Effective date
August 1, 2024
1. Context and scope of application
The protection of personal information is important to Altitude Optométrie Inc. This Personal Information Governance Policy (“Policy”), adopted pursuant to the legal framework applicable to Altitude Optométrie Inc., sets out our practices with respect to the governance of the personal information we hold.
This Policy applies to all employees of Altitude Optométrie Inc. and applies to all personal information held by Altitude Optométrie Inc. including that held by a third party, regardless of the medium on which it is held, from the time it is collected until it is destroyed. In this sense, this Policy also applies to persons with whom Altitude Optométrie Inc. does business as part of a mandate or service contract.
By “personal information”, we mean any information that relates to a natural person and makes it possible, directly or indirectly, to identify that person.
2. Roles and responsibilities of company personnel with respect to personal information
Optometrists
The clinic's optometrists have access to patients' medical records to provide quality ocular care. They are responsible for :
- Perform eye examinations and diagnose ocular conditions.
- Document examination results and prescriptions in patient files.
- Ensure confidentiality and security of medical information.
Prescription opticians
Prescription opticians have access to patient prescriptions and certain personal information needed to provide glasses and contact lenses. They are responsible for:
- Interpreting optometrists' prescriptions.
- Help patients choose appropriate frames and lenses.
- Maintain confidentiality of prescription information and patient preferences.
Administrative personnel
The clinic's administrative personnel have access to patient identification and contact information to manage appointments and financial transactions.
They are responsible for:
- Scheduling and confirming patient appointments.
- Process payments and manage billing information.
- Ensuring the security and confidentiality of personal and financial information.
- Respect the rules we have adopted to protect personal information throughout its life cycle;
- Access only the personal information required to perform his/her duties;
- Inform the Privacy Officer of any incident or attempted incident related to the protection of personal information held by Altitude Optométrie Inc;
- Participate in training and awareness activities made available by Altitude Optométrie Inc.
Technicians
Optometric technicians assist optometrists during examinations and have access to patients' medical records. They are responsible for:
- Preparing equipment for eye examinations.
- Assist with diagnostic tests.
- Document test results and maintain confidentiality of patient information.
Privacy Officer
At Altitude Optométrie Inc. the position of Privacy Officer is held by Dr. Georges Louis, optometrist.
The Privacy Officer is responsible for ensuring that Altitude Optométrie Inc. complies with and implements the policies and practices governing the personal information we hold, in order to meet the requirements of the applicable legal framework.
As such, he must, among other things:
- Ensure compliance with and implementation of the provisions of the Act respecting the protection of personal information in the private sector;
- Ensure the application of this Policy;
- Be consulted when assessing the risk of harm to an individual whose personal information is affected by a privacy incident;
- Maintain records of personal information disclosures, including in the event of a privacy incident;
- Be consulted at any stage of a privacy impact assessment in connection with a project involving an operating system or electronic service delivery system involving personal information / the communication of personal information outside Quebec / communication for study, research or statistical production purposes - if applicable;
- Respond to requests for access to personal information and, where applicable, requests for rectification. He or she must also assist the applicant in understanding the decision to deny him or her - in whole or in part - access to or rectification of personal information;
- Manage complaints and security incidents relating to personal information.
- Train staff on personal information management practices.
- Respond to requests from the Commission d'accès à l'information.
2. Protection of Personal Information
The protection of personal information is important to Altitude Optométrie Inc. and we take the necessary steps to ensure that everyone working at Altitude Optométrie Inc. adopts a responsible attitude throughout the life cycle of personal information.
As such, Altitude Optométrie Inc. ensures to :
- Only collect personal information that is necessary for the performance of its activities;
- Inform individuals from whom personal information is collected of the purposes for which it is collected;
- Obtain consent for the use and disclosure of personal information to third parties;
- Use and disclose personal information only within the limits prescribed by the applicable legal framework;
- Take appropriate security measures to protect personal information, taking into account the sensitivity of the information, the purpose for which it is to be used, its quantity, distribution and medium;
- Take reasonable steps to minimize the risk of harm to individuals whose personal information is the subject of a privacy incident, and to prevent a similar incident from occurring in the future;
- Take reasonable measures to comply with requirements for the retention and destruction of personal information.
3. Request for access to or correction of personal information
If an individual wishes to know what personal information Altitude Optométrie Inc. holds about him or her, or if he or she wishes to rectify such information, he or she should contact the Privacy Officer in writing at the following address:
Dr Georges Louis
705 rue Davidson Ouest, Local 1,
Gatineau, Quebec, J8R-2T1,
info@altitudeoptometrie.com
4. Complaints concerning the protection of personal information
In the event that an individual wishes to file a complaint regarding the protection afforded by Altitude Optométrie Inc. to the personal information we hold, he or she may do so by contacting the Privacy Officer by e-mail at the following address: info@altitudeoptometrie.com.
The complaint must contain at least the following information:
- Identification of the complainant: name, e-mail address;
- Purpose and reason for the complaint - the complaint must be sufficiently precise, otherwise the Privacy Officer may contact the complainant to obtain any additional information required to assess the complaint.
Within 30 days of receipt of the complaint, the Privacy Officer shall diligently process the complaint and inform the complainant of the findings.
5. Policy update
Altitude Optométrie Inc. is committed to updating this Policy on an annual basis, or more rapidly in the event of legislative changes.