SolePath Privacy Protection Policy

What is personal information?

Personal information means information about an identifiable individual. This includes but is not limited to an individual’s name, contact information, age, sex, marital or family status, an identifying number, etc.

What personal information do we collect?

We collect only the personal information that we need for the purposes of providing services to our clients, including personal information needed to, for example:

• open and manage a membership account
• deliver requested products and services
• enroll a client in a program
• send out membership information
• contact clients about appointments
• to provide information that is useful in developing new features and services for members and clients
• to provide the membership base and client with an individual experience on the site through personalization
• follow up with clients to determine satisfaction with products and services
• establish statistical trends that contribute to understanding SolePath
• administer our community programs
• meet regulatory requirements

We collect client information directly from our clients and we collect client information from other persons with the consent of the client or as authorized by law.

We inform our clients, before or at the time of collecting personal information, of the purposes for which we are collecting the information. However, we don’t provide this notification when a client volunteers information for an obvious purpose for example requesting a SolePath personality profile.

Use of Service Providers outside Canada

Our service providers across the world collect, use or disclose client personal information only for the purposes of providing services to our clients, including personal Information needed to, for example:

• open and manage a membership account
• deliver requested products and services
• enroll a client in a program
• send out membership information
• contact clients about appointments
• to provide information that is useful in developing new features and services for members and clients
• to provide the membership base and client with an individual experience on the site through personalization
• follow up with clients to determine satisfaction with products and services
• establish statistical trends that contribute to understanding SolePath
• administer our community programs
• meet regulatory requirements

Consent

We ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent in writing (by signing a consent form, by checking a box on a form, or electronically by clicking a button).

It is not possible for a client to delete his or her profile from our database, nor is it feasible to delete all traces of a Client’s activity on the system. Messages posted to boards are examples of activities that are not feasible to delete.

We may collect, use or disclose client personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.

How do we use and disclose personal information?

We use and disclose client personal information only for the purposes, for which the information was collected, except as authorized by law. For example, we may use client contact information to deliver goods. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary.

If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.

How do we safeguard personal information?

We make every reasonable effort to ensure that client information is accurate and complete. We rely on our clients to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible.

In some cases we may ask for a written request for correction.

We protect client personal information in accordance with the regulations set down under the Alberta Electronic Health Record Regulation. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.

We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.

Access to records containing personal information

Clients of SolePath have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.

If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.

You may make a request for access to your personal information by writing to our Director of Information Services. You must provide sufficient information in your request to allow us to identify the information you are seeking.

You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. For personal information collected before January 2004, if we do not have a record of disclosures, we will provide information about any disclosure of your information that is likely to have occurred.

You may also request a correction of an error or omission in your personal information.

We will respond to your request within 25 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.

Questions and complaints

If you have a question or concern about any collection, use or disclosure of personal information by SolePath, or about a request for access to your own personal information, please contact our Director of Information Services in the first instance:

Director of Information Services
SolePath
Info@solepath.org; 1.403.998.0191

If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Alberta:

Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6 Avenue, SW
Calgary, Alberta  T2P 3W2 Phone: 403-297-2728    Toll Free:1-888-878-4044
E-mail:     generalinfo@oipc.ab.ca
Website:       www.oipc.ab.ca