Personal Information Protection

Private Sector Privacy Legislation

Personal Information Protection Policy




OptaDerm Products Inc.

Personal Information Protection Policy

At Optaderm Products Inc., we are committed to providing our clients and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients and customers, protecting their personal information is one of our highest priorities.

While we have always respected our clients and customers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients and customers 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, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ and customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ and customers’ personal information and allowing our clients and customers to request access to, and correction of, their personal information.

Definitions

Personal Information – means information about an identifiable individual: As an example: Optaderm Products collects personal information including name, birthdate, home address, email addresses, and phone/cellular numbers in order to facilitate communication of appointments and reminders, as well as to track client and customer purchase records. We further collect only relevant medical information for persons receiving aesthetic laser services as recommended by the laser manufacturing companies as being necessary to create successful treatments.

Personal information does not include contact information (described below).


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 or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that Optaderm Products Inc. complies with this policy and PIPA. Our Privacy officer is Bryan Common, Business Operations Manager (BryanC@optaderm.com or 604-251-1190)

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the client or customer 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.

1.2 We will only collect client and customer information that is necessary to fulfill the following purposes:

· To identify client and customer preferences;

· To deliver requested products and services;

· To provide aesthetic services;

For example: we may collect name, home address, home telephone number, cellular phone number, email addresses, and birth date;

· To enrol the client in a program;

· To ensure a high standard of service to our clients and customers;

· To meet recommended requirements;

For example: we collect only relevant medical information for persons receiving aesthetic laser services as recommended by the laser product manufacturers’ as being necessary to create successful treatments and to exclude persons for whom treatments are not recommended or only recommended at specific settings.


Policy 2 – Consent

2.1 We will obtain client and customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided orally, in writing, electronically, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client or customer voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client or customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client or does not opt-out.

2.4 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 and customers can withhold or withdraw their consent for OpytaDerm Products Inc to use their personal information in certain ways. A client’s or customer’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 or customer in making the decision.

2.5 We may collect, use or disclose personal information without the client’s or customer’s knowledge or consent in the following limited circumstances:

· When the collection, use or disclosure of personal information is permitted or required by law;

· In an emergency that threatens an individual's life, health, or personal security;

· When the personal information is available from a public source (e.g., a telephone directory);

· When we require legal advice from a lawyer;

· For the purposes of collecting a debt;

· To protect ourselves from fraud;

· To investigate an anticipated breach of an agreement or a contravention of law


Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose client or customer 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:

· To conduct client and customer surveys in order to enhance the provision of our services;

· To contact our clients and customers directly about products and services that may be of interest if permission has already been given to participate in marketing activities;

· To transfer information obtained from retail sales to the client or customer aesthetics services program if the client or customer requests aesthetic services.

3.2 We will not use or disclose client or customer personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client or customer lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use client or customer personal information to make a decision that directly affects the client or customer, we will retain that personal information for at least one year so that the client or customer, member has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client or customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose. As an example; we retain details of customer or client contact data and medical details, provided at the time of obtaining laser aesthetic services for at least three years, in order to provide such data to medical, legal, or insurance professionals on the request of the client or customer; or in the event of legal proceedings related to the same said aesthetic laser services.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that client or customer personal information is accurate and complete where it may be used to make a decision about the client or customer, or disclosed to another organization.

5.2 Clients and Customers 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.

A request to correct personal information should be forwarded to the Privacy Officer Bryan Common, Business Operations Officer (604 )251-1190

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’ or customers’ correction request in the file.


Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client and customer 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 and customer personal information is appropriately protected:

· the use of locked filing cabinets;

· physically securing offices where personal information is held;

· the use of user IDs, passwords, encryption, firewalls;

· restricting employee access to personal information as appropriate (i.e., only those that need to know will have access;

· contractually requiring any service providers to provide comparable security measures.

6.3 We will use appropriate security measures when destroying client’s and customer’s personal information such as shredding documents, deleting electronically stored information after 1 or 3 years (see: Policy 4.0)

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 and Customers Access to Personal Information

7.1 Clients and Customers have a right to access their personal information, subject to limited exceptions.

Limited exceptions include documentation subject to solicitor-client privilege, or where disclosure would reveal personal information about another individual

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

A request to access personal information should be forwarded to the Privacy Officer Bryan Common, Business Operations Manager, BryanC@optaderm.com or (604)251-1190

7.3 Upon request, we will also tell clients and customers 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 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client or customer of the cost and request further direction from the client or customer, on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the client or customer in writing, providing the reasons for refusal and the recourse available to the client or customer.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer or Owner is responsible for ensuring OptaDerm Products Inc. compliance with this policy and the Personal Information Protection Act.

8.2 Clients and Customers should direct any complaints, concerns or questions regarding Optaderm Products Inc’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client or customer may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for OptaDerm Products Inc’s Privacy Officer:

Bryan Common,

Business Operations Manager

Suite 340-2184 West Broadway

Vancouver, BC V6K 2E1

(604) 251-1190

BryanC@optaderm.com


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