As of January 1, 2004, the federal privacy law, the Personal Information Protection and Electronic Documents Act (PIPEDA) will apply within any province that has not passed "substantially similar" legislation. PIPEDA governs the flow of Personal Information in the course of commercial activities. This law requires the Ontario Association of Speech-Language Pathologists and Audiologists ("OSLA") to obtain your consent to collect, use and share your Personal Information, including some or all of the information OSLA currently has on record and has always collected, used and shared.

Some information you provide to OSLA may be considered Personal Information. Personal Information is broadly defined as information about an identifiable individual. This does not include information that is business contact information, publicly available information - such as customer and member names, addresses, telephone numbers and electronic addresses when listed in a public directory or made available through directory assistance or other similar sources.

You have always had the option of giving OSLA permission to use your Personal Information. For example, your preferred mailing address is used to provide you with third-party mailings concerning OSLA-related issues on a timely basis. In the past, you have given OSLA your permission in an informal way, but with the new law, OSLA is required to ask you to give your permission to collect, use and share your Personal Information in a more formal way.

PIPEDA requires organizations, including the OSLA, to adhere to 10 principles of privacy protection governing the collection, use and sharing of Personal Information. In the context of OSLA’s relationship with you, the principles involve:

1. Be accountable
2. Identify the purpose of data collection
3. Obtain consent
4. Limit collection
5. Limit use, disclosure and retention
6. Be accurate
7. Use appropriate safeguards
8. Be open
9. Give individuals access
10. Provide recourse

OSLA wants you to know it keeps your Personal Information secure and uses it only as necessary and as is authorized. In recognition of this goal, we make the following commitments to you, our members and customers.

Each organization, including OSLA, is responsible for the Personal Information under its control. Accordingly, OSLA has designated a Privacy Officer to oversee OSLA’s compliance with the principles of privacy protection. The Privacy Officer will receive and respond to any complaints about OSLA’s information management practices. OSLA trains staff and volunteers about privacy issues, and has privacy policies and procedures in place to protect your Personal Information.

With your consent, OSLA may collect Personal Information from you in, but not limited to, the following ways: in person, over the telephone, by fax, by mail, through surveys, through online forms & activities, or through email. The type of Personal Information OSLA collects and maintains may include your name, personal mailing address, email address, home telephone number, home fax number, date of birth, comments made through correspondence, and payment information including banking information and credit card details.

OSLA will identify the purposes for which your Personal Information is collected, either before or at the time of collection. If OSLA seeks to use Personal Information that has been collected for a new purpose that OSLA has not previously identified, OSLA will obtain your consent to the new purpose, unless the new purpose is permitted by law.

To enable OSLA to fulfill its mission, OSLA generally collects, uses, and shares Personal Information for only the following purposes:

• To review, renew or attempt establish membership;
• To establish and maintain responsible professional and commercial relations with members and customers and to provide publications, ongoing services and offers;
• To understand member and customer needs, your Personal Information may also be used to compile statistics about OSLA’s business. These statistics include de-identified information that does not identify you personally.
• To develop, enhance, market or provide services; including, but not limited to: information related to membership, private practice, benefits, products, services, professional development and employment opportunities
• To manage and develop OSLA’s business and operations
• To meet legal and regulatory requirements; and,
• To facilitate commercial transactions.

There will be occasions where we will sell membership list mailing labels to OSLA-approved third parties. Mailing labels identify your preferred mailing address on file with OSLA. Money earned from label sales goes into the general revenue stream to support OSLA activities, allowing us to do more for you. All material being sent by a third party is first reviewed by OSLA to ensure its appropriateness. You may opt out of having your mailing address provided to a third party. However, if you request that your name be removed from the list distributed to third parties you may miss hearing about other important announcements that may be of interest and benefit to you - such as information and application packages for liability insurance, membership benefits and discount notices etc. If you are unsure of your current "mailing list" status or want to change your status, you can do so anytime through the Member’s Area section of our website, or contact the OSLA office and we'd be happy to take care of it for you.

If individuals, who are not OSLA members, provide OSLA with Personal Information (for example: contacting OSLA to request information about OSLA membership or services) OSLA will use that information to respond to their inquiries, and for the purposes identified above.

