This Policy applies to all personal information collected, used and disclosed by the Royal College, Royal College International and the Royal College Foundation as it relates to their operations, or their respective employees, members, volunteers, clients and others with whom they are conducting business.
Definitions and interpretation
“Personal information” is defined as information about an identifiable individual and includes, but is not limited to, name, date of birth, residential address and phone number, personal email address, social insurance number and Royal College identification number. Personal information does not include job titles, business addresses (including email addresses) and business phone/fax numbers.
Note: In this policy, all references to the Royal College include its affiliates Royal College Canada International and the Royal College Foundation.
The following privacy principles are based on the ten principles of the Canadian Standards Association (CSA) Model Code.
The Royal College is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the Royal College’s compliance with the ten principles.
- Identifying Purposes
The purposes for which personal information is collected shall be identified by the Royal College at or before the time the information is collected.
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate. Consent is considered valid only if it is reasonable to expect that the individual understands the nature, purpose, and consequences of the collection, use and disclosure to which the individual is providing consent.
- Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by the Royal College. Information shall be collected by fair and lawful means.
- Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
The Royal College shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information, and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
- Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the Royal College’s compliance.
Out of Country Agreements
When the Royal College enters into an agreement with an organization outside of Canada and that organization will have access to Royal College personal information, the Royal College will ensure that it enters into a contractual agreement in which the third party is obligated to protect personal information it receives from the Royal College in a manner equal, at a minimum, to the level of protection the Royal College provides.
Members or other impacted individuals are notified through publication of this Policy that the Royal College may share personal information with third party organizations outside of Canada.
Roles and responsibilities
Royal College Legal Counsel and Privacy Officer is responsible for administering this Policy and identifying and communicating recommendations to further enable compliance with this Policy.
Managers/Directors of each unit/directorate are responsible for implementing recommendations for enabling compliance with this Policy.
Privacy related inquiries may be directed to:
The Royal College of Physicians and Surgeons of Canada
774 Echo Drive