Personal Information Protection
Sector Privacy Legislation
Information Protection Policy
OptaDerm Products Inc.
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.
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
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
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
1.2 We will only
collect client and customer information that is necessary to fulfill the
identify client and customer preferences;
deliver requested products and services;
provide aesthetic services;
For example: we may
collect name, home address, home telephone number, cellular phone number, email
addresses, and birth date;
enrol the client in a program;
ensure a high standard of service to our clients and customers;
meet recommended requirements;
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
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).
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.
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.
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.
We may collect, use or disclose personal information without the client’s
or customer’s knowledge or consent in the following limited circumstances:
the collection, use or disclosure of personal information is permitted or
required by law;
an emergency that threatens an individual's life, health, or personal
the personal information is available from a public source (e.g., a telephone
we require legal advice from a lawyer;
the purposes of collecting a debt;
protect ourselves from fraud;
investigate an anticipated breach of an agreement or a contravention of law
– Using and Disclosing Personal Information
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:
conduct client and customer surveys in order to enhance the provision of our
contact our clients and customers directly about products and services that
may be of interest if permission has already been given to participate in
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
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
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
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
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
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.
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
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
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
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:
340-2184 West Broadway
BC V6K 2E1