Privacy and Communication
ONLINE PRIVACY AND SECURITY POLICY
Created/Last Revised: September 8, 2022
Introduction
The College of Opticians of Alberta (the “COA”) is committed to maintaining the accuracy, confidentiality and security of the personal information collected from members, applicants, public council representatives and employees.
The College of Opticians of Alberta (“COA”) Privacy and Security Policy (“Privacy Policy”) below is applicable to the following:
For the purpose of this policy, these sites collectively comprise the COA website (“the Website”).
The COA has established this Privacy Policy to advise you of the kinds of personal information we may gather during your visit to the Website, why we gather your information, what we use your personal information for, when we might disclose your personal information, and how you can manage your personal information.
Please be advised that the practices described in this Privacy Policy apply only to information gathered through the Website. This Privacy Policy does not necessarily reflect our practices with respect to information gathered through other means.
Accountability
The COA is committed to protecting all of the personal information that is shared with us. The Personal Information Protection Act (PIPA) is provincial legislation intended to protect the individuals submitting personal information to the COA. The policies and practices of the COA have been reviewed to ensure they meet the requirements of this legislation.
The COA has designated one person with the role and responsibilities of a Privacy Officer. The Officer is responsible for the COA’s compliance with privacy Legislation.
Terms and Conditions
By visiting the Website, you are accepting, without modification, this Privacy Policy. If you do not agree to any portion of this privacy policy, please exit the Website immediately.
We reserve the right to change, modify, add, or delete the terms of our Privacy Policy from time to time without further notice. Your continued use of the website following the posting of changes to this Privacy Policy means you agree to the new terms.
If we make material changes to this Privacy Policy, we will post the changes on this page and will indicate at the top of this page the date these terms were last revised. If we intend to apply the modifications or amendments to this Privacy Policy retroactively, we will provide you with notice of the modifications and amendments.
If you have any questions about this Privacy Policy or do not see your concerns addressed here, please contact us using the Privacy Officer contact information provided in the Contact Us section below.
Cookies and Analytics
Essential cookies are enabled for this Website. We do not receive any information from these cookies; they are there to assist you with your browsing experience. Without these cookies, the Website would not run as quickly or as smoothly for you.
You can delete cookies from your browser by clearing your cache (usually in the “history” section of your browser menu). Please be aware that when you clear your cache, the Website may run more slowly until new cookies are gathered.
We also use Google Analytics to bring us anonymized data about visitors to our site. We do not use the advertisement features of Google Analytics in any manner whatsoever.
Personal Information
The primary collection of applicant information is through registration and renewal. This information is used for determining eligibility for registration, as well as to perform other regulatory functions and provide membership benefits through COA.
The COA may use your personal information to provide services available through the Website, track your compliance with the site’s rules and regulations, or for editorial and feedback purposes (to the extent that is explained when you provide the information).
If the COA plans to publicly post any of your personal information on the Website (as for instance, a photo of you), you will be provided prior notification of such posting and given the option to accept or decline.
Personal Information may also be collected through other registration member services and may be used in aggregate, non-identifiable form. Under sections 33-34 of the Health Professions Act and Opticians Profession Regulations, the COA must maintain a register of individuals who are regulated by the COA. This information is not for or intended to be used for any other purpose, including marketing research.
Anonymous Information
Through your use of the Website, the COA may also gather certain information that does not identify you individually (“Anonymous Information”). Generally, this information is collected through “traffic data”. The COA collects and stores certain other information automatically whenever you interact with the Website.
For example, IP address, browser information, and reference site domain name are collected each time you visit the site. Information is also collected on user-traffic patterns and site usage. This information is used to analyze and improve the Website and to provide users with an accessible and useful experience.
The COA may use Anonymous Information to provide statistical “ratings” information in aggregated form to our partners and other third parties about how site users collectively use the website. We may also use or share Anonymous Information (or other information, other than Personal Information) in any other manner that is deemed appropriate or necessary.
Consent
The COA will limit the collection of personal information to those elements we require to meet our obligations. This information is collected by the COA during the application for initial registration and annual application for renewal of registration.
Contact and Personal Information is not shared with unaffiliated third parties except those we are satisfied are legitimately requesting the information (such as when required by law). Other uses of personal information will be identified either prior to or at the time the information is collected.
The COA will communicate verbally, electronically, or in writing for the primary purpose of collecting personal information outside of those uses listed above.
