes enacted as of January 1, 2004. (Revised May 2019*)
We collect and host Diabetes Care Community member data. This data remains the exclusive property of Diabetes Care Community. We do not rent, trade, or otherwise disclose personal data in any format (electronic or other) to any of our clients nor to any third party — individual, company or organization. Diabetes Care Community ensures that each of the members records contained within our data set was consented to be collected for the purpose(s) intended as detailed in the section of the Federal Act and in PIPEDA covering the collection, use and disclosure of personal information.
Our privacy policy has been written in an easy to read and understandable format, and consists of the following sections:
Your Privacy
Your privacy is important to us! We are committed to respecting your privacy through the protection of your Personal Information. As the collection of information is facilitated through technological advances such as the Internet, we have re-established our commitment to protecting your Personal Information.
The following outlines our pledge to you:
- Purpose and Consent: Before storing your Personal Information, we determine the purpose and ensure that effective consent has been gathered.
- Limiting Collection: Collection of Personal Information is limited to what is reasonable under the circumstances and if requested to use or disclose your information, we will only do so for the purpose for which it was collected.
- Security: Your Personal Information is kept confidential and secure, using industry standard practices for data safeguards.
- Access: You have the right to access your own Personal Information, and to correct any inaccuracies.
10 Principles
We have always been, and will continue to be, committed to maintaining the accuracy, confidentiality and security of your Personal Information. As part of this commitment, we have adopted the 10 Principles established by the Canadian Standards Association’s Model Code for the protection of Personal Information. These principles form part of the Personal Information Protection and Electronic Documents Act (PIPEDA or “the Act”), which establishes rules governing the collection, use and disclosure of Personal Information by the private sector.
Our 10 Privacy Principles:
- Accountability: Every business is responsible for the Personal Information under its control and is required to designate a “Privacy Officer” who is accountable for compliance with the Privacy Legislations.
- Our Privacy Officer is:
Ian Gardner, CEO
Diabetes Care Community Inc.
10 Dominion St - Bracebridge, Ontario P1L 2A5
- Our Privacy Officer is:
- Identifying Purposes: We will provide a clear Disclosure Statement, identifying the purposes for which Personal Information is collected, either before or at the time of collection.
- Consent: We will obtain compliant consent from you and only collect, use and disclose your Personal
- Limiting Collection: We will limit the collection of your Personal Information to only those details that are necessary for the purposes identified.
- Limiting Use, Disclosure and Retention: Your Personal Information will only be used or disclosed, by us, for the purpose for which it was collected, unless you have otherwise consented, or when it is required or permitted by law. We will only retain your Personal Information for the period of time required to fulfill the purposes for which it was collected.
- Accuracy: We strive to keep Personal Information as accurate, complete and up-to-date as possible.
- Safeguards: We will protect the Personal Information with security safeguards appropriate to the sensitivity of the information. We use industry standard data safeguards (for example, firewalls, restrictive access) for all Personal Information entrusted to our management.
- Openness: Information about our policies and practices relating to the management of your Personal Information will be made readily available to you through our Privacy Officer, following written request.
- Access: With written request, our Privacy Officer will contact you directly and address any questions you may have about the existence, use and disclosure of your Personal Information, managed by us stored within our databases. You have the right to challenge the accuracy and completeness of your information, and to amend or delete it as necessary.
- Challenging Compliance: Should you have concerns about your Personal Information managed by us, you should present your concerns to the Client Privacy Officer. You should expect to have your concerns dealt with in an expedient manner including access to your Personal Information, which you can have amended if required, or have deleted.
What Is Personal Information?
Personal Information is broadly defined as information about an identifiable individual, but does not include the name, title, business address, or telephone number of an employee of an organization. Managed data with personal identifiers removed, so that it is impossible to determine the identity of the person to whom the information relates, is not considered Personal Information.
Personal Information Managed by us
We manage Personal Information. The type of information we usually manage and maintain may include (but may not be limited to) your:
- Name
- Mailing Address
- email Address
- Telephone Number
- Date of Birth
It is always your choice whether or not you consent to us managing your Personal Information. However, a decision to withhold certain, or all, Personal Information may restrict or prevent us from providing the services to you.
