The CVO promotes the security and privacy of an individuals personal information. Also under section 38 of the Veterinarians Act, the CVO is legally obliged to keep all of its information confidential unless the regulatory mandate of CVO requires disclosure.

For the purpose of carrying out its objects, the CVO has the authority to collect, use and disclose personal information. This Privacy Policy sets out the practices and safeguards for the personal information collected, used or disclosed by CVO. The CVO's Privacy Policy also describes how the CVO interprets its ability to disclose information as "required in connection with the administration" of the legislation as set out in section 38 of the Veterinarians Act.

The CVO acknowledges responsibility for personal information that it collects, uses and discloses and has designated one person to oversee and be accountable for the CVOs compliance with its Privacy Policy. As the CVO Privacy Officer, the Registrar is accountable to the Council of the CVO. The Privacy Officer can be reached at:

Registrar
The College of Veterinarians of Ontario
2106 Gordon Street, Guelph, Ontario N1L 1G6
Phone: (519) 824-5600
Toll Free: 1-800-424-2856 (Ontario Only)
Fax: (519) 824-6497
Toll Free Fax: 1-888-662-9479 (Ontario Only)
E-mail: scarlyle@cvo.org

The CVO collects personal information for the purpose of administering and enforcing the Veterinarians Act. The most common types of personal information collected and the primary reasons for its collection are set out below. Where possible, the CVO will try to advise individuals about the primary reasons for its collection unless to do so would interfere with the regulatory mandate of the CVO.

The CVO collects personal information about applicants for a licence, for reinstatement, for a certificate of accreditation and for a certificate of authorization. It does so in order to assess whether the applicants meet the requirements for the licence or certificate, to respond to reviews of such decisions, to communicate with applicants, to receive payments, to obtain information for subsequent regulatory purposes (e.g., quality assurance activities) and other related purposes. Examples of the information collected for these purposes include: name, contact information, academic qualifications, veterinary school and year of graduation, field of primary veterinary professional activity, employment function, type of employment, proof of employment at the University of Guelph (for academic license applicants), proof of acceptance into a graduate program at the Ontario Veterinary College (for educational or postgraduate and resident licence), an undertaking from a supervising member (for a short term licence applicant), examination results, work experience, photograph, languages spoken, social insurance number, (to enable sharing of information regarding licensure in other jurisdictions), good character and past conduct information, immigration or citizenship status and banking or credit card information. Previously the College collected the date of birth of applicants but has decided to stop doing so unless a significant regulatory reason for doing so arises.

The CVO collects personal information about veterinarians for a number of regulatory purposes including to communicate with them, to renew licences or certificates, to investigate allegations of professional misconduct, serious neglect or impairment, to investigate the unlawful practice of veterinary medicine or the unlawful holding out as a veterinarian by unlicensed persons, to maintain registers and directories, to investigate concerns about the CVOs operations, to receive payments, to process resignations and to seek the view of the profession. Examples of the information collected for these purposes include: name, contact information, conduct and practice information, names of partners and associates, views and opinions, field of primary veterinary professional activity, employment function, type of employment, interest in serving on committees or as mentors etc., choice of constituency (home or business address), hours of continuing education, and banking or credit card information.

Members of the profession and, less commonly, members of the public, serve on Council, committees and task forces. To support these valuable contributions the CVO collects personal information for the following purposes: to communicate with them, to hold elections, to schedule meetings, for considering their suitability to serve on committees or task forces, to avoid conflicts of interest, to accommodate their preferences (e.g., committee preferences, dietary restrictions), to make travel arrangements and to reimburse their expenses, for honouring service and for noting their opinions, votes and decisions (e.g., minutes of meetings).

Examples of the information collected for these purposes include: names, contact information, qualifications, areas of interest, preferences, photographs, accomplishments, attendance, performance, travel arrangements, scheduling information for meetings, expenses and opinions and views.

The CVO deals with members of the public when performing its regulatory activities. During these contacts, the CVO may collect personal information about them. Examples of some of the personal information collected and the reasons why include the following:

• as a source of information about applicants to the CVO (e.g., their conduct history) or existing licencees, etc. (e.g., about an allegation of professional misconduct)

• as a source of information about the unlawful practice of veterinary medicine or the unlawful holding out as a veterinarian by an unlicensed person

• incidental information to an investigation of a veterinarian or unlawful practice (e.g., as clients, animal owners and witnesses)

• to provide information requested by a person about the CVO and veterinarians (e.g., responding to telephone, letter and email inquiries)

• information related to public meetings at the CVO (e.g., a Council meeting, discipline hearing)

• to gather opinions and views about veterinary and regulatory issues

• to communicate with the government or other groups about veterinary issues, and

• for security reasons (e.g., visitors to our office).

