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Privacy Policy



Openness About the Management of Personal Information
The Division makes information available about its policies and practices relating to the management of personal information.

  1. The Division has open and transparent information management practices that ensure accountability for personal information.
  2. The Division makes contact information available about the person responsible for the Division privacy policies and procedures.

Accountability for Personal Information
The Vancouver Division of Family Practice (VDoFP) is responsible for personal information under its control and will designate an individual or individuals who are accountable for the organization’s compliance with established privacy principles.

  1. The Board of Directors of the Vancouver Division of Family Practice (Division) is accountable for compliance with the privacy policy and procedures. The board may designate day-to-day operational responsibility to other staff members of the organization. Decisions regarding the interpretation and application of the policies and procedures are the ultimate responsibility of the board or designate.
  2. The Division is responsible for personal information in its possession and this includes both information that has been transferred to a third party for processing and information received from a third party. The Vancouver Division will put into place contractual agreements that commit the third party to protect the information in accordance with the Personal Information and Privacy Act. Third parties will also acknowledge that they understand the Vancouver Division’s Privacy Policy and will comply with this policy when using any personal information provided by the Vancouver Division.

Identifying Purposes for Personal Information
The Division will identify the purposes for which personal information is collected before or at the time the information is collected.

  1. The Division identifies the purpose for which personal information is collected before or at the time of collection of the information. The need for the information is clearly documented and only personal information with an identified purpose is collected.
  2. The Division has in place an approval process to review any request for the collection and/or use of personal information.
  3. The Vancouver Division will collect and use information to improve primary care for patients and the Vancouver population, and to support family physicians and improve their levels of well-being and professional satisfaction.

Consent for the Collection, Use or Disclosure of Personal Information
The Division will ensure that the knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

  1. The Division obtains consent for the collection, use and disclosure of personal information before or at the time of collection.
  2. The Division does not disclose personal information for secondary or other purposes such as marketing. The Division only discloses personal information to endorsed service providers and affiliated organizations, and a contractual agreement will be in place that commits the affiliated organization or endorsed provider to protect the information according to the Act.
  3. The Division does not make consent a condition for supplying a product or service, unless the information requested is required to fulfill a specified and legitimate purpose.
  4. The Division will collect, use and disclose employee personal information for the purposes of establishing, managing or terminating a contractual relationship.

Limiting Collection of Personal Information
The collection of personal information will be limited to that which is necessary for the purposes identified by the Division. Information will be collected by fair and lawful means.

  1. The Division collects only the personal information necessary to fulfill the purposes identified for the information.
  2. The Division information collection practices are fair, lawful and respectful of the individual.

Limiting Use, Disclosure and Retention of Personal Information
The Division will not use or disclose personal information for purposes other than those for which it was collected, except with the informed consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

  1. The Division uses or discloses information only for the purposes identified before or at the time of collection. New uses or disclosures are permissible only with the consent of the individual or as required or permitted by law.
  2. The Division retains personal information for as long as it is needed to achieve the identified purpose(s) or related business or legal obligation. Personal information that is used to make a decision about an individual is retained for at least one year after using it so the individual has a reasonable opportunity to obtain access to it. The Division is guided by industry standards related to retention schedules or applicable legislation.
  3. The Division communicates the limitations on use and disclosure of personal information to staff members. The Division allows staff to access and use personal information on a ‘need-to-know’ basis, i.e. information required to perform their job.

Accuracy of Personal Information
The Division is responsible for ensuring that personal information is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.

  1. The Division ensures that personal information being collected is accurate, complete, and up-to-date for the purposes for which the information is collected, used or disclosed.
  2. The Division updates personal information when necessary to fulfill the purpose(s) for which the information was collected.

Safeguards for Personal Information
The Division ensures personal information is protected by security safeguards appropriate to the sensitivity of the information.

  1. The Division has security safeguards in place to protect personal information against loss or theft and unauthorized access, disclosure, use, or modification regardless of the format in which it is held (e.g. paper, electronic, audio, video).
  2. The Division has a higher level of safeguards to protect more sensitive personal information.
  3. The Division uses care in the disposal or destruction of personal information in order to prevent access to the information by unauthorized parties.

Individual Access to Personal Information
Upon request, the Division informs an individual of the existence, use, and disclosure of his or her personal information and the individual has access to that information. An individual has the ability to challenge the accuracy and completeness of the information and have it amended as appropriate.

  1. The Division informs an individual of the existence, use, and disclosure of his or her personal information upon request, and provides access at no cost to the individual. Where the Division is unable to provide full access to an individual’s request for information, the reasons for limiting access are stated in a specific, reasonable, and justifiable manner.
  2. The Division provides the opportunity for an individual to correct inaccurate or incomplete information.

Challenging Compliance
An individual has the ability to challenge the Division’s compliance with these principles by contacting the designated individual or individuals accountable for the organization’s compliance.

  1. The Division provides a process for an individual to challenge the organization’s compliance with the stated privacy principles, policies and practices.
  2. The Division investigates all complaints.
  3. Breach of this policy may result in disciplinary action up to and including dismissal.

Privacy Policy Definitions
Access: The entitlement of an individual to examine or obtain his or her own personal information held by an organization.
Accountability: An organization is responsible for personal information under its control and designates individual(s) who are accountable for the organization’s compliance with its privacy policies, procedures and practices.

Accuracy: Personal information kept by the organization will be accurate, complete and up-to-date.
Challenging compliance: An individual has the ability to challenge an organization’s compliance with its privacy principles, policies, procedures and practices and the complaint is directed to the designated individual(s) accountable for the organization’s compliance with its privacy policies, procedures and practices.

Collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

Consent: An organization will ensure that there is voluntary agreement by an individual, or his or her legally authorized representative, to allow the collection, use or disclosure of the individual’s personal information. The consent may be either express or implied and should include an explanation as to the implications of withdrawing consent. Express consent is given explicitly and unambiguously, either verbally or in writing. Implied consent is given when the action/inaction of an individual reasonably infers consent.

Disclosure: Disclosure occurs when personal information is made available to a person who is not employed by or in the service of the party holding the information (e.g. service providers).

Identify the purpose: Purposes, which includes why the information is being collected and how it is being used is identified by the organization at or preferably before the time of collection. The reason for collection is documented.
Personal information: Personal information is any factual or subjective information, recorded or not, regarding an identifiable individual. Examples include name, age, identification number, income, ethnic origin, blood type, opinions, evaluations, comments, social status, disciplinary actions, employee files, credit or loan records, medical records, or the existence of a dispute between parties.

Privacy: Privacy is the fundamental right of an individual to have their personal information protected.
Retention schedule: A retention schedule identifies the period of time personal information is held. Personal information should not be held for longer than is necessary to fulfill the purposes for which it was collected.
Safeguards: Safeguards are the actions taken to protect personal information. The level of the action is appropriate to the level of sensitivity of the information.

Security: Personal information is protected from unauthorized or unintentional loss, theft, access, use, modification or disclosure.

Third party: A third party is an individual or organization outside the Division.

Use: Use refers to the treatment and handling of personal information within an organization.

Questions
Any questions related to this Privacy Policy can be directed to the Vancouver Division’s Privacy Officer, Halla Elmobayad.

** Last updated June 2013


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The Vancouver Division of Family Practice currently has more than 1,000 family doctors and resident members.

Contact Us

Vancouver Division of Family Practice
202- 777 W Broadway
Vancouver, BC
Canada, V5Z 4J7

Phone:  604.569.2010
Fax: 604.321.5878
Email: vancouver@divisionsbc.ca

Business Hours

8:30am - 4:30pm PST

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