Member Privacy Policy

LAST UPDATED: March 2024

At the Natural Health Practitioners of Canada Association ("NHPCA"), your privacy is of great importance to us. The NHPCA is dedicated to the protection of the personal information of applicants and members of the Association. In this policy, "you" refers to an NHPCA member.

Policy Contents:

1. Accountability for Your Privacy
2. Personal Information and How We Collect It
3. Obtaining Your Consent
4. Purposes for Collecting and Using Your Information
5. Sharing Your Information
6. Keeping Your Information Safe
7. Accessing Your Personal Information
8. How Long We Keep Your Information
9. Our Privacy Complaint and Breach Management Process
10. Cookies and Website Log Data
11. Social Media, Chat Rooms, and Discussion Forums
12. External Links
13. Changes to this Policy
14. Getting in Touch

1. Accountability for Your Privacy

The NHPCA takes full responsibility for the management and confidentiality of members' personal information. Personal information is collected, used, shared, and stored in accordance with the all applicable privacy laws that apply to the NHPCA, as well as the best practice principles contained in the Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96.

The NHPCA has appointed a Privacy Officer who oversees compliance with privacy laws and best practice. The Privacy Officer's duties include:

• developing and, on a regular basis, reviewing NHPCA policies and practices to ensure consistent implementation and compliance
• ensuring all staff are trained on privacy best practices and are aware of the importance of safeguarding any personal information that they are privy to
• ensuring that all inquiries and complaints relating to privacy are appropriately handled
• ensuring all third parties to whom the NHPCA provides access to personal information adhere to appropriate standards of care in managing that information.

2. Personal Information and How We Collect It

In order to fulfill its mission of championing professional excellence and advocating on members' behalf as holistic health practitioners, the NHPCA must collect personal information. 'Personal information' is any factual or subjective information, recorded or not, about an identifiable individual. This includes name, contact information, date of birth, educational history and certification, information relating to character and reputation, member account information, and any identifiable online activity. The NHPCA may offer voluntary assistance initiatives or programs designed to provide additional support or benefits to our members which requires the NHPCA to collect additional personal information from those who apply for such initiatives. This includes professional practice and demographic information, employment status, income sources, availability of credit, savings, investments, access to insurance coverage, monthly expenses, and housing situation. Any financial information, such as payment card details, are considered sensitive personal information that we handle with extra care.

Aggregate or de-identified information that cannot be associated with a specific individual, such as membership statistics used for strategic planning, is not personal information.

Personal information can be collected in several ways, including through the membership application form and other online forms used to register for an NHPCA program, or verbally on the telephone. We collect limited personal information as is reasonable to manage your membership and offer/deliver our products or services, and we do so with your consent or as otherwise authorized by law. We identify when information may be provided optionally and when it is necessary in order to service you.

When it is practical to do so, we will collect the information we need directly from you. In those instances where information is collected from a third party such as an educational institution to confirm educational and credentialing information, or a complainant or witness in the context of a complaint against you, your personal information will be respected in exactly the same way as if we collected it from you personally.

3. Obtaining your Consent

We collect, use, and disclose your personal information with your consent, except as required or permitted by law. Your consent to the collection, use, and disclosure of personal information may be express (that is, where you were asked specifically for your consent, whether verbally or in writing) or implied for non-sensitive information, when we can reasonably conclude that you've given consent by some action, or when it is obvious that you would consent if directly asked.

Note that there may be instances where the law permits the collection, use, or disclosure of your personal information without your consent, for example in the context of fraud investigations, and where necessary to protect our legal interests or the safety of others. For example, we may be required to collect, use, disclose, or store personal information without your consent to comply with other laws, an order of a court or other legal administrative tribunal, or to respond to an authorized inquiry of a government agency. In other contexts, your consent can be withdrawn at any time, subject to legal or contractual restrictions, by providing us with written notice. Upon receipt of notice of withdrawal of consent, we will inform you of the likely consequences of withdrawing your consent before we process your request, which may include termination of your membership, or the inability of the NHPCA to provide you with certain information, products, or services.

