For the purposes of this Policy, personal information means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from the information, but does not include business contact information (“Personal Information”). Membership Information is Personal Information that relates to your membership with the CPA, and consists of your name, mailing address, email, telephone number, fax number, member ID, password, membership account information, birth date and membership profile information (including information provided in your membership account regarding language, practice area, interests, CPA section selections, education, certification and licensing, and current residency). Customer Information is Personal Information provided to CPA in the course of obtaining or enrolling in CPA products and services offered through the website (if applicable), and consists of your name, mailing address, email, telephone numbers and payment information.
This Policy does not cover any information, recorded in any form, about more than one individual where an individual’s identity is not known and cannot be inferred from the information (Aggregated Information). The CPA retains the right to use Aggregated Information in any way that it determines appropriate.
CPA’s Privacy Officer
Mr. Glenn G. Brimacombe
Chief Executive Officer
Canadian Psychiatric Association
141 Laurier Avenue West, Suite 701
Ottawa, Ontario K1P 5J3
CPA will investigate all complaints and if it is justified, we will take all reasonable steps to resolve the issue. We will also let you know to which public bodies you may complain regarding our privacy practices.
Further, where appropriate, specific authorizations or consents may be obtained from time to time.
Please review this Policy periodically, especially before you provide any Personal Information.
In most cases, and subject to legal and contractual restrictions, an individual is free to refuse or withdraw his or her consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, products and services, including access to the website, can only be offered if a person provides Personal Information to CPA. Consequently, if an individual chooses not to provide us with any required Personal Information, we may not be able to offer certain products or services and we may ask you to refrain from using the CPA’s website. We will inform you of the consequences of the withdrawal of consent.
If you do not wish us to share your Personal Information with CPA Members, affiliates of the CPA, or other individuals or organizations who assist CPA in informing you about our products or services, you may advise us by contacting CPA’s Privacy Officer by sending an email to email@example.com or by calling (613) 234-2815.
Collection, Use and Disclosure of Personal Information
CPA may collect and use the Personal Information provided (including via the website, via email and through the website’s secure, members-only area) by members and others who have obtained or are enrolled for CPA products and services in order to:
- Fulfill its mandate to act as a professional association in support of psychiatrists in Canada;
- Provide products and services to its Members and to non-members who have obtained or enrolled for CPA products and services;
- Provide continuing education and educational courses to its Members;
- Meet legal or regulatory requirements;
- Manage our relationship with, among others, Members and others who have obtained or are enrolled for CPA products and services; and
- Such other purposes consistent with the foregoing purposes.
The Personal Information we ask for will depend upon which services or products you use.
CPA only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances, and only such information as is required for the above-noted purposes. The CPA does not sell, trade, barter or exchange for consideration any Personal Information. Unless permitted by law, no Personal Information is collected about an individual without first obtaining the consent of that individual to the collection, use and dissemination of that information.
Personal Information will be collected, to the extent possible, directly from the individual concerned except where it is reasonably necessary for the purpose of providing services to Members and where permitted by law.
The CPA may disclose Personal Information to organizations that perform services on its behalf (e.g., IT or infrastructure services). Personal Information will only be provided to such organizations if they agree to use the information solely for the purpose of providing services to the CPA and under the instruction of the CPA, and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy.
On receiving explicit consent from CPA Members, the CPA may also disclose certain Membership Information to other CPA Members through the CPA’s Member Directory available on in the Members-only section of the website. If you do not want your Membership Information to be shared with other CPA Members, you may ask us not to do so by updating/changing the consents provided in the Membership Profile section of your membership account under the heading “Directory Consent,” or by contacting us through CPA’s Privacy Officer at firstname.lastname@example.org or by calling (613) 234-2815.
Please note that there are circumstances when the use and/or disclosure of Personal Information may be justified or permitted or when the CPA is obliged to disclose information without consent, such as:
- When required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
- When the CPA believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- When it is necessary to establish or collect monies owing to the CPA;
- When it is necessary to permit the CPA to pursue available remedies or limit any damages that the CPA may sustain; or
- When the information is public, as permitted by Law.
When obligated or permitted to disclose information without consent, CPA will not disclose more information than is required.
The CPA does not knowingly collect Personal Information from anyone under the age of 18, especially children under 13, and does not use such information if it discovers that it is has been provided by a minor.
Active Information Collection
The public (unrestricted) areas of the site are not designed to actively collect information from visitors. In order to access and use the Members-only portion of the site, Members will need to provide certain Personal Information, which will only be used for providing services and information to Members.