Spyware
The COA never uses or installs spyware on your computer, nor does the COA use spyware to retrieve information from your computer.
Subscription Communications
We may use the email address of all users who subscribe to any of our communications. Except to our third-party agents (as described below), this information is not shared with any third parties.
Anyone who no longer wishes to receive communications from the COA may, at any time, follow the “Unsubscribe” instructions located within each communication.
Children and Privacy
The COA does not collect any personal information from anyone known to be under the age of 13. If you are under the age of 13, you should use the Website only under the immediate supervision of a parent or guardian and should not submit any personal information to COA.
Third-Party Disclosure and Agents
Except as disclosed in this Privacy Policy, the COA does not use or disclose information about your individual visits to the Website or your personal information collected online to any companies not affiliated with us. If the COA proposes to permit any use of your personal information, you will be provided an opportunity to decline such contact.
The COA may occasionally have third-party agents, subsidiaries, affiliates, and partners that perform functions on our behalf, such as marketing, analytics, security, etc. These carefully selected entities may have access to the personal information needed to perform their functions and will be contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, distributing, or altering this data in any way other than to provide the requested services to the site.
Retention policies have been developed for the organization based on the relevant legislation.
Emergency Situations
The COA may also use or disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to applicable law or comply with legal process served on us or the Website, or (b) act under emergency circumstances to protect the personal safety of the COA, our affiliates, agents, or the users of the Website or the public.
Securing Personal Information
The COA shall not use or disclose personal information for purposes other than those identified in this policy unless express consent has been received or the disclosure is otherwise permitted or required by law or legislation.
Personal information collected by the Website is stored in secure operating environments that are not available to the public. Only those employees who need access to your personal information to do their jobs are allowed access. Any employee who violates our privacy and/or security policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.
To protect the security of your information during transmission, we use Secure Sockets Layer (SSL) software, which encrypts information you input. Most browsers will give a visual indication of when your connection is secure (for example, Internet Explorer will show a padlock icon in the lower right of the browser window).
The COA attempts to safeguard your personal information once we receive it. However, you understand and agree that no transmission of data over the internet or any other public network can be guaranteed as 100% secure.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job are granted access to personally identifiable information. We take precautions to safely dispose of any printed information once a transaction is complete, and do not share the information that you provide through the Website.
Linking to Other Sites
The COA may link to other websites not operated by the COA. The practices described in this Privacy Policy do not apply to information gathered through these other websites. These other sites may also send their own cookies to you, collect your data, or solicit your personal information.
The COA is not responsible for the actions and privacy policies of third parties and other websites. Be aware when you leave our site and read the privacy policy of each other website you visit.
The COA uses third party plugins to facilitate your online experience. By entering your contact information into the e-newsletter signup form (MailChimp) or browsing the Website with analytics (Google Analytics), you are agreeing to the privacy policies of each organization. The COA does not sell or lease your information.
Governing Law
The COA Website is published in Canada and is intended for users from Canada. This policy shall be governed and construed and enforced in accordance with the laws of the Province of Alberta with the Country of Canada.
Recently, the European Union passed the General Data Protection Regulation (GDPR) that websites need to provide informed consent for the use of cookies. Although we are a provincial regulatory body for Canadian citizens, we do have some international visitors to our site so you will be asked to agree to the use of cookies when you first access the site.
Your Alberta Access and Privacy Rights
Alberta’s Access and Privacy Legislation, the Personal Information Protection Act (PIPA), applies to the COA. PIPA came into force on 1 January 2004 and provides individuals with the right to request access to their own personal information while providing private sector organizations with a framework for conducting the collection, use, and disclosure of personal information.
The Office of the Information and Privacy Commissioner of Alberta (OIPC) is legislated to provide review and resolution of decisions made by organizations in response to access to information requests under PIPA.
Public Access to Information
When a member of the public asks for information about a regulated member and specifies the member by name, the COA must provide the following information:
- The member’s registration number;
- Any conditions imposed on the member’s practice permit
- Whether the member’s practice permit has been suspended, cancelled, or restricted to a specific time frame;
- The member’s practice specialization recognized by the college, if applicable;
- Whether or not the member is authorized to provide a restricted activity normally provided by regulated COA members; and
- Whether a disciplinary hearing is scheduled to be held or has been held.
