Connect Hearing is committed to ensuring your personal information remains private. We know health issues are private and need to be treated with the same level of confidentiality as matters between doctor and patient.
As a hearing health care provider, we strictly adhere to and are committed to confidentiality with regard to the health and personal information we may gather in providing services to our customers.
Connect Hearing is responsible for personal information under its control, including the personal information it entrusts to third party service providers. To comply with BC’s Personal Information Protection Act (PIPA), we have a Privacy Officer to receive and respond to our customers’ questions and complaints and to respond to requests for personal files and correction of personal information.
When given permission by you, we will provide hearing health care information only to your physician(s) if requested by you. Each employee of Connect Hearing must sign a Confidentiality Agreement as a condition of their employment. Each employee is responsible for maintaining the confidentiality of personal information they may have access to.
Our Privacy Promise relates to all of our customers and applies to:
1. how we collect and use personal information
2. when we may provide your information to other persons
3. how we protect your personal information
4. how you have access to the information we retain, and
5. how we respond to your privacy questions or concerns.
What is a customer?
For the purposes of this Promise, we define a “customer” as any person who meets with any of our hearing health care professionals and/or any person who purchases any of our hearing health care products or services.
Why we ask for your information
The better we know you, the better we are able to serve you. We ask you for your personal information in order to:
• understand your needs
• determine the best products and services for you
• make appropriate appointments with our hearing health care providers
• provide you with information and offers on products and services we think may be of interest to you
• respond to your inquiries regarding warranties, assistive listening devices and our services, and to
• contact you to ensure you are satisfied with our products and/or services.
The nature of personal information we collect may include:
• information we receive from you on our forms, such as name, date of birth, gender, address and telephone number
• Information we receive from you on a voluntary basis when we are conducting an assessment of your lifestyle, needs or interests, and
• information regarding your hearing health and hearing aid purchases.
How we obtain your personal information
Our personal information about you comes from you. We may ask you for authorization to obtain certain types of personal information. We request only the information that allows us to serve you better.
How we protect your personal information
We do not disclose customer personal or demographic information to third parties except where and as required or permitted by law.
We protect your personal information that is in our possession, including that which has been received from a third party or personal information that may not be in our possession but which has been transferred to a third party.
Do you have access to your personal information?
Of course. We will establish and maintain a confidential file of personal information, both paper and electronic, for each customer. Only our employees who need to access your file in the course of their duties will have access to your information. You have the right to access your file and request rectification of any personal information in the file that may be obsolete, incomplete or incorrect.
We want to make this as simple as possible for you. You can obtain the ‘Customer Access to Personal Information Request’ form from us by requesting it in person, in a letter or by telephone. We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to that information. We may charge you an administration fee for providing access to your file in accordance with your request. Normally, we will respond to access or rectification requests within 30 days. Should you wish to review your personal information at any time, or find out to whom it has been disclosed to as permitted by this Policy, simply ask one of our hearing health care professionals for a Customer Access to Personal Information Request form. A nominal fee may apply and you will be advised in advance of the amount of the fee.
In some cases, we will not be able to provide the information we hold about you. That will only occur if:
• it contains references to other persons
• it is subject to solicitor-client or litigation privilege
• it contains our own proprietary information that is confidential to us
• it has already been destroyed due to legal requirements or because we no longer needed it for the purposes set out in our Promise
• it is too costly, in our determination, to retrieve
• it cannot be disclosed for legal reasons.
Is your personal information up to date?
You play an active role in keeping us up-to-date. Should your address or phone number change, for instance, we would appreciate it if you would let us know so that we can provide you with the best service possible.
Would we release your personal information?
We do not disclose customer personal or demographic information to third parties except where and as required or permitted by law. We do not sell personal information about our customers. (We do not share personal information with) (any of the companies that we do business with, for the purposes of marketing or for any other reason)
In common with many other organizations, we obtain some services from third party service providers, such as hearing aid manufacturers, and some of our information may be provided to them on a limited basis. These service providers must sign a confidentiality agreement and may only use the information disclosed to them for the specific purpose mentioned in the agreement.