The CVO uses electronic equipment in its operations. This results in the usual collection of personal information. The CVO tries to ensure that this collection is appropriate and as open as possible. Most of the collection is known by the person at the time (e.g., voice mail messages, emails sent to the CVO, court reporters or tape recorders at hearings or meetings, website forms filled out by visitors). Other forms of electronic collection are made known at the time (e.g., the CVOs website has its own Internet Privacy Policy). Other forms of electronic collection are made known in this Privacy Policy or upon request and are likely assumed by most individuals having contact with the CVO (e.g., the CVO has call display on some telephones, the CVOs long distance service provider details long distance calls made by CVO, and CVO cell phones may have automatic records of call details).

The purposes for this electronic collection of personal information include: ensuring the security of CVOs premises and records and databases, promoting responsiveness and accessibility of the CVO, helping CVOs staff to better do their jobs, accurate recording of important information and more responsive use of CVOs website.

The CVO collects personal information by fair and lawful means. The CVO obtains consent for the collection, use and disclosure of personal information whenever possible. For example, the CVO rarely collects personal information from an applicant until the applicant has initiated the registration process. Member surveys are optional.

In obtaining consent, the CVO uses reasonable efforts to ensure that an individual is told of the purposes for which personal information will be used or disclosed. These reasons for collection are set out in plain language. Generally, the CVO asks for consent to use and disclose personal information at the same time the CVO collects it.

The CVO will not require individuals to consent to the collection, use or disclosure of personal information, as a condition of licensure or service, unless this is required to fulfill the CVOs regulatory mandate.

In considering the appropriate form of consent, the CVO takes into account the sensitivity of the personal information and the reasonable expectations of individuals. For example, the CVO believes that express consent is not required for taking or publishing pictures of public CVO functions. However a personal profile of a veterinarian on the CVOs website or in the CVOs newsletter, Update, will normally occur only after consent has first been obtained. An individual may withdraw consent at any time unless a valid regulatory purpose would be compromised.

Where the consent of an individual or an action of an individual is required or authorized under this Privacy Policy, and the individual is incapable of giving the consent or taking the action, the CVO may accept the consent or action of a personal representative or other reasonable substitute for the individual.

However, obtaining the consent of the individual would, in some cases, defeat the CVO's regulatory purposes. Personal information will only be collected, used and disclosed without the knowledge and consent of the individual when necessary for the purpose of administrating the Veterinarians Act and related legislation. For example, the CVO has an obligation to verify applications for licences or certificates, even if the applicant does not consent. If the CVO investigates allegations of professional misconduct it cannot proceed only if the veterinarian consents. Sometimes the CVO cannot even state the purpose for collecting the information without jeopardizing the investigation or disclosing inappropriate personal information about the veterinarian.

The CVO may also use or disclose personal information without the knowledge and consent of the individual where the life, health or security of an individual is threatened. The CVO may also disclose personal information without the knowledge and consent of the individual to a lawyer representing CVO, to collect a debt, to comply with a subpoena, warrant or other court order or as may be otherwise required or authorized by law.

The CVO believes that in order for it to properly administer its legislation and achieve its public interest mandate, the public needs to have access to certain information about veterinarians. This will enable the public to choose a veterinarian for services, make employment decisions and to contact a veterinarian for professional purposes. For example, the public should have ready access to the following information about veterinarians: professional activity, University of graduation, year of graduation, year joined College, licence type, employment function and/or type of employment, address, conditions or limitations on a licence and any decision or sanctions imposed on a member's licence, business telephone number, if available, and language proficiency.

CVO staff is permitted to confirm the licence number of a member that has been provided to a third party.

The CVO tries to collect personal information directly from individuals unless there is a regulatory reason to collect the personal information from others. The CVO limits the collection of personal information to what is reasonably necessary for its identified purposes. The CVO collects personal information by fair and lawful means.

The CVO does not use or disclose personal information for purposes other than those for which it was collected with the consent of the individual, except to fulfill its regulatory mandate or as permitted or required by law.

Part of the CVOs regulatory mandate is to make available to the public certain information about its veterinarians. This enables members of the public to make an informed choice about which veterinarian they would choose to use and assists the public in following up with their veterinarian (e.g., if they move) and in dealing with any complaints or concerns. The CVO therefore maintains registers and directories of such information. For example, the CVO makes available to the public contact information about veterinarians, any terms and conditions on their licence and their discipline history.

The CVO maintains a high degree of openness in its regulatory processes. For example, its Council meetings and discipline hearings are open to the public. Personal information will sometimes be revealed in the course of maintaining this openness.

