Privacy of personal information is an important principle to the Ontario Chiropractic Association. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the appropriate provision of the products and services we provide to our members in our role as a professional association. We also try to be open and transparent as to how we handle personal information. The following describes our privacy policies.
- What is personal information?
- Who we are
- We collect personal information: primary purposes
- Invoicing & payment
- Patient Management Program — Technical Support
- Transfer of backup information
- Uploading data
- Downloading program updates
- External regulation
- You can look at your information
- Internet privacy
- Do you have any questions or concerns?
Personal information is information about an identifiable individual, including that which relates to his/her personal characteristics (i.e. gender, age, income, home address or phone number, ethnic background, family status), his/her health (i.e. health history, health conditions, health services received by them), or his/her activities or views (i.e. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is not to be confused with business information (i.e. an individual’s business address and telephone number), which is not protected by PIPEDA, the Personal Information Protection and Electronic Documents Act, an act of the federal government.
In existence since 1929, the Ontario Chiropractic Association is a voluntary, not-for-profit professional association, representing chiropractors in Ontario.
Our mission is to serve our members and the public by advancing the understanding and use of chiropractic care.
In order to achieve this broad mission, we utilize the services of the association staff, as well as a number of volunteers (who are OCA members), consultants and organizations that may, in the course of their duties, have limited access to the personal information we hold. We restrict their access to personal information as much as is reasonably possible. We also have their assurance that they comply with appropriate privacy principles.
Like all professional associations, we collect, use and sometimes disclose personal information in order to serve our members. At no time do we rent, sell, barter, exchange or distribute our membership list to any third party for commercial purposes.
For our members, the primary purpose we collect and maintain personal information is to ensure our members qualify for membership within the provincial and national association and that, once established as members in good standing, we can provide general membership services and exclusive membership benefits and that we can communicate appropriately with them. Members indicate their preferred method of receiving regular and special communications from the OCA, either via email, fax or regular mail. Examples of personal information we collect for this purpose include:
- email address (if available)
- graduation year and university
- registration number (assigned by CCO)
- liability insurance provider
- information on techniques, modalities, diagnostic methods and languages spoken (other than English), if provided to us by our members.
Though hosted on the OCA website, member micro-sites contain member-provided and -maintained information. It is the responsibility of the member to provide accurate and up-to-date information. The OCA cannot guarantee the accuracy or currency of this information.
The OCA invoices members for annual dues, including annual dues collected on behalf of the Canadian Chiropractic Association, and annual fees related to the use of OCA software — the Patient Management Program and ChiroWrite. In addition, the OCA collects registration fees for conferences and events and for sales of classified advertisements, products and materials.
Personal information collected (that is not already collected as part of the primary purpose):
- Payment details: cash / personal or business cheque or credit card / debit card account number and authorization. All credit card information is collected and sent to our payment partner for use in payment approval and processing only. The OCA does not retain your credit card information. If you elect to provide your bank account information to us for the purposes of payments by to pre-authorized EFT withdrawal, we must retain this information on file.
- Names of additional DCs and non-DC users of the Patient Management Program.
- Names, event choices and dietary preferences of guests registering to attend events with OCA members.
Patient Management Program users may choose to submit an annual statistics report, generated within the program, that is used by academic researchers in Ontario to identify trends. Researchers adhere to strict privacy and confidentiality principles.
The generic information that is collected and analyzed in the annual statistics report includes:
- General geographic data
- Types and total annual number of primary or secondary treatments provided
- Total number of patients treated
- Number of associates (DCs) and non-DCs in each practice
- Number of staff employed in each clinic
A key service provided to OCA’s PMP users is extensive and on-going technical support / troubleshooting. OCA’s PMP Support Representatives collect and use general and technical information provided by users calling for Technical Support. This includes:
- Names and types of DC and non-DC users
- PMP user number
- Names of office staff
- Computer system specs
- Network drive information, for mapping
In addition, each technical support call is logged. Information collected includes:
- Name of caller and best time to return calls
- Alternate phone number
- Type of problem with details
- OCA response / fix
This information enables the OCA to understand the type and frequency of problems encountered by users. This feedback, which has been maintained since the inception of the Support Line, is then used to improve the program, training sessions, user manual and user communications.
