Health and Work Productivity Web Portal (HWP) is a project of HWP - Canadian Institute for the Relief of Pain and Disability. HWP considers your personal privacy to be an important part of our service to you. We understand the need to safeguard information that you have entrusted to us. As part of our commitment to you, we have adopted principles designed to protect your privacy and prevent misuse of your personal information and help you understand our commitment to your personal privacy.
"HWP", "we" or "our" refer to the Health and Work Productivity Web Portal which is a project by Canadian Institute for the Relief of Pain and Disability and its subsidiaries and affiliates, depending upon the context.
"Personal information" refers to any information that identifies you as an individual and includes information with respect to your name, address, age, gender, income, marital status, finances, employment, and web site use information, together with your personal references and identification numbers.
HWP's Principles on Privacy
The following principles will answer most of the important questions that you may have about how we gather, protect and use personal information, and how we will hold ourselves accessible and accountable to you.
Collecting and Using Personal Information
We will explain how we intend to use your personal information prior to or when we are collecting it and we will limit the personal information we collect to what we need for those purposes. We will use it only for the purposes we have explained to you and we will obtain your consent if we wish to use your personal information for any other purpose.
Disclosing Personal Information to Others
We will not provide your personal information to other persons not affiliated with HWP, unless we have your consent or unless we are compelled to do so by law.
Retaining and Protecting Personal Information
We will retain your personal information only for the time it is required for the purposes that we explain or as otherwise required by law. We will protect the personal information we obtain about you with appropriate safeguards and security measures.
Access and Accuracy
Upon request, we will inform you of the existence, use and disclosure of your personal information on record with HWP. We will make every reasonable effort to keep your personal information accurate and up-to-date.
Accountability and Openness to Your Privacy Concerns
Why Does HWP Collect Personal Information?
We collect, retain, and use personal information about you only when we reasonably believe that it will help administer our activities or provide products, services and other opportunities to you as our member. We collect and retain your personal information only for the specific purposes we explain to you. The information we collect depends on the activities, products, or services you request and as required by law or the policies of the regulatory bodies which we are subject. HWP may use your personal information to provide you with information about HWP's activities, products and services and other matters. This consent is optional and you can decide to withdraw it at any time. Please refer to the section regarding your options below.
How Does HWP Collect Personal Information?
We obtain most of our information about you directly from you. We may also contact references you have provided to verify information that you have given us.
When Does HWP Release Personal Information?
HWP does not sell or lease client lists or personal information to others. We do not reveal personal information about you to parties outside our affiliated organizations for their independent use unless you request or authorize it, the information is provided in order to complete a transaction initiated by you or the disclosure otherwise is lawfully permitted or required. We may disclose information to the authorities to serve a clear public interest and fulfill our public duty – such as to protect against fraud, money laundering or other criminal activity. In certain circumstances, HWP may disclose your personally identifiable information if it believes, in good faith, that disclosure is otherwise necessary or advisable to protect its interests. Sometimes it is necessary to provide personal information about you to a party outside our affiliated companies, such as to a vendor or service company that we hire to do our data processing or prepare your account statements or to provide support or services for one or more of our products. These vendors and service companies agree to safeguard confidential information about you and your products and services with us and must abide by applicable law.
Does HWP Provide Options?
It is always your choice whether or not to provide personal information or to consent to our obtaining personal information about you from third parties. In many cases you are free to refuse or withdraw your consent at any time. If you choose not to provide requested personal information or consents, we may not be able to provide certain products and services to you or you may be ineligible for or be unable to use certain products and services we provide. For example, you may refuse consent for us to send your mailing address to the company we use to handle our mailing services in which case we may not be able to mail you our newsletter or other printed matter.
We will record and respect your choices. If you wish to discuss your options you may do so by contacting HWP's designated privacy officer set out below. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent.
How Long Does HWP Retain Personal Information?
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information and may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed, we have procedures to destroy, delete, erase or convert it to an anonymous form.
How Does HWP Protect Personal Information?
HWP stores and processes your personal information in Vancouver, British Columbia, Canada. Certain personal information about you is retained by the HWP office that handles your account. We maintain security standards and procedures to help prevent unauthorized access to confidential information about you. Our security standards and procedures are updated and tested from time to time to improve the protection of our information about you and to assure the integrity of our personal information. We have procedures that limit employee access to personally identifiable information to those employees with a business need to know such information about you. We educate our employees about the importance of confidentiality and privacy through standard operating procedures, special training programs, and our internal policies. We take appropriate measures to enforce employee privacy responsibilities.
All our suppliers and agents, as part of their contracts with HWP, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required – otherwise we will seek your consent prior to disclosing any information.
What about the Internet?
Our site's operating system may automatically record information about your computer and about your visits to and use of this website, including: your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation.
HWP use this information for statistical analysis, to help us make our site more useful to visitors. HWP may disclose this non-personal information to third parties such as sponsors, clients or advertisers and/or use it for auditing purposes. This tracking system does not record personal information about individuals or link this information to any personal data collected.
HWP may use 'cookies' that identify you as a return visitor. A cookie is a piece of data that a HWP site can send to your browser, which may then store the cookie on your hard drive. So, when you come back to visit us again, HWP can tailor information to suit your individual preferences. The goal is to save you time and provide you with a more meaningful visit and to measure HWP site activity. Cookies do not contain any personally identifying information. All website browsers allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.
What about Spam?
You will not receive marketing e-mail from this organization unless you have consented to receive it. From time to time HWP may use e-mail as a way to keep in touch with our existing members and other interested individuals. However, HWP does not send 'spam' (unsolicited marketing e-mail) unless it has purchased or received permission from an authorized list owner to send e-mail to targeted health professionals interested in musculoskeletal or other health-related conditions.
If you agree to receive e-mail communications from us, every e-mail message HWP sends you will include an e-mail address to which you can respond. If at any time you decide you do not want to receive future marketing e-mail from us, simply let us know and HWP will remove your name and e-mail address from our marketing lists. HWP will do the same with your mailing address and telephone number, on request.
When you Leave HWP's Website via Third-party Link
Our site contains links to third-party sites. Once you click through to another website, you are subject to the privacy and security policies of the new website. HWP encourages you to read the privacy policies of all websites you visit, especially if you share any personal information on them.
How do I Access my Personal Information?
You may request access to your personal information on record with HWP and information about HWP's use and disclosure of that information by contacting HWP's office. We will advise you in advance if a minimal charge will be required for conducting the search, and we will respond to your request promptly but in any case within 30 days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to HWP, is too costly to retrieve, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine actions. If you have any questions regarding decisions made about you, we will tell you the reasons for those decisions.
How Do I Keep My Personal Information Accurate?
HWP attempts to keep its records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.
Who Should I Contact Regarding Privacy Issues?
HWP has designated a privacy officer, to respond to your concerns or questions about privacy and confidentiality – or any concerns about the way a request for personal information was handled.
To reach our privacy officer, please refer to the following:
- In writing, at 204 – 916 West Broadway Avenue, Vancouver, British Columbia, V5Z 1K7;
- By telephone, at 604-684-4148, or toll free at 1-800-872-3105;
- By facsimile, at 604-684-6247; or
- By e-mail, at email@example.com . Your concerns will be passed on to the appropriate Compliance personnel at HWP so that further action is taken to resolve the matter, if necessary.
If your concerns remain unresolved, you can contact the Board of Directors directly using our official mailing address: HWP, 204 – 916 West Broadway Avenue, Vancouver, British Columbia, V5Z 1K7.