The CVO retains personal information only as long as is necessary to fulfill its purposes and has a records retention policy to facilitate this goal. The CVOs retention policy is based on the principle that the CVO will not retain a record of personal information after the purpose for which the CVO collected the information has been fulfilled unless,

1. another law requires or authorizes the CVO to retain the record,

2. the CVO reasonably requires the record for purposes related to its regulatory activities, or

3. the record is transferred to its archive for the purposes of permanent preservation or historical research.

Where personal information has been used to make a decision about an individual, the CVO retains the actual information considered to make the decision for a reasonable period of time.

The CVO shares relevant information about individuals with other regulators without obtaining consent. Such sharing of information is in the public interest and promotes a reciprocal sharing of information with the CVO. For example, sharing of information with other veterinary regulators for the purpose of discipline and enforcement is a well-established practice in North America. Also sharing of information with other veterinary regulators for the purpose of licensing is provided for in the Agreement on Mobility of Veterinarians within Canada.

The CVO makes its best effort to ensure that the personal information its collects, uses and discloses is accurate. The CVO updates personal information as appropriate to fulfill its regulatory purposes or upon notification of a change by the individual. The CVO requires veterinarians to routinely update their personal information. In order to be accountable for the handling of personal information, the CVO sometimes makes corrections to its records or databases without obliterating the original entry.

Principle 7:Safeguards

The CVO tries to ensure that its personal information is protected from unauthorized use or disclosure, unauthorized copying, modification or destruction. Reasonable steps depend upon the circumstances, including the sensitivity of the information, the amount of information and the format in which it is stored. The CVO safeguards personal information by physical measures (e.g., locks and keys), technological measures (e.g., limiting use of unencrypted email) and organizational measures (e.g., use of confidentiality agreements). These measures apply to both paper and electronic information.

The CVO protects personal information transferred to its agents and consultants (e.g., CVO's lawyers, accountants, IT consultants, external storage services) by obtaining appropriate privacy assurances about safeguarding the information and restricting the purposes for which it is to be used by them.

These safeguards are monitored by CVO's Privacy Officer.

The CVO permits access to personal information to an individual about themselves unless providing access could reasonably be expected to interfere with the administration of the Veterinarians Act or the CVO including:

1. access may reasonably interfere with a regulatory process of the CVO including an inquiry, investigation or hearing;

2. access may reasonably reveal a confidential source of information or otherwise breach a confidence that is reasonably necessary for the CVO to protect;

3. access may reasonably reveal personal information about another person that cannot be severed and who has not consented to the access;

4. access may reasonably interfere with the regulatory or enforcement activities of another statutory regulatory body or a law enforcement agency;

5. access may reasonably place the health or safety of a person or property at risk;

6. the personal information is not reasonably retrievable or access is reasonably available from another, more appropriate source;

7. access may reasonably reveal legally privileged information; or

8. access is prohibited by another Act.

The CVO permits individuals who have access to personal information about themselves to have the CVO correct statements of fact that are inaccurate or incomplete, unless making corrections could reasonably be expected to interfere with the administration of the Veterinarians Act. For example, correction requests can be declined in the following circumstances:

1. the person requesting the correction does not provide sufficient information to enable the CVO to assess the request to make the correction;

2. the fact that the statement was made, whether it is correct or not, is relevant to the regulatory activities of the CVO;

3. correction may reasonably interfere with a regulatory process of the CVO including an inquiry, investigation or hearing;

4. correction may reasonably interfere with the regulatory or enforcement activities of another statutory regulatory body or a law enforcement agency;

5. correction may alter an original document that belongs to someone else and will eventually be returned to that person; or

6. correction is prohibited by another Act.

Where the CVO agrees to correct a record of personal information, the correction may be made so as not to obliterate the original entry.

Where the CVO declines a request to correct a record of personal information, it shall file with the record any statement of disagreement of less than 500 words provided by the individual unless to do so is impractical or would reasonably interfere with the regulatory activities of the CVO.

Where the CVO agrees to correct a record of personal information or receives a statement of disagreement, the CVO shall provide written notice to every third party to whom the original record was provided within the previous 12 months unless to do so is impractical (e.g., website access) or would reasonably interfere with the regulatory activities of the CVO.

Individuals may obtain access to their individual files by contacting the CVO's Privacy Officer. If the individual is not satisfied with the Privacy Officer's response to their request for access and / or correction, he or she may have the decision reviewed by the Executive Committee in accordance with Principle 10.