From time to time, we may use a third party service provider that is located outside Canada to process or store personal information. In cases where we use a service provider outside Canada, our confidentiality agreement requires that the service provider meet our standards for maintaining the security of the information. However, where personal information is stored outside of Canada (e.g. the United States), it may be subject to the laws of that country and a confidentiality agreement cannot override those laws. Similar to Canadian law, law enforcement agencies in the U.S. may obtain access to Personal Information but only where access is permitted by U.S. or Canadian law. Confidentiality and the security of information are key considerations for us before we engage any third party service provider, whether inside and outside Canada.
Keeping your personal information confidential
We have comprehensive security controls to protect against unauthorized review and use of your personal information. We ensure the physical, organizational and electronic security of your personal information through the use of secure locks on filing cabinets and doors, restricted access to our information processing and storage areas, limited access to relevant information by authorized employees only, and through the use of passwords and the encryption of electronically transmitted information.
How long do we keep personal information?
We only keep your personal information during the time it is required to serve you or while there are legal requirements to do so. When destroying, deleting or disposing personal information, we have strict procedures in place to prevent unauthorized access.
We will occasionally communicate with you by mail, telephone or electronic means to offer you products or services that may be of interest to you. You may withdraw your consent to be contacted at any time as long as you give us reasonable notice of withdrawal.
Your consent to the collection, use or disclosure of your personal information can be express and positive (may be verbal, in writing or electronic) or implied, such as by using one of our products or services, or by not responding to our offer to remove your personal information from our contact list, in which case we assume your consent. Again, you may withdraw or refuse your consent at any time for any purpose whatsoever, as long as you give us reasonable notice of withdrawal.
Addressing your concerns
Please write us at the address in this document to file a privacy complaint. Should we fail to resolve a complaint to your satisfaction or within a reasonable delay, you may contact our CEO, Craig Cameron.
To file an opt-out request, request access to your information, report incorrect information or file a complaint, please write to:
309 – 645 Fort Street
Victoria, BC V8W 1G2.
Our Privacy Promise
While information is the cornerstone of our ability to provide superior services, our most important asset is our customers’ trust. Keeping customer information secure and using it only as our customers would want us to is a top priority. The following is our promise to our customers.
1. We will safeguard, according to strict standards of security and confidentiality, any and all information our customers share with us.
2. We will limit the collection and use of customer information to the minimum we require to deliver superior service to our customers, which includes advising our customers about our products, services and other opportunities, and to administer our business.
3. We will permit only authorized employees, who are trained in the proper handling of customer information, to have access to that information. Employees who violate our Privacy Promise will be subject to our disciplinary process.
4. We will not reveal customer information to any external organization unless we have previously informed the customer in disclosures or agreement, have been authorized by the customer, or are required by law.
5. We will always maintain control over the confidentiality of our customer information. If we share limited information with hearing aid manufacturers, they must have signed a confidentiality agreement with Connect Hearing.
6. We will tell customers how they may remove their names from our contact lists. At any time, customers can contact us to remove their names from such lists.
7. Whenever we hire other organizations to provide support services, we will require them to conform to our privacy standards and to allow us to audit them for compliance.
8. We will not use or share – internally or externally – personally identifiable medical information for any purpose other than the administration of a customer’s policy, claim or account, or as disclosed to the customer when the information is collected, or to which the customer consents.
9. We will attempt to keep customer files complete, up-to-date and accurate. We will tell our customers how and where to conveniently access their information (except where we’re prohibited by law) and how to notify us about errors which we will promptly correct.
We will continuously assess ourselves to ensure that customer privacy is respected. We will conduct our business in a manner that fulfills our Promise in the many provinces in which we do business.
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