Personal Information Protection Policy
Ultima Medical Service Inc; (UMS) is committed to providing our clients with exceptional service and privacy. Ultima Medical Services follows the privacy laws as dictated by the Office of the Information and Privacy Commissioner for B.C. As providing medical assessment involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.
We will inform our clients, of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances, unless required by law to do otherwise.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting personal information. Our privacy commitment includes ensuring the accuracy, confidentiality and security of our clients’ personal information and allowing our clients, to request access to, and correction of, their personal information.
This Personal Information Protection Policy applies to all subcontractors and subsidiaries.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Ultima Medical Services Inc.
Personal Information –means information about an identifiable individual. Personal information does not include contact information.
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Ultima Medical Services complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
With your consent, we may collect the following information about you, depending on the services required:
– Contact information, (e.g. name, address, telephone number)
– Date of Birth
– Primary language
– Claim or file number, Personal Health Number, Social Security number
– Health, education, financial, or employment history
– Citizenship or immigration status
1.2 We will only collect information that is reasonable and necessary, or as authorized by law.
2 – Consent
2.1 When you start receiving services from Ultima, we will obtain a written consent form that outlines the information collected and its use. We gather information through:
– Outside sources (e.g. referral agencies)
– Telephone conversations
– Questionnaires and forms
– Other Medical or Clinical professionals
2.2 Consent may also be implied where a client, customer, member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer, member does not opt-out.
2.3 We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
– When the collection, use or disclosure of personal information is permitted or required by law;
– In an emergency that threatens an individual’s life, health or personal security;
– When the personal information is available from a public source (e.g., a telephone directory);
– When we require legal advice from a lawyer;
– For the purposes of collecting a debt;
– To protect ourselves from fraud;
– To investigate an anticipated breach of an agreement or a contravention of law
3 – Using and Disclosing Personal Information
3.1 We will only use or disclose personal information where necessary to fulfill the purposes identified at the time of collection.
3.2 We will not use or disclose personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell lists or personal information to other parties.
4 – Retaining Personal Information
4.1 If we use personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose. (e.g. Medical records – 14yrs).
5 – Ensuring Accuracy of Personal Information
5.1 We will make every reasonable effort to ensure that personal information is accurate and complete where it may be used to make a decision or disclosed to another organization.
5.2 Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 Any request to correct personal information should be forwarded to the Privacy Office or designated individual.
5.4 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year
6 – Securing Personal Information
6.1 We are committed to ensuring the security of personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any information provided through a referral form or through a web portal will be encrypted using SSL technology. The only remote access allowed to the network is via an L2TP VPN tunnel which only one user utilizes. All file services are password protected.
6.2 The following security measures will be followed to ensure that personal information is appropriately protected:
– the use of locked filing cabinets;
– physically securing offices where personal information is held;
– the use of user IDs, passwords,
– password notification
– encryption when transferring private and confidential information,
– restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures
6.3 We will use appropriate security measures when destroying personal confidential information. Examples may include: shredding documents, deleting electronically stored information, destruction of hardware, etc.)
6.4 We continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Note that confidentiality and security are not assured when information is transmitted through e-mail or other digital or wireless communication.
7 – Providing Access to Personal Information
7.1 Clients have a right to access their personal confidential information, subject to limited exceptions.
Some examples include: solicitor-client privilege, disclosure that would reveal personal information about another individual, health and safety concerns).
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. All requests to access personal confidential information should be forwarded to the Privacy Officer.
7.3 Upon request and if applicable, we will also tell clients how we use their personal information and to whom it has been disclosed.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the individual(s) of the cost and request further direction on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will provide written notification outlining the reasons for refusal.
8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Ultima Medical Services’ compliance with this policy and the Personal Information Protection Act.
8.2 Clients should direct any complaints, concerns or questions regarding Ultima Medical Services’ compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, may also write to the Information and Privacy Commissioner of British Columbia.