4. Purposes for Collecting and Using Your Information

Personal information is collected and used by the NHPCA for one or more of the following specific purposes:

• approving, managing, and renewing membership with the NHPCA, including processing of registration fees
• assessing member credentials with respect to different modalities, competency equivalency, and continued competency
• responding to member questions or concerns
• assessing your needs and administering questionnaires, feedback forms, or contests
• assessing your eligibility for voluntary assistance initiatives or programs designed to provide additional support or benefits
• registering you for an upcoming event or providing you with the NHPCA's products or services
• investigating and resolving complaints against a member in accordance with the NHPCA's By-Laws
• to improve our products and services/programs
• to inform you about our products and services, conferences and volunteering opportunities that we believe members would benefit from knowing about. We may also tailor our offerings to you based on your demographics or other information, with the objective of meeting your specific needs
• facilitating member involvement on a committee or the Board of Directors;
• assessing and managing risk, including detecting and preventing fraud or error
• for administrative purposes such as reporting and membership analytics
• for internal and external audits
• to meet legal and regulatory processes and requirements, or bring or defend against legal actions
• for such other purposes for which you have provided your consent, or as otherwise permitted or required by law

5. Sharing Your Information

Note that you may authorize the NHPCA to share your name, location, contact information, and other information, such as your modalities of practice and training, with the public through the NHPCA's public member directory on the NHPCA website. This directory is opt-in only.

Your personal information may also be shared as required to provide you with membership and our products and services, to support professional excellence and transparency, and to comply with legal requirements. We may disclose your personal information in the following circumstances:

• to insurance companies, health benefits administrators, or licensing authorities to confirm your membership in good standing
• to other professional associations or colleges of regulated health professionals if you are a member who is in the NHPCA's complaint resolution process
• to presenters or other affiliates in the context of partnered workshops
• to a complainant (only as required in the context of complaint resolution)
• to the public if a member who has completed a complaint resolution process has a finding made against them
• to a court, administrative tribunal, governmental authority, or other body authorized to compel the disclosure of your personal information, for the purpose of complying with legal requirements such as a statute, regulation, search warrant, subpoena, court or administrative order, or as otherwise required or permitted by law
• as required to reduce the risk of harm if the personal safety of any individual may be compromised

In addition, personal information may be transferred or made accessible to the NHPCA's agents and third-party service providers who assist us in carrying out our business and providing you with our products and services. These trusted entities have agreed to comply with strict privacy and confidentiality obligations. Such transfers of data for processing may occur in the context of payment processing. complaint investigation, IT managed services and software development, event planning, and other business outsourcing arrangements. Only personal information that is required by the third party to provide the service in question will be transferred.

Please note that in the context of any of these disclosures or transfers of data, your personal information may be processed or stored outside of Canada. Such information may be provided to law enforcement or national security authorities of the foreign jurisdiction upon request, in order to comply with foreign laws. We take reasonable steps to ensure that any such third parties who we entrust with your personal information are reputable and have safeguards in place to protect your information.

6. Keeping Your Information Safe

The NHPCA acknowledges that a data security breach could result in potential harm to individuals whose personal information is entrusted to the NHPCA. Thus, we have implemented critical physical, organizational, and technical measures to guard against unauthorized or unlawful access to the personal information we manage and store. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by NHPCA significantly reduce the likelihood of a data security breach.

Here are some examples of the security controls we have in place:

• secure office premises
• locked filing cabinets and a secure shredding practice for paper records
• the use of encryption, firewalls, anti-virus programs, and robust authentication processes, including complex passwords, for access to electronic records
• limited access to personal information by employees who need the information to perform their work-related duties
• the use of sophisticated data centres with effective physical and logical data security controls
• initiatives to raise awareness amongst staff of their data protection responsibilities
• regular reviews of privacy compliance and best practice initiatives

In addition, we recommend that you do your part in protecting yourself from unauthorized access to your personal information. For example, never share your Member Account password with anyone. The NHPCA is not liable for any unauthorized access to your personal information that is beyond our reasonable control.

7. Accessing Your Personal Information

We make every effort to ensure that the personal information contained in records that we control or have custody over is accurate, complete, and up-to-date for the purposes for which we collect it. We rely on members to notify us if there is a change in their personal information. You can correct your information yourself by logging into your Member Account or contacting the Membership Department at memberservices@nhpcanada.org.

You can make a written request for access to your personal information at any time and also request that it be corrected if there are any inaccuracies. You will need to provide as much information as you can to help us process your request and locate the information you require.

If you need assistance in preparing your access request, please get in touch with our Privacy Officer (see contact information at the end of this policy). As we take your privacy seriously, we will take reasonable steps to verify your identity before granting you access or making corrections, updates, or deletions to your personal information. Upon your written request, the NHPCA will also inform you of how your personal information has been or is being used, and who your personal information has been shared with. If we have obtained information about you from other people, we will let you know who we got it from upon your request.

The NHPCA responds to access requests within 30 days, unless an extension of time is required. We may charge a fee to cover any expenses related to responding to your access request. Note that there may be contexts where access is refused or only partial information is provided, for example, in the context of an on-going investigation or where another individual's personal information or identity must be protected.

