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PRIVACY POLICY

Canadian Chiropractic Protective Association
(herein referred to as CCPA)

PRIVACY POLICY

CCPA is committed to continuing to protect your privacy and the confidentiality of your personal information as a member of CCPA. Most companies, in order to comply with the privacy legislation in Canada, have had to develop a Privacy Policy. Any personally identifiable information about a member is considered personal information (“Personal Information”) and must now be protected and treated in accordance with the legislation. The existing by-laws and regulations of CCPA, in effect since 1986, places CCPA in compliance with privacy legislation.

CLAIMS INFORMATION

Personal Information is distinguished from Claims Information, the latter which pertains to member incidents or claims. Claims Information is treated as privileged and does not form part of members’ Personal Information. With the exception of our duly appointed legal counsel or authorized claims representatives, CCPA does not disclose claims information or related litigation information to any other organization.

IDENTIFIED PURPOSES

CCPA only collects, uses and discloses Personal Information for the following purposes:

  • Offering and providing protection for each member for any chiropractic act;
  • Establishing and maintaining communications with you;
  • Verifying your identity and the accuracy of your Personal Information for CCPA records;
  • Analyzing and assessing risks on a prudent basis.
  • Determining and facilitating your member payment of fees and dues;
  • Investigating and providing protection for members;
  • Compiling statistics re chiropractic practices.
  • Confirming your eligibility for membership with the CCA, your Provincial Association and your Provincial Licensing Authority.

In this Privacy Policy, the above list of identified purposes will be referred to as the Identified Purposes.

CONSENT

Your knowledge and consent of CCPA’s collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:

  • Your voluntary provision of Personal Information directly to CCPA on the application form for CCPA membership (including correction of information previously provided to CCPA);
  • Your express consent or acknowledgement contained within a written, verbal or electronic application process for protection;
  • Your consent solicited by CCPA (or our agent) for a specified purpose in relation to providing you member protection;
  • Your receipt of the regulations wherein CCPA agrees to maintain confidentiality of any of your personal information.

CCPA collects information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible, CCPA collects your personal information directly from you. This generally occurs in the initial application, just prior to the commencement of a calendar year, in the form of a renewal notice, and then from time to time thereafter, as circumstances may necessitate or require.

CCPA may obtain information about you from other sources; for example, from:

  • your licensing authority;
  • your provincial association;
  • The Canadian Chiropractic Association;
  • a prior insurer;
  • your chiropractic college or other educational institution;
  • credit bureaus; and,
  • your authorized representative(s).

Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent to CCPA at any time. CCPA will inform you of the consequences of withdrawing your consent.

In some cases, refusing to provide certain Personal Information or withdrawing consent for CCPA to collect, use or disclose your Personal Information may create a situation wherein CCPA cannot provide protection to you.

LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION

CCPA WILL ONLY COLLECT, USE, OR DISCLOSE Personal Information that is necessary for the Identified Purposes or as required by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent, the new purpose will become an Identified Purpose. CCPA will retain Personal Information only as long as necessary for the fulfillment of the Identified Purposes which usually means 2 to 6 years, depending on the province and limitation period of when a member may need protection. Given that some protection matters have no limitation period, some Personal Information may remain on record for an indefinite period of time.

ACCURACY

CCPA will maintain your Personal Information as corrected and updated by you each year when you renew your membership as accurately, complete, and up-to-date as is necessary for the Identified Purposes.

SAFEGUARDS

CCPA will continue to protect your Personal Information by security safeguards appropriate to the sensitivity of the information. Safeguards will vary depending on the sensitivity, format, location, and storage of the Personal Information. Safeguards currently employed include:

  • premises security;
  • restricted access to records;
  • controlled technology access, password security and firewalls.
ACCOUNTABILITY, OPENNESS AND MEMBER ACCESS

CCPA is responsible for all Personal Information under its control and has designated a Privacy Officer, namely, Dr. Dean Wright, Chief Executive Officer of CCPA, for continuing compliance with this Privacy Policy.

You may request access to any Personal Information we hold about you. The right is not absolute, and if your request is denied, you will be furnished with a written explanation and/or reasons.

A copy of this Privacy Policy (and any future updates) can be obtained from our office by calling 416-781-5656 or Toll Free 1-800-668-2076. If you have any questions about this Privacy Policy or your Personal Information, please call us. When you call us, we may confirm your identity by asking you to confirm certain Personal Information and you may be directed to send us certain requests in writing.

ELECTRONIC COMMUNICATION

Website access to general information may be available. We reserve the right to gather traffic related information to optimize our web service. The use of such information will not include use of Personal Information of a member.

CHALLENGING COMPLIANCE

If you are not satisfied with CCPA’s response to a privacy related inquiry or complaint, you may contact the Office of the Privacy Commissioner of Canada during business hours at 1-800-282-1376 or at www.priv.gc.ca.