In the event of a catastrophic system failure or severe usage problem, PMP users may be asked to forward to the OCA office a copy of their most recent backup files (which contain private patient information). A standard feature of the Patient Management Program is that patient information is automatically encrypted as part of the daily backup process.
Backup files may be used to attempt to recover a failed system. Once recovered and stabilized (within 30 days) private patient files transferred to the OCA office are destroyed (hard copies shredded and electronic versions permanently deleted from discs or hard drive).
In the event a PMP user must upload his/her patient data to the OCA for repair, the upload is transmitted via encrypted link to the OCA’s FTP site. Once the data has been repaired, the user may download the data via that encrypted link. The PMP Utilities program automatically decrypts the data and replaces it in the Patient Management Program.
In order to understand and accommodate the technical capabilities of OCA members using the Patient Management Program, especially for new development / program enhancements, the OCA collects basic computer system information on PMP users, during downloading, and after user authentication, including:
- Response type
- User ID
- Version of Windows operating system
- Amount of RAM
- Originating internet address
- Is wrapping turned on?
For each Doctor on the system:
- Doctor Number
- Doctor Name
- Number of columns across the appointment book
- Is the doctor a DC?
- Is this a pay clinic?
Various government agencies (Canada Revenue Agency, Office of the Privacy Commissioner of Canada, Human Rights Commission, Ontario Ministry of Finance, Ontario Ministry of Labour, etc.) have the authority to review our files and interview our staff as part of their mandates. External regulators have their own strict privacy obligations.
With only a few exceptions, OCA members and former members have the right to see what personal information we hold. 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 (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.
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 explain the reasons.
If you believe there is a mistake in the personal information we maintain in our files, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation to support your request. Where we agree that we have made a mistake, we will make the correction and notify anyone to whom we have sent this information. If we do not agree that we have made a mistake, we will still agree to include in our records a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
- Cookies: Cookies are small files or parts of files stored on a World Wide Web user’s computer, created and subsequently read by a website server, and containing personal information, such as a user identification code, customized preferences, or a record of pages visited. The OCA does not use any personal information from members’ or non-members’ cookies during visits to the OCA website. We do track general usage patterns, number of hits per page, etc. in order to improve website content and layout.
- Links: Some of our websites, including member micro-sites, link to other sites that were not created and are not maintained by the OCA. When you link to an outside website, you are leaving the OCA site and our information management policies no longer apply.
- Please note that the OCA does not warrant that functions available on www.chiropractic.on.ca will be uninterrupted or error free, that defects will be corrected or that www.chiropractic.on.ca or the server that makes it available are free of viruses or bugs. You acknowledge that it is your responsibility to implement sufficient procedures and virus checks (including anti-virus and other security checks) to satisfy your particular requirements for the accuracy of data input and output.
- Content, including the information, names, images, pictures, logos and icons regarding or relating to the OCA, its products and services (or to third-party products and services is provided “as is” and on an “as available” basis. To the extent permitted by law, the OCA excludes all representations and warranties (whether express or implied by law), including implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy. The OCA does not guarantee the timeliness, completeness or performance of the website or any of the content. While we try to ensure that all content provided by the OCA is correct at the time of publication, no responsibility is accepted by or on behalf of the OCA for any errors, omissions or inaccurate content on the website.
The OCA’s Privacy Officer will address any questions or concerns you have:
Contact 416-860-0070 or 1-877-327-2273.
If you wish to make a formal complaint about our privacy practices, you may do so in writing to our Privacy Officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a response in writing.
For general enquiries and in the absence of any applicable provincial legislation, the Office of the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as an Ombudsman for privacy disputes. The Office of the Privacy Commissioner can be contacted at:
Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa ON K1A 1H3
613-995-8210 / 1-800-282-1376 / www.privcom.gc.ca