- The member’s registration number;
Notification of Conditions on Practice Permits
If a member’s registration is suspended or cancelled or if conditions are imposed on it, the COA must notify:
- The registrant’s employer(s) (including anyone who employs the member as a consultant, contractor, or volunteer;
- The health authority where the member provides services;
- The hospital if the member is a member of the hospital’s professional staff;
- The Minister of Health or any organization that administers the payment of fees for the professional services the registrant provides;
- Another health professional college if the Registrar knows the regulated member is also a member of the other college; and
- The governing bodies of any similar profession in other provinces or territories in Canada.
If after a review or appeal, a cancellation or suspension is lifted or imposed conditions are varied or removed, the COA will notify the same parties.
How to Access and/or Correct Personal Information for Accuracy
If you wish to verify, correct, or update any of your personal information, you may contact the Registration department. Additionally, you may contact the Privacy Officer via the contact information provided in the Contact Us section below.
It is important to note that an individual may challenge the accuracy and completeness of their personal information that the COA has in its custody and control and may request a correction form to request to have it amended if appropriate.
To obtain the date of a disciplinary hearing, a member of the public may call during business hours, name the regulated member whose hearing they wish to attend, and if there is a scheduled date the information will be provided.
To obtain a copy of a decision of a hearing tribunal and/or a transcript of the testimony given before the hearing tribunal, a member of the public must submit a request in writing to COA and pay the administration and reproduction costs. The request must be submitted within five (5) years of the date of the disciplinary hearing to which it related. A record will be kept of the member of the public who receive the information.
Transparency
The COA will share information on the policies and procedures that apply to the management of personal information when requested by any member of the public.
Policy Revisions
Sep 8/22: Public Directory and Registrant Portal links updated. Policy name updated from “Website Privacy and Security Policy” to “Online Privacy and Security Policy.”
Contact Us
If you have any questions or concerns about the Privacy Policy for this Website or its implementation, please contact the COA’s Privacy Officer.
Tammy Kohut
CEO and Registrar
587.760.1884
ceo@albertaopticians.ca
The Alberta Office of the Information and Privacy Commissioner
10, 9925 109 Street
Edmonton AB T5K 2J8
Need Help Creating Your Own Website’s Privacy Policy?
Contact Rustruct Consulting: info@rustructconsulting.com
SOCIAL MEDIA POLICY
Created/Last Revised: January 1, 2022
Introduction
The College of Opticians of Alberta (the “COA”) has adopted a social media policy to guide communications by and with the COA. The intent of this policy is to establish guidelines for social media usage by the COA’s employees, volunteers, and contractors, and for the public to engage with the COA using social media.
Definitions
Social media refers to a variety of online communities that facilitate organizational communication and engagement with the public. Social media platforms and channels are the tools used to support this communication and engagement. The COA’s social media channels include Facebook, LinkedIn, Twitter, and YouTube. For the purposes of this document, “user” will refer to employees, volunteers, and contractors using social media on behalf of the COA.
Guiding Principles
In addition to the COA’s values of accountability, ethicality, fairness, effectiveness, openness, and transparency, the COA uses the following principles to guide employee, volunteer, and contractor social media usage:
- Disclose: Users must identify themselves (or the COA) in each social media post to ensure transparency and accountability in external communications.
- Protect: Users must take extra care to protect their own reputation and the reputation of the COA.
- Use Common Sense: Users must always communicate professionally and ethically.
Use of Official Accounts
The COA’s CEO and Registrar will have executive oversight of the organization’s social media accounts and will delegate the use of social media to employees as appropriate. Access to the COA’s official social media accounts will be limited to designated employee(s).
The COA’s social media usage shall comply with relevant laws and regulations, including privacy, copyright, anti-spam, and defamation legislation. The COA’s social media usage shall also embody the spirit of the COA’s commitment to providing an inclusive and welcoming environment for the public, registrants, volunteers, staff, and other stakeholders. Employees who are managing the COA’s social media accounts shall adhere to the following principles:
- Be respectful, polite, and patient.
- Avoid speaking on matters outside of the employee’s field of expertise without first consulting expert advice (e.g., legal counsel).
- Adhere to all COA regulations and policies.
- Seek approval from the CEO and Registrar before sharing information that impacts the COA’s operations and reputation.
- Avoid deleting or ignoring comments from the public.
