Mood Disorders Association of Ontario
I. Identifying the purposes and Use of Personal Information
Before collecting any Personal Information, MDAO will identify why the Personal Information is required and how it will be used. This Personal Information is documented and kept on file at MDAO’s offices. MDAO will obtain the User’s consent before using or disclosing Personal Information for purposes other than the original reasons given.
The only Personal Information MDAO has access to, uses and discloses is a User’s name and email address. It is used for the following purposes:
· Collecting, recording and using Personal Information relevant to the performance of the services rendered to and for a User only upon explicit consent from the User;
· Communicating with a User via email notification only upon explicit consent from the User;
· Complying with all applicable laws; and
· Such other specific purposes which are communicated to a User by MDAO and its representatives before collection of the Personal Information.
We may use, share and disclose a User’s Personal Information to our affiliates, associates, agents, suppliers and such other third parties as MDAO, acting reasonably, may deem necessary for the fulfillment of the purposes noted above or where otherwise permitted by law. In the unlikely event that MDAO or substantially all of its assets are acquired by a third party, a User’s Personal Information may be one of the assets transferred to such third party.
Except in certain extraordinary circumstances, MDAO does not collect, use or disclose a User’s Personal Information without their knowledge and consent. Such extraordinary circumstances may include, without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent.
III. Limiting collection
IV. Limiting use, disclosure and retention
Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the User, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous.
MDAO has security safeguards in place designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Personal Information and Module Information under the care of MDAO. The nature of the safeguards depends on the sensitivity, format, location and storage of the Personal Information. These security measures may from time to time include locked cabinets, computer passwords, software firewalls to stop hackers, encryption software, restricting access to Personal Information and Module Information to only the User and to those third parties to whom the User has authorized.
E-mail and the internet are not a 100% secure medium, and Users should be aware of this when sending Personal Information and Module Information.
VII. Accountability and Openness
VIII. Individual access
Upon written request of a User, MDAO will provide such User with access to his or her Personal Information, which MDAO has access to. MDAO only has access to a User’s name and email address. MDAO will correct or amend any inaccuracies in the User’s name or email address, and such amended information will be forwarded to any third parties who require access to the information. MDAO has the right to refuse a request for access to Personal Information:
• If the information is protected by legal privilege;
• If granting access would reveal confidential commercial or financial information;
• If doing so would reasonably be expected to threaten the life or security of another individual;
• If the information was collected for purposes related to the detection and prevention of fraud;
• If the information was generated in the course of a formal dispute resolution process;
• If the information would likely reveal Personal Information about another User;
• If the request is vexatious or frivolous; and/or
• To protect MDAO’s rights and property.
If the request of a User for such individual’s Personal Information is denied, the individual will be informed in writing of the reasons for the denial, as well as any recourse available to such individual.
Access to a User’s Personal Information will be at no cost to such User. Minimal charges may apply, however, for the transcription, reproduction or transmission of documents containing Personal Information.
IX. Challenging compliance
If a complaint (“Complaint”) regarding MDAO’s handling of Personal Information is received, an individual (the “Investigator”) with the skills necessary to conduct an investigation fairly and impartially will be assigned. The Investigator will have access to all relevant records and will be permitted to speak with employees of MDAO who handled the Personal Information access request. The complainant will receive notification of the outcome of the investigation clearly and promptly. Any inaccurate Personal Information or policy/procedure changes will be modified, if necessary, based on the outcome of the Complaint.
Currency: l 2012