Last modified: January 5, 2015
Personal Information Protection Policy
At AcuteNet™, we pride ourselves in delivering exceptional service to our clients. This service involves the collection, use and disclosure of some personal information about our clients, and protecting their personal information as one of our highest priorities guided by the 7 Principles of Design.
While we respect our clients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information in response to US HIPAA, Canada PIPEDA, Canada PHIPA and EU Data Protection Directives.
Through our corporate culture of visibility and transparency, 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.
This Personal Information Protection Policy outlines the 7 Privacy by Design principles and practices we will follow in protecting clients’ personal information. Our privacy responsibility 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.
Scope of this Policy
This Personal Information Protection Policy applies to AcuteNet™ and its subsidiaries. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of AcuteNet™.
Personal Information –means information about an identifiable individual. Personal information does not include contact information (phone number).
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.
Privacy Officer – means the individual designated responsibility for ensuring that AcuteNet™ complies with this policy.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
Policy 2 – Consent
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for AcuteNet™ to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.
2.3 We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
- When client has given approval to third parties who license the use of AcuteNet™ services under their supervisions, branding, product or service offerings.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- Reporting to third parties (licensees of AcuteNet™ services) to support the delivery of their products or services to clients
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties
Policy 4 – Retaining Personal Information
4.1 If we use client 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 client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client 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 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. If the correction is not made, we will note the clients’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client personal information is appropriately protected:
- Personal information, if collected, is encrypted in transit and at rest.
- Personal information is only accessible to authorized roles
- Personal information has physical and procedural safeguards in data centres
6.3 We will use appropriate security measures when destroying client’s personal information
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.
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 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring AcuteNet™’s compliance with this policy
8.2 Clients should direct any complaints, concerns or questions regarding AcuteNet™’s compliance in writing to the Privacy Officer.
Contact information for AcuteNet™’s Privacy Officer: