Privacy Policy
The following page outlines our privacy policies which apply to staff and doctors of Vibrant Eyes Optometry and the use of this website. We value your privacy and are committed to providing our best care whilst being responsible for and protecting it with the utmost delicacy and transparancy. We aim to collect, use and disclose personal information responsibly and only to the extent necessary for the optometric services that we provide.
Effective Date and Changes
While in effect, we will comply with the terms of this privacy policy. We reserve the right to modify this policy at any time in order to comply with potential changes in privacy legislation. Any changes would then apply to all personal information moving forward. This policy will be in effect from April 17, 2020 until the date an amended policy is published. If we change the privacy policy, we will post the amendments in our office, have copies available and publish it on our website here.
What is Personal Information?
Personal information is information about an identifiable individual. This includes information that relates to any personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status), health (e.g. health history, health conditions, health services received by them) or activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is not business information (e.g. your business address and telephone number), which is not protected by privacy legislation.
Who We Are
Vibrant Eyes Optometry includes any optometrist or health care professional, all employees, staff and student trainees authorized to collect, use or disclose personal information. We use a number of consultants and agencies that may, in the course of their work for us, have limited access to personal information we hold. These include, but are not limited to; pharmacists; specialists to whom we refer (e.g. ophthalmologists, general practitioners, opticians), third party insurers, contact lens companies, lens manufacturing companies, frame manufacturers, office security and maintenance, credit card companies, collection agencies, website managers and lawyers. 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.
Collecting Personal Information: Primary Purposes About Patients
Vibrant Eyes Optometry collects, uses and discloses personal information in order to serve our patients. For our patients, the primary purpose for collecting personal information is to provide optometric services. For example, we collect information about one's health history, including family history, physical condition and function in social situations to help us assess what one's eye care needs are to advise of treatment options and then to provide the eye care chosen.
We may communicate this information to other regulated health practitioners, technicians, or individuals authorized to work in our practice as part of a patient’s continuing care. In order to better identify changes that are occurring over time, this communication is used to obtain a baseline of health and social information during a patient's ongoing care with us. It would be rare for us to collect information without the patient’s implied consent, but the exception where this would happen is in an emergency (e.g., the patient cannot communicate) or where we believe the patient would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our patient and we have no reason to believe the message is not genuine).
About Our Staff, Students, Volunteers
For people who are contracted to do work for us (e.g. temporary workers), our primary purpose for collecting personal information is to ensure we can contact you in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending pay cheques, year-end tax receipts).
Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency or to investigate a possible breach of law (e.g. if a theft were to occur in the office). If contract staff, volunteers or students, request a letter of reference or an evaluation, we will collect information and their work-related performance and provide a report as authorized by them.
Collecting Personal Information: Related and Secondary Purposes
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:
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To invoice patients for optometric services, products or treatments that were not paid for at the time the service was provided, to process credit card payments or to collect unpaid accounts either ourselves or through a collection agency or lawyer. When the cost of some optometric services, products or treatments provided by the practice to patients is paid for by third parties (e.g. OHIP, private insurance and various social assistance programs). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate patient entitlement to this funding.
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To advise patients, by telephone, mail or email that your vision and eye care needs or treatment should be reviewed (e.g. to schedule an appointment, to ensure that your eye glasses and/or contact lenses are still functioning properly and appropriate for your current needs and to consider modifications or replacement).
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To advise patients, prospective patients and others of special events or opportunities (e.g. a seminar, development of a new service, arrival of a new product) that we have available.
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Vibrant Eyes Optometry reviews patient and other files for the purpose of administration, business planning and ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g. auditors, lawyers, practice consultants, quality assurance programs) may, on our behalf, do audits and continuing quality improvement reviews of our practice, including reviewing patient files and interviewing our staff. In rare cases, our practice or our consultants may make inquiries to verify that the information we have about our patients is accurate.
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Optometrists are regulated by the College of Optometrists of Ontario, which may inspect our records and interview our staff as a part of their regulatory activities to protect public interest. In addition, as professionals, we report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Furthermore, our practice will report information suggesting serious illegal behaviour to the authorities. Sometimes these reports include personal information about our patients, or other individuals, to support the concern (e.g. improper services). Also, like all organizations, various government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, et cetera) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g. lawyers, accountants) who will investigate the matter and report back to us. External regulators have their own strict privacy obligations.
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Patients or other individuals we deal with may have questions about our products or services after they have been received. We also provide ongoing optometric services for many of our patients over a period of months or years for which our previous records are helpful. We retain our patient information for a minimum of ten (10) years after the last contact to enable us to respond to those questions and provide these services. For those under eighteen (18) years of age, we will retain information for a minimum of ten (10) years after their 18th birthday after last contact as per the College of Optometrists of Ontario mandate for patient record retainment.
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If Vibrant Eyes Optometry or its assets were to be sold, the prospective purchaser would want to conduct a “due diligence” review of the practice records to ensure that it is a viable business that has been honestly portrayed to the prospective purchaser. This due diligence may involve some review that may include releasing personal information. The prospective purchaser would not be allowed to remove or record personal information and, before being provided a review of the clinical files and records, the prospective purchaser must provide a written promise to keep all personal information confidential. Only a reputable purchaser who has already agreed to purchase the practice or its assets would be provided, at closing, complete access to personal information. The purchaser would be required to maintain the same principles of privacy as established under the present privacy legislation.
You can choose not to be part of some of these related or secondary purposes (e.g. by declining to receive notice of special events or opportunities, or by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g. external regulation).
