CORPORATE PRIVACY POLICY RESPECTING THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
Why a Corporate Privacy Policy?
The CMA has always valued your privacy and acted to ensure that it is protected. The CMA has enacted this Corporate Privacy Policy to put into writing its current practices and to conform to legislative requirements requiring organizations to have written privacy policies. We have looked to the 10 principles of the Canadian Standards Association's (CSA) Model Code, which has been incorporated into federal privacy legislation, to formulate this policy.
This Privacy Policy applies to all personal information, excluding CMA employee information and information in the public domain, that has been and will be collected, used and disclosed by the CMA. The CMA has a separate but consistent online privacy policy for the cma.ca Web site (www.cma.ca).
What do we mean by 'Personal Information'?
Throughout this Policy, we discuss "personal information", and it is important from the outset to set out what we mean by this term. "Personal information" is information that reveals a distinctive trait about yourself and helps others identify you. Some personal information such as your business address may be found in the public domain by accessing publications like telephone or professional directories. The focus of this policy is personal information collected, used and disclosed by CMA that is NOT in the public domain.
What Types of Personal Information does CMA collect and use?
Primarily, the CMA collects and uses personal information about its members. CMA also has personal information about individuals who purchase CMA products and services, attend CMA sponsored events and seminars and submit manuscripts to CMA publications. The CMA assigns a personal identifier called a "CMA ID" to each member or purchaser of a CMA product or service so that you can use this number when contacting the CMA, ordering CMA products and publications or registering for the cma.ca Web site.
The CMA collects personal information directly from individuals or receives it from one of its provincial or territorial medical associations ("Divisions") or subsidiaries, the CMA group of subsidiary companies, including our primary financial services company, MD Management Ltd.
For instance:
- If you are a CMA member, you might have provided on an application form or will provide to the CMA or a CMA Division or a CMA subsidiary, personal information like your home address, date of birth and gender. Please note that if you happen to be both a client of one or more of CMA's financial subsidiaries and a CMA member, CMA does not collect or use such highly sensitive information as your client status and the financial details you might have provided to your advisers.
- If you have attended an event organized through CMA's Meetings and Travel Department, you might have provided us with credit card data as well as information about certain travel preferences and food sensitivities.
- If you have purchased a CMA product (e.g., classified advertising) or attended a CMA seminar (e.g., Physician Manager Institute), you provided us with personal contact information such as your name and address. We might also have collected credit card information if you chose to pay for the product or service by this method.
- If you have submitted a manuscript for publication in a CMA journal, you provided us with contact information, financial disclosure and competing interests data and the manuscript itself.
Why does CMA collect and use personal information?
CMA will collect and use only the personal information necessary to achieve the following purposes:
- to determine an individual's eligibility for membership in the CMA or to serve as a potential contributor to a CMA publication;
- to determine an individual's eligibility to benefit from the services of one of CMA's subsidiaries or its preferred third-party suppliers;
- to provide and to communicate information about CMA member benefits and services (e.g., the delivery of publications and travel reservations, financial services, advocacy, etc.);
- to develop and to market products and services tailored to the interests of CMA members and the purchasers of CMA products and services;
- to update contact information in the CMA database;
- to assist the CMA Divisions and CMA's subsidiaries with the maintenance of their membership and client contact information;
- to provide individuals with the opportunity to benefit from supporting the Canadian Medical Foundation which provides CMA members and others with valuable educational programs and services;
- to conduct surveys and research studies of the physician population in order to analyze for statistical and research purposes such issues as the demographics of physician human resources;
- to engage members and physicians in CMA's policy development process; and
- to broadcast urgent health alerts of national significance.
When and to whom does CMA disclose personal information?
The CMA does not sell or trade personal information. The CMA will only disclose your personal information to an organization for a purpose outlined in this policy, unless we obtain your consent for a new purpose. For example, one purpose identified above is maintaining up-to-date membership and client contact information. Although the CMA does not collect, use or disclose financial information about its subsidiaries’ clients, the CMA and its subsidiaries do share a core data field for the purposes of updating addresses and confirming membership status. A limited number of employees in the CMA Member Service Centre administer and update this shared core data field in our computer system. For example, if you are both a CMA member and a client of a CMA subsidiary company, when you inform the Member Service Centre of an address change, with your permission, this information will be changed for both organizations.
