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PURPOSE:
 To establish and document a policy which defines Voyago (VTS) commitment to the protection of an individual’s personal health information in the course of providing our transportation services and in accordance with Personal Health Information Protection Act (PHIPA) and Personal Information Protection and Electronic Documents Act (PIPEDA).

SCOPE:
This policy is effective at all VTS facilities, locations and anywhere business is conducted.

DEFINITIONS:
VTS – refers to Voyago and all of its divisions and locations and subsidiaries including Checker Limousine and Voyago Medical Transportation Services.

PIPEDA –  The Personal Information Protection and Electronic Documents Act

PHIPA – Personal Health Information Protection Act

Personal Health Information – Personal health information includes oral or written information about the individual, if the information relates to the individual’s physical or mental health, including family health history; relates to the provision of health care, including the identification of persons providing care; is a plan of service for individuals requiring long-term care; relates to payment or eligibility for health care; relates to the donation of body parts or bodily substances or is derived from the testing or examination of such parts or substances; is the individual’s health number, or identifies an individual’s substitute decision maker.

Independent Contractor – refers to an Independent Contractor and Employees thereof.


POLICY: 


Accountability
VTS is responsible for personal health information in its possession or custody and has designated a Privacy Officer to oversee compliance to the Corporate Policy and Procedures.  VTS will not share or transfer information to a third party.

Identifying Purpose for Collection of Customer Information
VTS will identify the purposes for which personal health information is collected at or before the time the information is collected.  Depending on the sensitivity of the information, the purpose may be stated orally or in writing.

Obtaining Consent
The individual’s consent will be obtained for collection, use or disclosure of their personal health information, except where required by law. VTS collects personal health information for the purposes of providing transportation of individuals, in addition to accounting, administration and management of transportation services.  When personal health information is disclosed by a health information custodian, such as hospitals or schools, an individual’s consent is implied for the purpose of providing our services within their circle of care. Persons collecting personal health information will be able to explain to individuals the purpose for which the information is collected.

Limiting Collection of Personal Information
Personal health information collected shall be limited to that which is necessary for the purposes identified by VTS, or as otherwise permitted by law.

Limiting Use, Disclosure and Retention of Personal Information
VTS will not use or disclose personal health information for purposes other than the identified purposes for which it was collected, except with the consent of the individual or as required by law.  VTS will retain personal health information only for as long as necessary to fulfill the identified purpose.  VTS will ensure personal health information is protected during disposal or destruction to prevent unauthorized parties from gaining access to the information.  VTS will dispose of or cause destruction of the information using the most appropriate methods.

Accuracy of Personal Information
The personal health information kept shall be as accurate, complete and up-to-date as is necessary for the purpose for which it is to be used.  VTS relies upon its customers to notify it of any changes or corrections to their personal health information through the access provisions of this privacy policy.

Security and Safeguards
Personal health information shall be protected using various methods that are appropriate to the sensitivity levels of information:

Physical restrictions include locked filing cabinets, controlling physical access to documents, and securing technological equipment from theft or damage.
Technological controls includes use of passwords, automatic screen savers during computer inactivity, storing information on secure servers, installing firewalls, and the installation of anti-virus software
Organizational controls include confidentiality agreements, termination processes (such as changing passcodes, locks and passwords), reviewing and updating policies as required, ensuring staff are well training on privacy regulations, and promoting privacy as part of the VTS culture

The security safeguards will protect personal health information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.  VTS will protect personal health information regardless of the format in which it is held.  VTS will ensure personal health information is protected during disposal or destruction to prevent unauthorized parties from gaining access to the information. VTS will dispose of or cause destruction of the information using the most appropriate methods.

Openness Concerning Policies and Practices
Information will be available to individuals about our policies and procedures relating to the management of personal health information under the company’s control without unreasonable effort.  The information may be available in a variety of ways such as on-line access or brochures.

Individual Access of Personal Information
Upon written request to VTS’ Privacy Officer, an individual will be informed of the existence, use and disclosure of his personal health information that is under the company’s care and control as required and permitted by law.  Individuals are entitled to challenge the accuracy and completeness of their personal health information and request that it be amended, which VTS shall amend once confirming the accuracy of the new information and where such amendment is appropriate in the circumstances.

Handling Inquiries or Complaints
Any questions or inquiries concerning compliance with our privacy policies and procedures may be addressed to:
Catherine McBride, Privacy Officer
Voyageur Transportation Services, 
573 Admiral Court, London, Ontario, N5V 4L3, 
Phone: 519-455-4579 Ext. 280 
E-mail: catherine@voyageurtransportation.ca


5.0    RESPONSIBILITY:
It is the responsibility of all Company personnel, Independent Contractors and suppliers to adhere to this policy.
It is the responsibility of all Company personnel, Independent Contractors and suppliers to maintain the confidentiality and security of all personal health information to which they have access in accordance with Provincial and Federal laws.
It is the responsibility of the Privacy Officer to monitor Company-wide application of this policy and compliance with applicable Provincial and Federal laws.
It is the responsibility of each manager for ensuring this policy is adhered to within their respective centres.

Reference:      Privacy of Personal Information (VTS-111)
        


Revision Log

Rev. Level
Rev. Date
Description of Change
1
01/01/2014
Change Date
2
04/22/2014
Added some definitions, responsibilities, changed Privacy Officer’s name, and minor wording changes  
3
01/01/2015
Review policy and change date

01/01/2016
Change Date 
5
01/01/2017
Review Policy, Change Date, Introduce Voyago
6
01/01/2018
Review Policy, Change Date
7
01/01/2019
Review Policy and Change Date