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LAST UPDATED: March 2021
At the Natural Health Practitioners of Canada Association ("NHPCA"), your privacy is of great importance to us. The NHPCA is dedicated to the protection of the personal information of customers, event registrants, volunteers, visitors to our websites, and members of the public with whom we interact.
The NHPCA takes full responsibility for the management and confidentiality of personal information. Personal information is collected, used, shared, and stored in accordance with the all privacy laws that apply to the NHPCA, as well as the best practice principles contained in the Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96.
The NHPCA has appointed a Privacy Officer who oversees compliance with privacy laws and best practices. The Privacy Officer's duties include:
'Personal information' is any factual or subjective information, recorded or not, about an identifiable individual. This includes name, contact information, occupation, and any identifiable online activity. Any personal health information provided to the NHPCA, for example from a complainant with respect to treatment received from a member, or any financial information such as payment card details, are considered sensitive personal information that we handle with extra care.
Aggregate or de-identified information that cannot be associated with a specific individual, such as website usage volume data, is not personal information.
Personal information can be collected in several ways, including through online forms when you register for an NHPCA program, or verbally on the telephone, for example if you provide your information to our Education and Events, Complaints Resolution, or Practice Management Departments. We collect limited personal information as is reasonable to offer and deliver our products or services, and we do so with your consent or as otherwise authorized by law. We identify when information may be provided optionally and when it is necessary in order to service you.
When it is practical to do so, we will collect the information we need directly from you. In those instances where information is collected from a third party such as a family member or a witness, your personal information will be respected in exactly the same way as if we collected it from you personally.
We collect, use, and disclose your personal information with your consent, except as required or permitted by law. Your consent to the collection, use, and disclosure of personal information may be express (that is, where you were asked specifically for your consent, whether verbally or in writing) or implied for non-sensitive information, when we can reasonably conclude that you've given consent by some action, or when it is obvious that you would consent if directly asked.
Note that there may be instances where the law permits the collection, use, or disclosure of your personal information without your consent, for example in the context of fraud investigations, and where necessary to protect our legal interests or the safety of others. For example, we may be required to collect, use, disclose, or store personal information without your consent to comply with other laws, an order of a court, or other legal administrative tribunal, or to respond to an authorized inquiry of a government agency. In other contexts, your consent can be withdrawn at any time, subject to legal or contractual restrictions, by providing us with written notice. Upon receipt of notice of withdrawal of consent, we will inform you of the likely consequences of withdrawing your consent before we process your request, which may include the inability of the NHPCA to provide you with certain information, products, or services.
Where an individual is not capable of consenting to the collection, use, or disclosure of his or her own personal information but you wish to provide us with that information, please ensure you are legally entitled to do so on behalf of that individual.
Personal information is collected and used by the NHPCA for one or more of the following specific purposes:
Your personal information is shared only to the extent required to provide you with our products and services, to support professional excellence and transparency, and to comply with legal requirements. We may disclose your personal information in the following circumstances:
In addition, personal information may be transferred or made accessible to NHPCA's agents and third-party service providers who assist us in carrying out our business and providing you with our products and services. These trusted entities have agreed to comply with strict privacy and confidentiality obligations. Such transfers of data for processing may occur in the context of payment processing, complaint investigation, IT managed services and software development, event planning, and other business outsourcing arrangements. Only personal information that is required by the third party to provide the service in question will be transferred.
Please note that in the context of any of these disclosures or transfers of data, your personal information may be processed or stored outside of Canada. Such information may be provided to law enforcement or national security authorities of the foreign jurisdiction upon request, in order to comply with foreign laws. We take reasonable steps to ensure that any such third parties who we entrust with your personal information are reputable, and have safeguards in place to protect your information.
The NHPCA acknowledges that a data security breach could result in potential harm to individuals whose personal information is entrusted to the NHPCA. Thus, we have implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful access to the personal information we manage and store. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by NHPCA significantly reduce the likelihood of a data security breach.
