PRIVACY POLICY
Santana Behavioural Services., its subsidiaries and affiliates ("Santana", “we”, “us”) respect your privacy and consider it to be an important part of providing you with quality care. This "Privacy Policy" summarizes what personal information we collect, and how we use and disclose this information of our clients (“you”).
By using our Services, you signify your consent to the terms of our Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Services or submit any personal information to us.
We shall ensure that, in providing the Services hereunder, Santana will collect, use, maintain, disclose and destroy all personal information of about you or your child (together, our “Client”) and others dealing with the Client in accordance with all applicable privacy laws and regulations, specifically the Personal Health Information Protection Act, 2004 (“PHIPA”) and the Personal Information Protection and Electronic Documents Act, (“PIPEDA” and together with PHIPA, the “Privacy Acts”).
We reserve the right to modify this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy on our website. Your continued use of our Services will be regarded as acceptance of our practices around privacy and personal information including but not limited to this Privacy Policy, as revised. You should check this Privacy Policy regularly to review any changes.
What Personal Information We Collect and How We Collect Personal Information
Personal information is information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person (“Personal Information”). We collect Personal Information when you voluntarily provide it to us through various means, including but not limited to: email, telephone, mail; or other correspondence; registering for our Services; or filling in forms as part of the Services. We may also collect information when you file reports, documents and/or otherwise provide information to us. We may further collect information from records and copies of your correspondence, if you contact us.
We ensure that we only collect necessary information about our Client and store, retain, and destroy, Personal Information in compliance with applicable Privacy Acts. Further, Santana ensures that our privacy protocols comply with the standards of our credentialing body, the Behavior Analysis Certification Board (the “Board”).
The Personal Information we may collect will depend on the particulars of the Service, and may include your and/or your child’s full name, contact information, such as your address, telephone number, or email address; any other Personal Information that you choose to submit to us.
How We Use and Disclose Personal Information
The Personal Information we collect may be used by us for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to you and to which you consent. Santana may collect, use and disclose Personal Information about our Clients for the following, but not exclusive, reasons:
To deliver safe and efficient care;
To identify and to ensure continuous high quality service;
To enable us to contact you;
To establish and maintain communication with you;
To offer and provide treatment, care and services in relationship the practice of Applied Behaviour Analysis;
To communicate with other treating health-care providers, including specialists;
To allow us to maintain communication and contact with you to distribute health-care information and to book and confirm appointments;
To allow us to efficiently follow-up for treatment, care, and billing;
To comply with legal and regulatory requirements, including the delivery of clients' records to the Board in a timely fashion, when required, according to the provisions of Privacy Acts;
To comply with agreements/undertakings entered into voluntarily with the Board, including the delivery and/or review of clients' records to the Board in a timely fashion for credentialing and monitoring purposes;
To prepare material for the Board reviews;
To invoice for goods and services;
To process credit card payments;
To collect unpaid accounts;
To assist this office to comply with all regulatory requirements; and
To comply generally with the law.
We may also disclose Personal Information: (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law; (ii) to enforce or apply our Privacy Policy and other agreements; and (iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Santana, our Clients, or others. Such disclosure may include that to the Children’s Aid Society or other similar agency if there is suspicion of a child or vulnerable person being at risk or in need of protection.
Where we disclose Personal Information to third parties that perform services on our behalf, we will require those third parties to use such information solely for the purposes of providing services to us and to have appropriate safeguards for the protection of that Personal Information. Nothing herein shall be deemed to govern Personal Information with third parties that provide content and/or offerings to you. If you agree to provide such information to these third parties, then your Personal Information will be subject to their privacy policies in addition to our own.
We may disclose your Personal Information to a third party or parties where you consent to such disclosure or the disclosure is required by law. Some or all of the Personal Information we collect may be stored or processed in jurisdictions outside of Canada, including the United States. As a result, this information may be subject to access requests and legal requirements from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
We reserve the right to transfer Personal Information in the event that we merge with or are acquired by a third party. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.
Transferring Your Personal Information
We may transfer Personal Information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our Services. To the extent possible, we will obligate such businesses to use this information only for the purposes for which we disclose it to them and to process the Personal Information with the same standards set out in this policy.
We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country.
By submitting your Personal Information or engaging our Services, you consent to this transfer, storage, or processing.
How We Protect Personal Information
We protect your Personal Information by maintaining physical, organizational and technological safeguards appropriate to the sensitivity of such Personal Information. Personal Information may only be accessed by persons within or under contract with our organization and who require such access. Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted via electronic means. Any transmission of Personal Information is at Client’s own risk.
We retain Personal Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements. We destroy Personal Information in accordance with Board regulations and Privacy Acts.
Access and Rectification
The Client has a right to access their Personal Information and to request a correction to it if you believe it is inaccurate. We will provide you with access to your Personal Information that is in our possession, subject to certain exceptions, including information that is referenced to another individual’s personal information that we cannot sever, or information subject to legal restrictions that may prevent us from fulfilling your request. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below.
Changes to This Privacy Policy
Santana reserves the right to modify our Privacy Policy at any time, so please review it from time to time. If we make significant changes to this policy, we will notify you here, by email, or by a notice on our website, so you continue to be aware of the information we collect, how we use it, and under what circumstances we disclose it.
Withdrawing Consent
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the contact information below. Please note that if you withdraw your consent we may not be able to provide you with use of our Services.
Unsubscribe
If you no longer wish to receive electronic messages from Santana, you may unsubscribe in the “unsubscribe” link in the e-mail you receive, or contact us at the information listed in this Privacy Policy. Please note that, after you unsubscribe, Santana may still send electronic communications to you in certain limited circumstances, such as to provide you with Services notification, or to provide information that Santana is legally obligated to provide you.
How to Contact Us
If you have any questions regarding this Privacy Policy, or to access your information, please contact our Privacy Officer at:
Name: Jaime Santana