Consent is the cornerstone to protecting your privacy. OSLA collects Personal Information by fair and lawful means and obtains the individual’s consent for the collection, use or disclosure of his or her Personal Information, as required by the Act or by law.

Consent can be express or, in some circumstances, implied, given through an authorized representative, given in writing, by using a check-off box, electronically, orally (in person or by telephone), or by your conduct, such as use of a product or service.

In determining the type of consent to obtain, OSLA will consider all relevant factors, including the sensitivity of the information and your reasonable expectations. You may withdraw your consent at any time, on reasonable notice, subject to legal or contractual restrictions. OSLA will inform you of the implications of doing so.

At any time you may refuse to provide consent or withdraw your consent for OSLA to collect, use or share your Personal Information, subject to legal restrictions and reasonable notice. Simply inform OSLA’s Privacy Officer of what Personal Information you no longer wish to use or share. (See “Contact Us” below.)

It is always your choice as to whether or not you provide OSLA with your Personal Information. Depending on the nature of the Personal Information you do not wish to provide, OSLA may not be able to provide you with OSLA’s full scope of services, programs or publications, for example:

• No email address provided: You will not be able to conduct online transactions through www.osla.on.ca; nor would you be able to receive urgent emails providing timely information on hot topics such as press releases and government funding announcements; nor would you be allowing OSLA to save money by emailing information instead of mailing out printed copies of documents and/or publications.
• Home address not provided: You will not receive mailings (e.g. The OSLA Connection, OSLA Perspectives, voting information, notices of coming educational events or meetings, including OSLA’s Annual Members’ Meeting, membership renewal applications) at your home
• Birth date not provided: OSLA will not be able to process your membership application as there would be insufficient information for proper identification and security.

OSLA will only collect the data needed to fulfil the Identified Purposes.

OSLA keeps your Personal Information for as long as necessary for the Identified Purposes. The length of time OSLA retains your Personal Information is also affected by any legal requirements OSLA has to meet. This period may extend beyond your term as an OSLA member.

OSLA may disclose Personal Information to a person or organization involved directly or indirectly in supplying a product or service to OSLA members or customers, including without limitation, sales and marketing, our invoice printing and mailing suppliers, our data processors, our website and database providers, and our product and service suppliers. This disclosure is only made to the extent the Personal Information is required and is used only for purposes such as the efficient supply of OSLA services. Such disclosure requires the receiving person or entity to keep the Personal Information confidential.

If OSLA wishes to use your Personal Information for a new purpose, unless the use is permitted or mandated by law, OSLA will obtain your consent for that purpose.

OSLA will maintain the Personal Information collected from you as accurate, complete and up-to-date as necessary to fulfill the Identified Purposes. OSLA is committed to maintaining the accuracy of your Personal Information for as long as it is being used for the purposes set out in this Policy, and your input is essential in keeping OSLA up-to-date. Please notify OSLA promptly of any changes (e.g. address, telephone number) to assist OSLA in providing you with the best possible service. As well, please advise OSLA should you believe, upon review of your Personal Information, that amendments are required.

OSLA protects your Personal Information with safeguards against loss, theft, unauthorized access, disclosure, copying, or modification that are appropriate to the sensitivity of the information. To ensure that the Personal Information you provide OSLA is maintained confidential, OSLA has developed processes and procedures to keep it safe and secure. The safeguards OSLA has in place include:

     Physical
     Restricted access to files, appropriate disposal of Personal Information

     Technological
     Password-protected computers/files

     Administrative
     OSLA employees and volunteerswho deal with your Personal Information in the performance of their duties are aware of the importance of maintaining the confidentiality of your Personal Information      and of ensuring that they destroy or otherwise dispose of Personal Information in a manner that prevents unauthorized access.

     Contractual
     OSLA has contracts in place with independent third parties that restrict them to using Personal Information only for the purposes of providing OSLA’s services, programs and publications to you.