How Your Information May Be Used
Our Relationship with You Is Important to Us
We pride ourselves on our ability to create and maintain leading communication systems and services that enable us and our clients to have ongoing communication with you on value added services, and to establish long-lasting relationships with you that will grow and change to meet your needs.
Your Personal Information may be used to:
- Identify you (such as when you come back to a Web site)
- Establish and maintain a relationship with you, and to provide you with ongoing service
- Protect you, our Clients, and us, against error and fraud
- Comply with legal requirements
Your Personal Information may also be used to create statistics about our business. The statistics that we provide do not contain any information that would identify you personally.
You Can Choose Not to Receive Direct Marketing
Using our services, we and our Clients may inform you about products or services by mail, telephone or other means. If you do not wish to receive direct marketing, simply check the box that indicates you do not wish to be contacted in a particular manner.
Your Personal Information will not be used or disclosed without your consent, except where required or permitted by law.
We will not sell or share your Personal Information to any organization, for any purpose, except on prior written direction
Giving Consent
The cornerstone to protecting your privacy is consent. We only collect, use, and disclose your Personal Information on direct instructions by you or our clients, except where otherwise permitted by law.
Our Clients are legally obligated, through a contractual agreement with us, to ensure that consent has been gathered for the Personal Information managed by us on their behalf, in an effective and compliant manner.
You may choose not to provide your Personal Information. However, if you make this choice we and our Clients may not be able to provide you with the product, service or information that you requested or that could be offered to you.
Withdrawing Consent
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw your consent, simply contact and advise us of what Personal Information you no longer wish stored.
Security and Disclosure of Your Personal Information
What Safeguards Do We Have in Place?
We know you are concerned about the security of the information provided to us. To address this concern, we have developed processes and procedures to keep your Personal Information safe and secure.
We have appropriate safeguards in place, which include:
- Physical: Locked filing cabinets
- Technological: Password-protected computers/files, firewalls and encryption of sensitive data
- Organizational: All of our associates are trained in the importance of safeguarding your Personal Information from loss and unauthorized access
Disclosure of Your Personal Information:
We will only use and disclose your Personal Information to fulfill the purposes for which it was collected, or as may be required by law. Also, we will keep your information only for as long as it is needed to fulfill the purposes for which it was collected. We also have contractual agreements (Transfer for Processing) in place with our third parties who may come into contact with your Personal Information as a result of performing the services on behalf of clients and other partners. These contractual agreements prohibit our third parties from using, processing, storing, retaining or disclosing that information other than for the purpose for which they have been retained with written consent.
Access to and Changing Your Personal Information
Accessing Your Personal Information
You may access and verify your Personal Information and find out to which we have disclosed it by contacting and requesting the information from us. It is likely that we will require specific information from you to verify your identity. Once we have positively identified you, we can provide you with the Personal Information we hold.
There may be instances when we will not be able to provide you with the Personal Information that you request. Examples are if the Personal Information:
- Contains references to other persons
- Has already been destroyed due to legal requirements or because we no longer needed it for our purposes
- Is subject to solicitor-client or litigation privilege
- Cannot be disclosed for legal reasons
Changing your Personal Information
We are committed to striving to maintain the accuracy of your Personal Information for as long as it is being used for the purposes identified. To help us and our Clients keep your Personal Information up-to-date, we encourage you to notify us of inaccuracies or corrections as often as you wish. Notification of changes such as your address or telephone number will help us provide you with the best possible service.
If you identify any incorrect or outdated information requiring amendment, please contact our Privacy Officer directly. We may ask you to put your request for a correction in writing. Once we receive written consent, including the requested amendments, we will make the proper changes and, upon your request, provide you with a copy of the corrected information.
Contact Us
If you have questions, concerns, or complaints about the privacy of your Personal Information managed by us, you may contact us at the address listed below. We will contact you to assist you in resolving the situation. If a complaint is found to be justified, appropriate measures will be taken including, if necessary, amending our practices and procedures.
Please write to:
Attention, CEO
Diabetes Care Community Inc.
16 Dominion St.
Bracebridge, Ontario
P1L 2A5
*For a more complete understanding of PIPEDA, you may refer to the Federal Government PIPEDA in brief here https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/pipeda_brief/)
