Privacy Statement

The Regional Animal Protection Society (RAPS) is a registered charity that operates the full-service RAPS Animal Hospital. RAPS is committed to protecting your personal privacy in accordance with the Freedom of Information and Protection of Privacy Act R.S.B.C. 1996, c. 165 and the Personal Information Protection Act S.B.C. 2003, c. 63.  If you have any questions about RAPS privacy practices, please contact RAPS by email at [email protected] or by mail at 201-13340 Smallwood Place, Richmond, BC V6V 1W8.  
 
What is personal information?
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Age, name, ID numbers, government ID, income, ethnic origin;
• Opinions, evaluations, and comments; and
• Employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, and intentions (for example, to acquire goods or services).

How do veterinarians collect personal information?
There are a variety of ways in which veterinarians collect personal information during regular business practice, the most common being the creation and updating of animal medical records. Other examples include electronic communications, Client surveys, and payment collection services. The information collected is to identify both the Client (the person) and the patient (the animal). RAPS collects information it deems necessary for the proper operations of the hospital and the Client agrees to the collection of this information.

What conversations should veterinarians be having with Clients regarding personal information?
RAPS obtains Client consent when they collect, use or disclose any personal information. Personal information can only be used for the purposes for which it was collected. RAPS does not use personal information except for the purposes of the Client and for legal regulatory purpose if required (example: to deal with the CVBC). 

Third-party service providers?
RAPS does not use private Client information with third party services except for medical purposes, which the Client automatically approves when admitting the patient to the hospital. This includes sharing some information with third party medical suppliers for diagnostics, x-rays, ultrasounds and other tests which require the sharing of information with third parties. Clients agree that RAPS may contact them using the personal information.

RAPS also partners with third-party service providers for electronic medical records storage and other practice management related purposes. When contracting these services, RAPS is responsible for ensuring that the third-party service provider upholds the same level of privacy protection expected required by law. RAPS utilizes industry professionals for the safeguard and protection of electronic information. 

What is considered a breach of privacy of personal information?
A breach of security safeguards is defined as: the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards. 

What are veterinarians expected to do if there as a breach of privacy of information?
Private sector and not for profit organizations, including accredited veterinary facilities like the RAPS Animal Hospital, are required to report to the Privacy Commissioner of Canada any breaches of security systems involving personal information (e.g. hacking, stolen hard drives, malware software, etc.)  that pose a real risk of significant harm to individuals. They are also required to notify the affected individuals about those breaches and to keep records of all breaches for a period of two years.

Is all information contained in an animal’s medical record considered personal information?
While not all information contained in an animal’s medical record is considered personal information it is professional misconduct to reveal:
information concerning a Client, an animal or any professional service performed for an animal, to any person other than the Client or another member treating the animal except,

1. with the consent of the Client (please see RAPS Animal Hospital Admission Form and other forms which provide consent by the Client in some instances),
2. if required or authorized to do so by law,
3. to prevent, or contribute information for the treatment of, a disease or physical injury of a person, or
4. for the purpose of identifying, locating or notifying the apparent owner of the animal, protecting the rights of the apparent owner or enforcing applicable laws in respect of the animal, where it appears that the animal is not owned by the person presenting it for treatment.
   
   

Given this, all information contained in an animal’s medical record is subject to confidentiality and requires informed Client consent before it can be disclosed. Please see RAPS Animal Hospital Admission Form which provides consent in some instances.
 
Electronic Surveillance (Media) Waiver
With the permission of the Client when signing the RAPS Animal Hospital Admission Form, RAPS sometimes takes video or pictures of Hospital guests and procedures on animals for educational purposes and to demonstrate the capabilities of the RAPS Animal Hospital and to garner good will from the public. The RAPS Hospital premises are under twenty-four video, audio and recording surveillance. By signing the admission agreement, Clients authorize any images or video footage taken of themselves and their animal(s), in whole or in part, individually or in conjunction with other images and video footage, to be displayed by RAPS on all of RAPS’ official channels, in the hospital and to be used for media purposes including promotional presentations and marketing campaigns, including social media sites, media sites, print and electronic mediums without any further authorization from the Client beyond the signed admission agreement. RAPS will use the information without identifying Clients or animals unless provided consent by the Client to do so. The Client agrees that all captured video and recordings can and will be used, at RAPS’ sole discretion, in any conflict resolution or legal proceedings related to their hospital visit. The Client waives rights to privacy and compensation, which they may have in connection with such use of their likeness, including rights to written copy that may or will be created in connection with video production, editing and promotion therewith. The Client agrees that RAPS may use these images or video files to promote hospital procedures, practices and to inform the public about RAPS and the RAPS Animal Hospital.