The CMA might also disclose personal information to third parties or to organizations or companies that are not CMA-affiliated companies or Divisions if these organizations have contracted or partnered with the CMA to help us provide products and services or do research. For example, the CMA might out-source the mailing list function for one of its publications or work with the Canadian Post-MD Education Registry to study physician resource planning.
Within the CMA itself, your personal information is shared among departments on a strictly need-to-know basis. For instance, the fact that you might have submitted a manuscript for publication or purchased a classified advertisement will not be known within the CMA except to those staff members within the Publications department itself who are required to know this information. Similarly, only certain CMA employees have access to personal information about food sensitivities for meeting preparation and catering purposes.
What if you object to CMA's collection, use or disclosure of personal information?
The CMA seeks to respect and honour your privacy and communication preferences. For instance, if you indicate to the CMA that you do not wish to receive certain publications, participate in surveys or receive information about new or specific benefits and services such as communications from CMA’s subsidiaries, your preference will be noted and you will no longer receive correspondence from us on these issues. Please contact the CMA Member Service Centre at 888 855 2555 to make such a request.
You may also at any time, subject to restrictions required by law, object to the CMA’s collection, use or disclosure of personal information. You need only provide the CMA with reasonable notice in writing of your intention and the details of your objection. For instance, if you do not wish to have contact and demographic information shared with the Canadian Medical Foundation, we will respect your choice.
Please note, however, that your objection to the disclosure of other information might mean that the CMA is unable to continue to provide you with some products or services. For example, if you object to the sharing of your CMA membership status with CMA’s financial subsidiaries, then you will not be eligible to benefit from their products or services. MD Management has to confirm your CMA membership status in order to offer you financial services.
It is your responsibility to contact the CMA in order to determine how an objection to the collection, use and disclosure of personal information might affect the services supplied.
How accurate is the personal information held by CMA?
The CMA makes every reasonable effort to ensure the accuracy and currency of your personal information so that we might fulfill the purposes for which it was first collected. Your personal information is subject to change so please advise us accordingly of such changes so that we might better meet your needs.
How do you access the personal information held by CMA?
You may send a written request to the attention of the Chief Privacy Officer at 1867 Alta Vista Drive, Ottawa, Ontario, K1G 3Y6 or to privacy@cma.ca to obtain the personal information held about you by CMA. Within a reasonable time frame, CMA will then advise you in writing whether it has such personal information and the nature of this information unless there is the rare occurrence that the release of such information is legally prohibited. If CMA cannot release the personal information, we will provide you with the reasons for denying access.
You may challenge the accuracy and completeness of the personal information that is maintained by CMA. CMA will amend personal information when an individual successfully demonstrates inaccuracy or incompleteness.
How secure is your personal information?
The CMA makes every reasonable effort to protect your personal information by implementing security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The CMA uses physical, organizational and technological measures as methods of protection. For instance, only a limited number of staff have access to such sensitive information as credit card numbers. An even smaller number can actually change personal contact information for updating purposes. Moreover, the CMA will ensure that employees are aware of the importance of maintaining the confidentiality of personal information.
How long does CMA retain personal information?
The CMA keeps personal information as long as it is needed to fulfill the purposes identified above. When personal information is no longer required to fulfill the identified purposes, it will be safely and securely destroyed. Moreover, the CMA will retain personal information that is the subject of an access request for as long as is necessary to allow an individual to exhaust any legal remedy that is provided for in applicable federal or provincial/territorial privacy legislation.
What if you have a question or concern about this Privacy Policy or CMA privacy practices?
You may address any questions or concerns relating to this Privacy Policy or CMA privacy practices to the Chief Privacy Officer, 1867 Alta Vista Drive, Ottawa, Ontario, K1G 3Y6 or to privacy@cma.ca. For more information about your personal privacy rights, you might contact the Privacy Commissioner of Canada at the web site:http://www.privcomm.gc.ca or the applicable provincial Privacy Commissioner in your province or territory.
JULY, 2007
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