8. How Long We Keep Your Information

NHPCA retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with our record retention schedules. If a member goes through the complaint resolution process, their membership information is retained indefinitely, even if they are no longer a member of the Association. The NHPCA is subject to specific contractual or legal requirements with respect to retention periods as well, for example, as required by the Association's insurers.

Once your information is no longer required by the NHPCA to administer products or services and meet contractual, legal or regulatory requirements, it is securely destroyed, erased, or made anonymous. Keep in mind however that residual information may remain in back-ups for a period of time after its destruction date.

9. Our Privacy Complaint and Breach Management Process

The NHPCA takes privacy complaints very seriously and has a procedure in place for escalating and managing any privacy related concerns to ensure that they are responded to in a timely and effective manner. Any suspected privacy breach must be escalated internally to the NHPCA's Privacy Officer who oversees the containment, investigation, and corrective actions for the breach situation.

In the event that you are not satisfied with NHPCA's resolution of a complaint or privacy breach, you may have the ability to file a formal complaint with a privacy regulator at the provincial or national level in Canada.

10. Cookies and Website Log Data

A cookie is a small text file containing a unique identification number that is installed by a website on a device's local storage. The NHPCA websites use cookies and other web technologies for a variety of purposes in the course of administering its websites. The NHPCA uses both session cookies (used only during your visit and that expire when you close your browser) and persistent cookies (stored on your device for longer than your visit to our websites). Cookies used by the NHPCA collect certain information from your browser or mobile platform, including the date and time of your visit, your IP address or unique device identifier, browser type and other device information (such as your operating system version and mobile network provider), but do not contain personal information such as your name or e-mail address.

The NHPCA installs first-party cookies on devices that access its websites unless the browser used by the device has disabled the installation of cookies. The first-party cookies the NHPCA installs ensure the website functions as intended, and in some circumstances are essential for the NHPCA to provide services requested by website visitors. For example, enabling first-party cookies is required to log into your Member Account, as certain cookies are used to support the log-in process and keep you logged in. Non-essential cookies are also used by the NHPCA to analyze and improve the performance of our websites, design and layout, and your overall online experience. For example, the NHPCA uses web analytics services, including Google Analytics, to understand the interests of our visitors and analyze traffic patterns. We make no effort to personally identify you based on your visit to our sites if you are not logged into your account. If you wish, you can make use of Google's free Google Analytics Opt-Out Browser Add-On.

You can easily adjust your browser settings to notify you when you receive a cookie so you can choose whether or not to accept it, disable your browser from receiving cookies, or delete cookies through your browser. Please consult the Help function of your browser for more information. Be aware that cookies allow for optimal functionality of the NHPCA's website. Some features and services on our website may not work properly if you refuse cookies.

11. Social Media, Chat Rooms, and Discussion Forums

The NHPCA's use of social media serves as an extension of our presence on the Internet and helps us build a positive brand image as well as offer our customers personalized service. The NHPCA social media accounts are not hosted on NHPCA's servers. Please note that when you publicly post personal information on social media, it can be viewed by anyone who visits our platforms. Users who choose to interact with the NHPCA via social media, such as Facebook, should read the terms of service and privacy policies of these services/platforms.

Likewise, take precaution when posting information to chat rooms or other discussion forums because, once posted, the information will be made public and cannot be easily removed from the Internet. This Privacy Policy does not cover information you post to social media, chat rooms, or other discussion forums and how persons receiving your information will use that information.

12. External Links

We may offer links from our websites to the sites of third parties (including affiliated organizations), that may be of interest to you. Since these sites are not owned or controlled by us, the NHPCA makes no representations as to such third parties' privacy practices and we recommend that you review their privacy policies before providing your personal information to any such third parties.

13. Changes to this Policy

We may change this Privacy Policy from time to time in order to better reflect our current personal information handling practices. Thus, we encourage you to review this document frequently. The "Last Updated" date at the top of this Privacy Policy indicates when changes to this policy were published and are thus in force. Your continued use of NHPCA products and services following the posting of any changes to this Privacy Policy means you accept such changes.

14. Getting in Touch

Any inquires, concerns, or complaints regarding privacy should be directed to:

Privacy Officer
Natural Health Practitioners of Canada Association
230-9440 49 Street
Edmonton, AB T6B 2M9

Telephone: 1-888-711-7701
Email: privacy@nhpcanada.org

Your concerns will receive prompt attention. Our Privacy Officer can also provide you with more detailed information about the NHPCA's policies and practices. Keep in mind however that email or text messaging are not secure forms of communication, so never send confidential personal information to us this way.

Thank you for continued trust in the Natural Health Practitioners of Canada Association.