- Wherever possible, respond with appropriate information or request that the commentor contact the COA for support.
- Exceptions to this principle may include hate speech, obscene content, or defamation, which should be referred to the CEO and Registrar for review against the COA’s anti-bias and anti-discrimination policy and relevant law.
- If a comment is deleted due to a contravention of the COA’s policy or relevant legislation, the COA will be transparent about this decision and will post a comment indicating that the post was deleted for this reason.
- Ensure that no information shared is defamatory.
- Immediately correct or remove any misleading or false content as quickly as possible and include notification of the correction as needed.
Prohibited Behavior
Employees shall use social media with the understanding that even personal use can negatively impact the COA. Therefore, the COA forbids its employees from using social media in any manner and at any time, whether personal or professional, that can cause harm to COA, its employees, volunteers, registrants, other stakeholders, and the public.
As such, the COA expressly forbids:
- Plagiarized content
- Inappropriate jokes
- Derogatory comments
- Defamatory and inflammatory comments or obscenity
- Offensive images
- Images or content to which the COA has no rights
- Discriminatory remarks and hate speech
- Content that infringes on privacy rights and legislation
Respecting Confidentiality
While transparency and openness are considered important values inherent in the COA’s operations, employees are still required to respect the organization’s sensitivities.
Staff members must respect their employee confidentiality agreements and may not share information that includes confidential information about the COA, protected information about employees, volunteers, registrants, or other stakeholders. This applies to both personal and corporate social media use.
Security
To ensure the COA’s social media channels remain safe, all passwords must be changed every 90 days.
Monitoring, Enforcement, and Discipline
The COA’s social media use shall be monitored regularly by the CEO and Registrar and any staff designated to manage social media channels.
Violating the COA’s social media policy may result in disciplinary action, ranging from a cautionary reminder to for-cause termination depending on the severity of the violation.
Disclaimers
No employee may speak on behalf of the COA unless they are an authorized spokesperson. This includes the use of social media.
In accordance with Council policy, the President is the authorized spokesperson for the COA and may delegate representation of the COA to the CEO and Registrar as needed. When the President or the CEO and Registrar speak on behalf of the COA, they must do so in accordance with Council policy and in alignment with decisions made by the COA Council as a whole.
All employees and Council members who are publicly recognized as being affiliated with the COA are urged to include a disclaimer in their personal social media accounts stating that their comments are theirs alone.
Social Media Terms of Use
The COA appreciates and is thankful for the public who engage with us via social media. The use of our social media channels is subject to these terms and conditions:
We are committed to providing accurate content about the COA and encourage open and respectful dialogue.
We, the COA, reserve all rights relating to our social media channels, including but not limited to:
a. adding, removing, or modifying any content,
b. (ii) blocking disruptive users; and (iii)
c. discontinuing any of our social media channels at any time.
Periodically we may post information on our social media channels from key stakeholders when that information may be relevant to optical care and regulation in Alberta. Information of this nature does not necessarily represent the COA’s views and opinions. The COA will make every effort to ensure, but cannot guarantee, that information from key stakeholders shared on our social media channels is accurate, complete, reliable, useful, timely, and current.
The COA may, in its sole discretion, delete irresponsible content or content that is otherwise inconsistent with the purpose of the COA, and we reserve the right to block any user who fails to follow these Terms of Use.
Examples of inappropriate or off-topic messages include, but are not limited to, the following:
- Defamatory, obscene, discriminatory, harassing, abusive, vulgar, sexually explicit, inappropriate with respect to race, gender, sexuality, ethnicity, other intrinsic characteristic, or religion, threatening comments, or hate propaganda;
- Calls to violence of any kind;
- Activity that violates any law or regulation;
- Spam directed at the COA including any form of automatically generated content or repeatedly posting the same content;
- Any potential infringement upon any intellectual property rights;
- Content posted by fake or anonymous users.
The COA appreciates your understanding of and agreement with our terms and conditions.
Adding Social Media Accounts
The COA may, at its discretion, add or remove social media channels. Any change in social media channels does not affect this social media policy.
Maintaining Relevance
The COA shall review this social media policy annually or as the need arises. Any changes will be communicated to all affected parties as required.
Contact Information
If you have questions, comments, or complaints concerning our social media usage, please contact:
Tammy Kohut
CEO and Registrar
587.760.1884
ceo@albertaopticians.ca