Protecting Personal Information
The following are things done to protect personal information:
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Employees, including temporary staff, are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
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Paper information is either under supervision or secured in a locked or restricted area.
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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 use digital signals, which are more difficult to intercept.
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Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies or collected by the patient who asks for the information.
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Electronic information is transmitted either through a direct line or is anonymized or encrypted.
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Verbal personal information is collected and used in such a manner that other persons would not hear the exchange of the information.
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External consultants and agencies with access to personal information must enter into privacy agreements with us.
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 we provided to you and for our own accountability to external regulatory bodies. Patient files and records are kept for a minimum of ten (10) years. For those under the age of eighteen (18), we will retain information for a minimum of ten (10) years after their 18th birthday after last contact as per the College of Optometrists of Ontario mandate for patient record retainment. We keep any personal information relating to our general correspondence (i.e. with people who are not patients), newsletters, seminars and marketing activities for about 12 months after the newsletter ceases publication or a seminar or marketing activity are over.
You can ask us, in writing, to restrict our uses and disclosures of personal information at any time. We will also discontinue to use or to disclose your personal information after a written revocation of your implied or informed consent is received, unless we have already acted in reliance upon this consent. 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 information on the hard drive is formatted and destroyed. Alternatively, we may send some or the entire patient file to our patient.
How to Look At Your Information
Outside of rare circumstances, you have the right to see what personal information we hold about you which can be requested for at any time. 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). A release of information form will need to be filled out and your identify confirmed before providing access. We reserve the right to potentially charge a fee for such requests which will be explained in advance.
If you believe there is an error in the information we have about you, 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 assist in our information correction. Where a mistake has been made, we will make the correction and notify anyone to whom we sent this information. If we do not agree that a mistake has been made, we will 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. Any further inquiries can be made to the provincial privacy commissioner.
Do You Have A Question?
If you have a question, please contact us at info@vibranteyes.ca with RE: Privacy Officer in the subject line. If you wish to make a formal complaint about our privacy practices or the application of those practices, you may make it in writing to our Privacy Officer. He/She 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.
If our office is unsuccessful in resolving a general complaint about your personal health information, you may, within one year of the occurrence, submit a written complaint to the Information and Privacy Commissioner of Ontario.
If you are either denied access to, or refused a correction to your personal health information, you have six months to file a written complaint with the Information and Privacy Commissioner of Ontario.
Contact information for the Information and Privacy Commissioner of Ontario is below.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff, we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to file a complaint with our regulatory body.
Contact information:
College of Optometrists of Ontario
65 Saint Clair Avenue East, Suite 900
Toronto ON M4T 2Y3
416-962-4071
toll-free: 1-888-825-2554
fax: 416-962-4073
This policy is made under the Personal Health Information Protection Act, 2004, and the Personal Information Protection and Electronic Documents Act. These are complex acts and provide some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
Information and Privacy Commissioner of Ontario
The Information and Privacy Commissioner of Ontario oversees the administration of provincial privacy legislation for health information custodians, including optometrists. The Commissioner reviews complaints and enforces the Personal Health Information Protection Act, 2004.
Contact information:
Office of the Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto ON M4W 1A8
416-326-3333
toll-free: 1-800-387-0073
fax: 416-325-9195
For more general inquiries, you may wish to contact the Information and Privacy Commissioner of Canada, which oversees the administration of privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes.
Contact information:
Information and Privacy Commissioner of Canada
30 Victoria Street
Gatineau QC K1A 1H3
819-994-5444
toll-free: 1-800-282-1376
Log Files and Cookies
This website utilizes industry standard analytics packages which gathers limited information on visitors to our website automatically, and stores this anonymous information in server log files. This information may include IP addresses, browser type, basic IP information, referring pages, operating system used and date/time stamps. This information does not identify individual users; it is used only for site administration, as well as for analysis of website usage and trends. Additionally, cookies may be used to provide easier and faster access to website features such as logins and/or repeat visits. Cookies are very small text files that are stored on personal computers for reference purposes. We do not link the information we store in cookies to any personally identifiable information you have submitted while on our site. We use both session ID cookies and persistent cookies. A session cookie expires when your browser is closed, and a persistent cookie may stay on your hard drive for an extended period. Session cookies make it easier for you to navigate our site; persistent cookies can perform such activities as storing your password for forums or blogs so you do not have to sign in every time you visit those areas, and/or may be used to enable us to track and target the interests of our users so as to enhance the overall experience of using our site. We have no access to or administration abilities over any cookies that are used by any advertisers on our site.
Links to Other Websites
This website may contain links to other sites that are not controlled in any way by us. Please be aware of this when you click on any such links; we are not responsible for the privacy practices and/or policies of any website other than our own. Consequently, we strongly suggest that you review the privacy policy of every website you visit, whether or not they are linked to by our own site.
Access to Personally Identifiable Information
If your personally identifiable information changes, or if you no longer wish us to possess your information, you may request correction, updating, or deletion of your information by contacting us on the Contact page.
Security
We follow accepted industry standards to protect any personal information you have provided to us. However, please be aware that no method of electronic storage can ever be 100% secure. Therefore, as is the case with any organization – we are not in a position to guarantee the absolute security of your information. You may submit any questions you may have about our security procedures by contacting us.
Legal Disclaimer
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process served on our website.
Contact Details
If you have any questions or concerns regarding this privacy policy, please contact us using the information located on the Contact page of this website.