     OSLA website
     OSLA’s website, www.osla.on.ca is hosted by Affinisys Inc. and powered by their Memlink software. Our online credit card payment processing is secured by IATS (International Automated Ticket      Systems). IATS is a division of Ticketmaster Canada Ltd. They draw on over 30 years of experience in ticketing services and transaction processing. The technology and security used by IATS on      www.osla.on.ca is the same used by banks and Ticketmaster. IATS keeps our ecommerce active 24/7 with their two data centres; one located in Vancouver and the other in Toronto. In addition to their      headquarters located in Vancouver, they have offices in Toronto, Ottawa, Calgary and Edmonton. Ticketmaster Canada Ltd. employs over 800 full and part-time employees.

     Please read our website’s Terms and Conditions for more information on using our website.

     Email
     Sending an email is a quick and convenient way to conduct business. However, keep in mind that someone with a lot of skill, and a lot of time, may be able to intercept your email while it is transmitting.      Bear in mind also that there is a possibility of you misspelling and thus sending your email to an email address other than OSLA’s. We suggest you double check the email address before beginning the      transmission, or use the email links provided on our website’s Contact OSLA page. Feel free to contact us to confirm receipt of your transmission. When you send us an email, we may store your      communication and any reply. Communications not retained will be responsibly disposed of. If your communication is retained by OSLA, your Personal Information will be deemed to be collected and      protected under the terms set out for Personal Information in this privacy policy. This means that if we do send you email, we will assume you will enjoy receiving them, and we will continue to do so      until you ask us to stop (using the 'unsubscribe' instructions provided with each email).

     Faxing OSLA
     Sending a fax still remains a convenient way to conduct business. However, keep in mind that someone with a lot of skill, and a lot of time, may be able to intercept your fax while it is transmitting.      Bear in mind also that there is a possibility of you misdialing and thus sending your fax to a fax machine other than OSLA’s. When in doubt, double check the number before beginning the transmission,      and feel free to contact us to confirm receipt. When you send us a fax, we may store your communication and any reply. Communications not retained will be responsibly disposed of. If your      communication is retained by OSLA, your Personal Information will be deemed to be collected and protected under the terms set out for Personal Information in this privacy policy.

OSLA makes information about OSLA’s policies and practices relating to the management of Personal Information readily available to you, through our website at www.osla.on.ca and in written format, upon request.

Individuals have a right to access their Personal Information as well as the opportunity to challenge its accuracy and completeness and to have it amended as necessary. Accordingly, upon your written request to the Privacy Officer, OSLA will inform you in a timely manner and at minimal or no cost to you, of the nature of the Personal Information about you in OSLA’s custody and control, of the use OSLA has made of that information and of the parties to whom OSLA has shared your Personal Information, and OSLA will provide you access to that information except where such access is prohibited by law or OSLA is permitted to provide access through a third party. Where an error or omission is discovered, OSLA will correct the Personal Information and transmit the corrected information to independent third parties where appropriate. At the time of your request to the OSLA’s Privacy Officer, the Privacy Officer will need specific information from you to verify your identity, in order to provide you with access to the Personal Information about you that OSLA holds.

You may contact OSLA if you have any questions, complaints or suggestions with respect to the above-outlined principles. Our Privacy Officer will respond to your inquiries and assist you in resolving the situation in a timely manner. In cases where OSLA’s privacy policies and procedures are found to be deficient in some measure, OSLA will take immediate steps to correct these deficiencies.

We value our relationship with you and welcome any questions or comments you might have about your privacy or your relationship with OSLA. If you have any questions please contact our Privacy Officer at:

     Privacy Officer
     The Ontario Association of Speech-Language Pathologists and Audiologists
     410 Jarvis Street, Toronto, Ontario M4Y 2G6
     Phone: 416-920-3676
     Fax: 416-920-6214
     Email: mail@osla.on.ca

The OSLA website’s Terms and Conditions

The Privacy Commissioner of Canada http://www.privcom.gc.ca/index_e.asp

Ontario’s Information and Privacy Commissioner http://www.ipc.on.ca/

Canadian Standards Association http://www.csa.ca/standards/privacy/Default.asp?language=english

Dated November 2004. This Policy is subject to PIPEDA and/or any other applicable privacy laws and OSLA has the right to change it at any time.