Here are some examples of the security controls we have in place:
In addition, we recommend that you do your part in protecting yourself from unauthorized access to your personal information. For example, never share your passwords with anyone. The NHPCA is not liable for any unauthorized access to your personal information that is beyond our reasonable control.
We make every effort to ensure that the personal information contained in records that we control or have custody over is accurate, complete, and up-to-date for the purposes for which we collect it. You can make a written request for access to your personal information at any time and also request that it be corrected if there are any inaccuracies. You will need to provide as much information as you can to help us process your request and locate the information you require.
If you need assistance in preparing your access request, please get in touch with our Privacy Officer (see contact information at the end of this policy). As we take your privacy seriously, we will take reasonable steps to verify your identity before granting you access or making corrections, updates, or deletions to your personal information. Upon your written request, the NHPCA will also inform you of how your personal information has been or is being used, and who your personal information has been shared with. If we have obtained information about you from other people, we will let you know who we got it from upon your request.
The NHPCA responds to access requests within 30 days, unless an extension of time is required. We may charge a fee to cover any expenses related to responding to your access request. Note that there may be contexts where access is refused or only partial information is provided, for example, in the context of an on-going investigation or where another individual's personal information or identity must be protected.
The NHPCA retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with our record retention schedules. Personal information that has been used to make a decision about an individual shall be retained long enough to allow the individual access to the information after the decision has been made. NHPCA may be subject to specific contractual or legal requirements to maintain personal information as well.
Once your information is no longer required by the NHPCA to administer products or services and meet contractual, legal, or regulatory requirements, it is securely destroyed, erased, or made anonymous. Keep in mind however that residual information may remain in back-ups for a period of time after its destruction date.
The NHPCA takes privacy complaints very seriously and has a procedure in place for escalating and managing any privacy related concerns to ensure that they are responded to in a timely and effective manner. Any suspected privacy breach must be escalated internally to the NHPCA's Privacy Officer who oversees the containment, investigation, and corrective actions for the breach situation.
In the event that you are not satisfied with the NHPCA's resolution of a complaint or privacy breach, you may have the ability to file a formal complaint with a privacy regulator at the provincial or national level in Canada.
The NHPCA installs first-party cookies on devices that access its websites unless the browser used by the device has disabled the installation of cookies. The first-party cookies the NHPCA installs ensure the website functions as intended, and in some circumstances are essential for the NHPCA to provide services requested by website visitors. For example, enabling first-party cookies is required when registering for an event or purchasing advertising space, as certain cookies are used to support movement between webpages with your selections. Non-essential cookies are also used by NHPCA to analyze and improve the performance of our websites, design and layout, and your overall online experience. For example, the NHPCA uses web analytics services, including Google Analytics, to understand the interests of our visitors and analyze traffic patterns. We make no effort to personally identify you based on your visit to our sites if you are not logged into your account. If you wish, you can make use of Google's freeGoogle Analytics Opt-Out Browser Add-On.
The NHPCA's use of social media serves as an extension of our presence on the Internet and helps us build a positive brand image as well as offer our customers personalized service. NHPCA social media accounts are not hosted on NHPCA's servers. Please note that when you publicly post personal information on social media, it can be viewed by anyone who visits our platforms. Users who choose to interact with the NHPCA via social media, such as Facebook, should read the terms of service and privacy policies of these services/platforms.
We may offer links from our websites to the sites of third parties (including affiliated organizations) that may be of interest to you. Since these sites are not owned or controlled by us, the NHPCA makes no representations as to such third parties' privacy practices and we recommend that you review their privacy policies before providing your personal information to any such third parties.
Any inquires, concerns or complaints regarding privacy should be directed to:
Natural Health Practitioners of Canada Association
230-9440 49 Street
Edmonton, AB T6B 2M9
Your concerns will receive prompt attention. Our Privacy Officer can also provide you with more detailed information about the NHPCA's policies and practices. Keep in mind however that e-mail or text messaging are not secure forms of communication, so never send confidential personal information to us this way.
Thank you for continued trust in the Natural Health Practitioners of Canada Association.