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Personal Information Protection Policy
International Graduate Medical Education

Personal Information Protection Policy

At International Graduate Medical Education, we are committed to providing our clients, customers, members, faculty and students with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers, members, protecting their personal information is one of our highest priorities.

While we have always respected our clients, customers, members, faculty and students privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Alberta's Personal Information Protection Act (PIPA). PIPA, sets out the ground rules for how Alberta businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients, customers, members, faculty and students 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.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients', customers', members' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients', customers', members' personal information and allowing our clients, customers, members, faculty and students to request access to, and correction of, their personal information.


Scope of this Policy

This Personal Information Protection Policy applies to International Graduate Medical Education and its subsidiaries and products, GLOBL Academic and TRACT.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of International Graduate Medical Education. 

Definitions

Personal Information –means information about an identifiable individual [E.g., including name, age, home address and phone number, education and employment information]. 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. Contact information is not covered by this policy or PIPA.

IGME Registrar – means the individual designated responsibility for ensuring that International Graduate Medical Education complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the client, customer, member, faculty and student voluntarily provides his or her personal information for those 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 client, customer, member, faculty and student information that is necessary to fulfill the following purposes:

  • To verify identity;
  • To identify student preferences;
  • To open and manage an account;
  • To deliver requested products and services
  • To guarantee a travel or hotel reservation;
  • To enrol the client in a program;
  • To ensure a high standard of service to our students;

Policy 2 – Consent

2.1 We will obtain client, customer, member, faculty and student 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, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer, member, faculty and student voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client, customer, member, faculty and student 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 client, customer, member, faculty and student 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), clients, customers, members, faculty and students can withhold or withdraw their consent for International Graduate Medical Education to use their personal information in certain ways. A client's, customer's, member's decision to withhold or withdraw their 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 client, customer, member, faculty and student in making the decision.

2.5 We may collect, use or disclose personal information without the client's, customer's, member'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 client, customer, member, faculty and student 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, customer, member, faculty and student surveys in order to enhance the provision of our services;
  • To contact our students directly about products and services that may be of interest;]

3.2 We will not use or disclose client, customer, member, faculty and student personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client, customer, member, faculty and student lists or personal information to other parties [unless we have consent to do so].


Policy 4 – Retaining Personal Information

4.1 If we use client, customer, member, faculty and student personal information to make a decision that directly affects the client, customer, member, we will retain that personal information for at least one year so that the client, customer, member, faculty and student has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client, customer, member, faculty and student 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 client, customer, member, faculty and student personal information is accurate and complete where it may be used to make a decision about the client, customer, member, faculty and student or disclosed to another organization.

5.2 Clients, customers, members, faculty and students 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. A request to correct personal information should be forwarded to the IGME Registrar. 

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', customers', members' correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client, customer, member, faculty and student 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 client, customer, member, faculty and student personal information is appropriately protected through the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access]. 

6.3 We will use appropriate security measures when destroying client's, customer's, member's personal information such as 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 Clients, customers, members, faculty and students Access to Personal Information

7.1 Clients, customers, members, faculty and students have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the IGME Registrar.

7.3 Upon request, we will also tell clients, customers, members, faculty and students 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, customer, member, faculty and student of the cost and request further direction from the client, customer, member, faculty and student 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 client, customer, member, faculty and student in writing, providing the reasons for refusal and the recourse available to the client, customer, member.

Policy 8 – Questions and Complaints: The Role of the IGME Registrar

8.1 The IGME Registrar is responsible for ensuring International Graduate Medical Education's compliance with this policy and the Personal Information Protection Act.

8.2 Clients, customers, members, faculty and students should direct any complaints, concerns or questions regarding International Graduate Medical Education's compliance in writing to the IGME Registrar . If the IGME Registrar is unable to resolve the concern, the client, customer, member, faculty and student may also write to the Information and Privacy Commissioner of Alberta.

Contact information for International Graduate Medical Education's IGME Registrar:
Subject Privacy:

intergme@internationalgme.org

In the event that there is any discrepancy between the English and French version of this document, the English version will supersede.

 
       
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