Passive Information Collection
As you navigate through a website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses, cookies, Internet tags, and navigational data collection. The CPA uses IP addresses on this site to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, and administer and improve the site.
A cookie is a bit of information that a website sends to your Web browser that helps the site remember information about you and your preferences. The CPA’s site uses session cookies, which are temporary bits of information used to improve website navigation and to collect aggregate statistical information. They are erased when you exit your Web browser window or turn your computer off.
The CPA’s site also uses navigational data (log files, server logs, and clickstream data) for system management, to improve the content of the site for market research purposes, and to communicate information to visitors.
CPA does not share Personal Information obtained through cookies or other passive information collection with third parties.
Accuracy & Retention
The CPA endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which it uses that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, CPA will revise the Personal Information and, if necessary, use best efforts to inform third parties which were provided with inaccurate information (if applicable) so that those third parties may also correct their records.
The CPA retains Personal Information as long as the CPA believes it is necessary to fulfill the purpose for which it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your Personal Information is no longer required for CPA’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.
The principal place in which the CPA retains Personal Information is in the City of Ottawa, Ontario, as well as in the business locations of organizations performing services on the CPA’s behalf. Some of these third-party service providers may be located outside of Canada, including in the United States, and may therefore be subject to U.S. law. By using the site and providing Personal Information to the CPA, you hereby expressly consent to the collection, processing, maintenance and transfer of such information to and in the U.S.
Access and Correction
The CPA permits the reasonable right of access and review of Personal Information about an individual held by the CPA.
If you believe the information about you is not correct, you may request an update of that information by sending a request to the Privacy Officer at email@example.com or by calling (613) 234-2815. The CPA reserves the right not to change any Personal Information but will append any alternative text that the individual concerned believes to be appropriate.
The CPA reserves the right to decline access to Personal Information when the information requested
(a) Would disclose the Personal Information about another individual or about a deceased individual;
(b) Would disclose confidential business information that may harm the CPA or the competitive position of a third party;
(c) Is subject to solicitor-client or litigation privilege;
(d) Could reasonably result in: (i) serious harm to the treatment or recovery of the individual concerned; (ii) serious emotional harm to the individual or another individual; or (iii) serious bodily harm to another individual;
(e) May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions;
(f) Is not readily retrievable and the burden or cost of providing the information would be disproportionate to its nature or value;
(g) Does not exist, is not held, or cannot be found by the CPA;
(h) Would interfere with contractual or other negotiations of CPA or a third party; and/or
(i) May be withheld or is requested to be withheld under applicable legislation.
When information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
When information will be disclosed, the CPA will endeavor to provide the information in question within a reasonable time and no later than 60 days following the request.
The CPA will not respond to repetitious or vexatious requests for access to Personal Information. To determine whether a request is repetitious or vexatious, the CPA will consider such factors as the nature of the information, the frequency with which it is updated, and its purpose for which the information is used.
To guard against fraudulent requests for access to Personal Information, the CPA will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
The CPA endeavors to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to protect such information from loss, misuse, and unauthorized access, disclosure, alteration or destruction.
As part of those precautions, access to Personal Information is restricted to certain employees and external service providers that the CPA has determined need to possess this information, to ensure that the CPA may provide its products, services and information effectively. We use contracts and other measures with outside suppliers to maintain the confidentiality and security of your Personal Information and to prevent it from being used for any unauthorized purpose.
If any employee of CPA misuses Personal Information, this will be considered a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses Personal Information – provided for the purpose of providing services to or for CPA – this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between CPA and that individual or organization.
In terms of communicating Personal Information to CPA, you may wish to note that there is no method of transmitting or storing data that is completely secure. While the physical characteristics of each are different, mail, telephone calls, faxes and transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted.
The CPA attempts to strike a reasonable balance between security and convenience. In communicating with you, the CPA reserves the right to use a method of communication that is less secure than some of its less convenient alternatives. For example, we now send email as unencrypted plain text (as well as HMTL) because we believe that many of our Members, service providers and other third parties cannot readily process encrypted email. Thus, although this is done for your convenience, the security concern exists that, if misrouted or intercepted, unencrypted plain text could be read more easily than encrypted email.
You may have received or created a unique Member ID and password in order to use the secure, Members-only portions of CPA’s website. You are requested not to divulge your Member ID or password to anyone other than authorized CPA personnel and only to permit them to serve you.
Links to Other Websites