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Vision Loss Rehabilitation Canada Privacy Policy

Personal information is information that can be used, on its own or in combination with other data, to identify or contact a specific person. It includes facts, assessments and opinions. Personal information does not include anonymous or aggregate information that cannot be traced back to you personally.

We collect personal information about you over the course of your involvement with Vision Loss Rehabilitation Canada. What information we collect, and how we use and disclose it, depends on the specific circumstance, the nature of your involvement with our organization, and the consent you provide.

The personal information we collect from clients includes :

• Your name, address and contact information;
• Demographic information about you, such as your age and gender;
• Contact information for a representative you have authorized to make appointments and/or communicate with us on your behalf , or a Power of Attorney if you have one ;
• Personal health information, including information about diagnosed eye conditions, your sight loss , and care provided by other providers;
• Records of your participation in services ;
• Your language, communication and reading format preferences;
• Information about your personal interests, goals or topics on which you would like to receive information, support or services ;
• Credit card, banking information and transaction records, where you have purchased a device directly from Vision Loss Rehabilitation Canada;
• Third-party payer and/or insurance information.

We collect this information when you:

• Are referred to Vision Loss Rehabilitation Canada by a third party, such as a physician healthcare professional or community agency;
• Register for and/or participate in Vision Loss Rehabilitation Canada therapy, services, programs or activities;
• Complete program evaluation, satisfaction and other types of surveys;
• Purchase products and devices, and/or apply for related government subsidies administered by Vision Loss Rehabilitation Canada;
• Contact us with an enquiry, comment or suggestion, and;
• Subscribe to a mailing list or newsletter.

We use your personal information in order to:

• Facilitate your participation in requested therapy, programs, services, activities or events,;
• Refer you to CNIB , CNIB Deafblind Community Services or other community organizations , with your consent;
• Contact you with information about programs , offers and research opportunities from Vision Loss Rehabilitation Canada and/or our partners that may be relevant to you , with your consent ;
• Plan, administer and manage our internal operations;
• Conduct research and compile statistics ;
• Teach, train and qualify staff and volunteers;
• Get payment for the rehabilitation services you receive;
• Investigate activity that may violate the terms of acceptable use for particular services;
• Comply with legal and regulatory requirements, and fulfil other purposes permitted or required by law.

From time to time, we may wish to use your personal information for new or additional purposes, in which case we will request your consent as required.

Your personal information will not be disclosed without your consent for purposes other than those for which it was collected, or as permitted by law. We may disclose your personal information to third parties in the following limited circumstances:

• To other external service providers or agencies to support the planning and delivery of coordinated health and social services. Disclosure of information may be directly to an external provider, or through a shared health record .
• To funding bodies such as government ministries or health authorities, for the purposes of verifying your eligibility for funded programs, and providing reports on program participation and outcomes.
• To service providers, including vendors, consultants and service delivery partners or agencies contracted to perform certain services on behalf of Vision Loss Rehabilitation Canada . These organizations are given only the information necessary to perform those services , and sign an agreement committing to ensure that personal information is securely transferred , stored , and used only for the contracted purposes.
• Some service providers with whom we share personal information may perform activities in the United States or another country, in which case personal information is subject to laws in the United States or that other country. For example, personal information may be shared in response to valid demands from government authorities, courts and law enforcement officials in the country where the data resides.
• To a government institution that has asserted its lawful authority to obtain the information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity.
• To comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the disclosure of information, or with court rules regarding the disclosure of records and information.
• As otherwise required by law.

The length of time we retain personal information varies depending on the situation and the type of information. Our record retention policy outlines the following standard retention timelines :

• Adult clients: Records are kept for a minimum of 7 years from the date of the last entry in the client's record, or as long as required
• Clients who are minors : Records are kept for 10 years f rom the date on which the client reached or would have reached their 18th birthday.

Unless there are exceptional circumstances such as pending legal matters, when these timelines have elapsed personal information is securely destroyed, deleted or de-identified.

We make reasonable efforts to ensure your personal information is accurate, complete and up to date so that we can fulfil the purposes outlined in this policy. We rely on you to provide us with accurate information and to notify us when your information needs to be updated. 

We also take reasonable measures to ensure that our systems keep personal information safe from loss or theft, unauthorized access, use, copying, disclosure or modification.  Safeguards include but are not limited to:

• A designated systems security officer accountable for information security controls and ongoing oversight to strengthen information security;
• Hard disk encryption on all issued laptop computers;
• Firewalls, intrusion-detection, anti-virus, strong passwords, inactivity-based screen lock, mandatory portable device access control and other software solutions for technical security;
• Annual privacy training and policy sign-off by all employees, and;
• An ongoing operational emphasis on the importance of safeguarding personal health information.

As soon as we become aware of any possible infringement of our privacy policy, we take immediate action to contain, investigate and remediate the situation and notify affected parties, as required by law and our breach management protocol.

This includes mandatory reporting of privacy breaches to information and privacy commissioners in situations and jurisdictions where this is required.

You have the right to access and correct inaccuracies in the personal information we have about you in our records. 

To do so, contact Vision Loss Rehabilitation Canada with a request in writing . To protect your privacy, we will take reasonable steps to verify your identity upon receiving your request , and ask you to complete a standardized request form. 

We will respond to all requests to access or correct personal information within 30 days, either providing access to the requested information, providing written notice of the need for an extension, or providing written notice of why the request cannot be fulfilled . 

If you are requesting a physical or digital copy of your personal information , you will be informed of any applicable fees ahead of time. Fees are capped at a reasonable rate.

Websites

Generally, you can visit our website without providing us any personal information. However, our site does use several types of technology to log different types of non-personally identifiable information, for different reasons.

These include:

• Logs of information such as:
• the type of device you have used to access the website (e.g. mobile, tablet)
• your IP address
• page requests
• browser types
• operating systems
• date and average time spent on our sites
• Click-through tracking and analytics software to map how visitors navigate through the pages of our websites and interact with different links to and within the sites. This information is used to analyze and understand site usage and to assist in planning future improvements.
• Cookies: A short text file that is downloaded to your computer when you visit our website. This common practice enables our website to find out whether your computer has connected to the site before and remember your preferences. Cookies, by themselves, do not provide your email address or other personal information unless you choose to provide this information. The "help" portion of the toolbar on most browsers can show you how to prevent the browser from accepting new cookies or disable them altogether.