Questions or concerns about CVO's compliance with this Privacy Policy should be sent to the Privacy Officer who can be reached at:

Registrar
The College of Veterinarians of Ontario
2106 Gordon Street, Guelph, Ontario N1L 1G6
Phone: (519) 824-5600
Toll Free: 1-800-424-2856 (Ontario Only)
Fax: (519) 824-6497
Toll Free Fax: 1-888-662-9479 (Ontario Only)
E-mail: scarlyle@cvo.org

1. The Privacy Officer shall investigate the complaint, prepare a written report of his or her findings and provide it to the person making the complaint and to the Executive Committee of the CVO.

2. The report shall be provided within 30 days of the complaint. If the Privacy Officer is unable to complete the report within 30 days, the Privacy Officer shall advise both the person making the complaint and the Executive Committee of the delay and the anticipated date of completion of the report.

3. If the person making the complaint disagrees with the report, he or she can ask the Executive Committee of the CVO to review and reconsider the report by filing a written request setting out the grounds for the request with the CVO. The Privacy Officer shall have 30 days to provide to the Executive Committee and the person making the request a response to the request. The Executive Committee shall review the written submissions and shall make a decision on behalf of the CVO. The decision of the Executive Committee is final.

4. If the report of the Privacy Officer recommends that certain action be taken by the CVO or, if there is a review and the Executive Committee directs that certain action be taken by the CVO, the Registrar shall report to the Executive Committee within 30 days, and at such other times as directed by the Executive Committee, as to whether the action has been taken.

Please note that there is a different process for handling complaints about the conduct of a veterinarian. Contact CVO's Registrar if you wish to file a complaint about the conduct of a veterinarian.

Since the CVO does not engage in commercial activities, it is not covered by the Personal Information Protection and Electronic Documents Act. The College has an overall accountability to the Ontario Minister of Agriculture and Food and, ultimately, to the Legislative Assembly of Ontario.

Unless the context suggests otherwise, the definitions in the Privacy of Personal Information Act apply to this Privacy Policy.

"CVO" means the College of Veterinarians of Ontario.

"Personal Information" means information about an identifiable individual, but does not include the business contact information of an employee of an organization. In addition, this Privacy Policy does not apply to personal information about employees of the CVO.

"Privacy Officer" means the Registrar of the CVO and any delegate acting on his or her behalf.

The College of Veterinarians of Ontario recognizes the importance of protecting the privacy of personal information. During a visit to our Web site, your privacy is respected.

Our Web site privacy policy is intended to permit you to make an informed decision when choosing to communicate with the College through this site.

We do not collect personal information about you unless you choose to send us an e-mail, in which you voluntarily provide your name and contact information.

The nature of the Internet is such that it passively and automatically collects certain information about a user's traffic patterns, linked to their Internet Protocol (IP) addresses. These are unique Internet addresses assigned to all Web users by their Internet Service Providers (ISP). IP addresses are automatically logged by Web servers. While the IP address does not obviously identify an individual on its face, it may with the co-operation of the ISP be used to locate and identify an individual using the Web. The IP address is considered personal information because it is an identifying number, and IP addresses are therefore protected by most privacy legislation. The privacy issues surrounding IP addresses are explained further below.

Site visitors' personal information received by e-mail is generally only used to respond to inquiries. Where the information is relevant to the Colleges regulatory activities it may be filed in an appropriate regulatory file. We protect all personal information in our custody with strong security safeguards, including a strict need-to-know policy for accessing personal information. The CVO does not share or sell this information to commercial organizations.

We may use IP address information; however, to personally identify you when necessary to protect and defend the rights or property of the CVO network and website or of visitors to our website, to identify individuals who may be violating the law or when required to do so by law.

Our Web site is hosted on servers owned and managed by a third party. The CVO has made inquiries and satisfied itself that this third party has high privacy standards and, to the best of our knowledge, complies with privacy law.

Our servers automatically log information about visits to our Web site in the normal course of establishing and maintaining Web connections. Server logs record statistical information, such as time and duration of visit, Web pages requested, and browser types. These statistics are reported in aggregate forms to our Web and communications staff, and are used to improve our Web site. This information does not personally identify you. We do not link server log information to any other data in a way that would enable us to identify individual visitors. This tracked information will not be used by any other organization.

Our site does not make use of cookies. Cookies are small text files often used on sites to keep track of your browser as you navigate a Web site.

Other sites to which we provide links may be governed by different policies. The CVO does not assume responsibility for the information practices of these other Web sites, and we encourage you to review the privacy policies and statements of all externally linked sites.

If you have any questions or concerns about this policy, please review the Colleges general privacy policy also posted on the Web site. In addition you may contact the College's Privacy Information Officer, who is also the Registrar of the College. You can contact the Privacy Officer at 519-824-5600, toll free at 1-800-424-2856, by e-mail at scarlyle@cvo.org.  Our postal address is 2106 Gordon Street, Guelph, ON N1L 1G6.