Who Does This Privacy Statement Apply To?
WECHU administers mandated public health programs to keep our community healthy. Depending on an individual’s relationship with us and how they interact with us, the specific personal information or personal health information that we collect, use and disclose and the related purposes varies. This Privacy Statement applies only to website visitors. It applies to all of our websites.
What is the Purpose of this Privacy Statement?
WECHU is committed to protecting your privacy, whether you are browsing for information or communicating with WECHU through our websites. The purpose of this Privacy Statement is to let you know how WECHU respects your privacy in connection with our websites.
Privacy Compliance
All of our privacy related practices have been designed to comply with, or exceed applicable privacy legislation, specifically:
- Ontario Health Protection and Promotion Act
- Ontario Municipal Freedom of Information and Protection of Privacy Act
- Ontario Personal Health Information Protection Act
How Do We Collect Personal Information?
Generally, we collect personal information about you directly from you or those who act on your behalf. Sometimes we collect personal information by recording how you interact with us, for example, by way of using Google Analytics or Siteimprove, in connection with our websites. Occasionally, we collect personal information about you from other sources, if we have obtained your consent to do so or if the law permits such collection.
What Personal Information Do We Collect, Use and Disclose and Why?
We limit the personal information that we collect about website visitors to that which is necessary for our purposes as outlined in this Privacy Statement. Further, we also only use and disclose your personal information for those purposes. If the personal information we require is collected for a reason other than as outlined in this Privacy Statement or if a new purpose arises, we will seek your further consent. More specifically:
- Personal Information. Personal information that we collect about our website visitors includes:
- When you view our website your internet protocol (IP) address, your device type, brand and model, your operating system, your browser type, and the date and time of your visit are automatically logged. IP addresses are unique numbers assigned by internet service providers to all devices used to access the Internet. The IP address on its own does not identify you and while we generally do not try to link it with other data, it is possible. We also employ digital markers. A digital marker is a small file placed on your computer. A “cookie” is an example of a digital marker. Our digital markers allow us to recognize a previous visitor to our website. They also allow us to track what information is viewed, for how long, the sequence and other information, and the source such as an email newsletter.
- We have a number of features on our website. For example, you can send us an email, subscribe to receive emails, register for a class or clinic, submit and view immunization records, and participate in surveys and contests. Our features change from time to time as we make improvements to our website. Depending on which feature you use, we collect a variety of additional personal information, such as for example, your name and email address.
- For certain website features we may request that you provide a health card number. Unless we are permitted by law to require production, any production is on a voluntary basis. If you do not wish to voluntarily provide a health card number please contact our Privacy Officer (see below contact information) for other options.
- Purposes. The personal information about our website visitors that we collect, use and disclose, is for the following purposes:
- Conducting web analytics, including monitoring website use, traffic patterns and other aspects, so that we can work at improving your on-line experience.
- In the context of the use of any website feature, to fulfill the purpose of that feature, and also to understand better who is using our features, so that we can target improvements.
- Evaluating, planning, administering, and managing WECHU’s operations.
- In connection with the collection of a health card number – it will only be used and disclosed for purposes related to the provision of provincially funded health resources or for other purposes required or permitted by law.
- Any other purposes required or permitted by law.
What We Won’t Do with Your Personal Information
We assure you that we will not sell or rent your personal information to others.
What We Do to Protect Privacy
We are responsible for the personal information within our control. We have established policies and procedures, specifically designed to protect personal information from theft, loss, unauthorized use, disclosure, copying, modification, or disposal. Once we no longer need your personal information for our purposes, we securely destroy it. We educate our staff about these policies and procedures and monitor compliance. More specifically in the context of our websites:
- Access Controls. Access controls are applied to data and other files to ensure that they are accessible only to WECHU staff or agents for necessary purposes.
- Encryption. Secure Socket Layer encryption software is used throughout the website to protect your information during transmission. A security icon will appear in your browser window to indicate that you are using a secure channel. Please note that WECHU cannot guarantee the security of email or files sent through unsecured channels. If encryption is not available through a WECHU website, an alternative means of communication is recommended (e.g., telephone call).
- Disposal. Personal information is disposed of according to WECHU's record retention schedule. To ensure personal and personal health information is unrecoverable, any paper records generated are shredded, and electronic media is wiped prior to disposal using a utility program or by physical destruction of the media.
What We Do to Ensure Our Service Providers Protect Privacy
From time to time, we may engage third-party service providers to assist us with our purposes. We require all of our third-party service providers to protect your privacy, however if your personal information is out of the country, such as for example by way of a cloud computing provider, we note that it is subject to the laws of that country and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such country.
Your Control Over Your Own Personal Information
When you, or someone you have authorized, provides us with your personal information, you are consenting to WECHU’s collection, use and disclosure of that personal information for the purposes outlined in this Privacy Statement. In many circumstances, particularly when the personal information is extra sensitive, we also employ other methods to further ensure consent, such as just-in-time notifications. For example, many of our forms collecting personal information will contain a notice about consent.
You can change your consent preferences or withdraw your consent for the collection, use and disclosure of any or all of your personal information, at any time (see contact information below). However, it is important to note that when you change or withdraw your consent, it will not have a retroactive effect; it may have implications to you and it will not affect the collection, use and disclosure of personal information where such collection, use and disclosure is permitted or required by law without consent.
You have a right to see and get a copy of the information that WECHU has collected and retained about you, unless the law restricts access. You can request access in writing. The law allows WECHU to charge you a fee which may vary depending upon the amount of information you ask for, or additional actions that WECHU needs to take to provide the information. WECHU may waive this fee. WECHU will respond to your request for information within 30 calendar days. If there is a delay in providing the information, we will notify you and respond as quickly as possible. When all or a part of a record cannot be provided, we will inform you why access is restricted and give WECHU’s legal authority for this refusal.
If any inaccuracies in the personal information are noted, you can request that we correct those inaccuracies.
Questions and How to Reach WECHU
We are committed to providing you with understandable and easily available information about our privacy policies and procedures. We encourage you to contact us with any questions you might have. Please contact:
Privacy Officer
Windsor-Essex County Health Unit
1005 Ouellette Avenue
Windsor, Ontario N9A 4J8
(519) 258-2146, Ext. 1303
Email: privacy@wechu.org
Information and Privacy Commissioner of Ontario ("IPC/O")
We encourage you to let us try and resolve any privacy concerns that you may have. However, if you do not agree with how WECHU has responded to your request for access to a record or correction of a record, or have other privacy concerns, you have the right to make a complaint to the Information and Privacy Commissioner of Ontario. For more information about how to make a complaint, please see the Information and Privacy Commissioner’s website at www.ipc.on.ca, or you may write to them at:
Information and Privacy Commissioner/Ontario
2 Bloor Street East
Suite 1400
Toronto, Ontario M4W 1A8
Changes
We may change this Privacy Statement from time to time and encourage you to refer back to it regularly. This Privacy Statement is current as of the “last revised” date which appears at the top.