At Veritas IRB Inc., we are committed to providing sponsors, researchers and participants with exceptional service. As providing this service involves the collection, use and disclosure of some personal information, protecting their personal information is one of our highest priorities.
This Personal Information Protection Policy, in compliance with applicable privacy legislation, outlines the principles and practices we will follow in protecting clients’, customers’, members’, participants’ and visitors’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of collected personal information and allowing individuals to request access to, and correction of, their personal information.
We will inform individuals of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Scope of this Policy
This Personal Information Protection Policy applies to Veritas IRB Inc. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Veritas IRB Inc.
Personal Information – means information about an identifiable individual. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.
Privacy Officer – means the individual designated with the responsibility for ensuring that Veritas IRB Inc. complies with this policy and applicable privacy legislation.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the individual voluntarily provides his or her personal information for specific purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect personal information that is necessary to fulfill the following purposes:
- To verify identity;
- To verify creditworthiness;
- To identify client preferences;
- To understand the banking needs of our clients;
- To open and manage an account;
- To deliver requested products and services
- To ensure a high standard of service to our clients;
- To meet regulatory requirements;
- To collect and process payments;
- To assess the performance of the organization;
- To conduct quality assurance and quality improvement studies;
Policy 2 – Consent
2.1 We will obtain consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a person, is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the person does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for Veritas IRB Inc. to use their personal information in certain ways. An individual’s decision to withhold or withdraw his/her consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the individual in making the decision.
2.5 We may collect, use or disclose personal information without the individual’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual's life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as: To conduct client surveys in order to enhance the provision of our services; To contact our clients directly about products and services that may be of interest;
3.2 We will not use or disclose personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 We will retain personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that personal information is accurate and complete.
5.2 Individuals may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of collected personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that personal information is appropriately protected:
- the use of locked filing cabinets;
- physically securing offices where personal information is held;
- the use of user IDs;
- passwords, encryption & firewalls;
- restricting employee access to personal information as appropriate;
- contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying personal information such as shredding documents and deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Access to Personal Information
7.1 Individuals have a right to access their personal information, subject to limited exceptions such as solicitor-client privilege or disclosure that would reveal personal information about another individual
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell individuals how we use their personal information and to whom it has been disclosed, if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the individual in writing, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Veritas IRB Inc.’ compliance with this policy and applicable legislation.
8.2 Individuals should direct any complaints, concerns or questions regarding Veritas IRB’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Privacy Commissioner of Quebec.