We consider the protection of the personal information of each client (including potential clients) to be a key part of our high level of service. Privacy of personal information is an important principle to West Lake Clinic. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We strive to be open and transparent regarding how we handle personal information. This document describes our privacy policies.

What is Personal Information?

Personal information is information about an identifiable individual. It includes information that relates to an individual’s personal characteristics (e.g., gender, age, income, home address or phone number, family status), and personal health information (e.g., physical and mental health history, health conditions, health services received by them); or, activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). Public information found in directories and listings, or business names, addresses and/or contact numbers, is not considered to be personal information.

Who We Are

West Lake Clinic includes at the time of writing one Traditional Chinese Medicine practitioner – David Ip, and occasional clinic assistants. (Other practitioners who rent space in the Clinic may have their own privacy policies.) We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include accountants and bookkeepers, auditors, insurance claims representatives, medical professionals, lawyers and computer consultants. From time to time, we also have TCM interns registered in formal TCM or Acupuncture training programs. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their written assurance that they follow appropriate privacy principles.

We have adopted, as corporate policy, the following ten personal information privacy principles stated in the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information.

1. Accountability – We will identify individuals in our Clinic who are to be specifically responsible for our compliance with the CSA Code. Their responsibilities will include making sure that third parties who process personal information on our behalf will comply with the CSA Code.

2. Reason for Collection – We will only collect and use personal information about our clients to identify them, to communicate with them, to protect the Clinic and its clients against error and fraud, to understand what products and services our clients want, to improve the quality of our products and services, and to provide information about our products and services to our clients. We will not disclose any personal information concerning our clients to anyone else and we will not permit anyone else to use personal information about our clients for any purpose without the client’s consent.

Primary Purposes

Like all health practitioners, we collect, use and disclose personal information in order to serve our clients. For our clients, we collect personal information for these purposes:

About Members of the General Public

For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of health services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.

On our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for an activity, to subscribe to a newsletter). Cookies are only used to help you navigate our website and are not used to monitor you. For detailed information, please see our Website Privacy Policy.

About Employees, Contract Staff, Volunteers and Students

For people who are employed or contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If employees, contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work-related performance and provide a report as authorized by them.

Related and Secondary Purposes

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

3. Consent

Mostly we collect your personal information directly from you. Sometimes we may obtain information from other sources, e.g., from your physician, pharmacist or other practitioners with your permission or without in emergencies; from your employer, insurer or other agency, institution or government source, accepting responsibility to pay for the services you receive. Before collecting, using or disclosing any personal information, we will ensure that we have your consent in an appropriate form.

Normally, we ask for your consent in writing, but in some circumstances we may accept your oral consent. Sometimes your consent may be implied through your conduct with us. In the course of obtaining your consent, we will explain any diagnosis we make, and the proposed treatment plan if treatment is indicated, so that you have sufficient information upon which to provide us with an informed consent to treatment.

You have a right to revoke your consent at any time. If you need clarification, we will be pleased to respond.

4. Limiting Collection 

We will collect personal information only for the purposes stated above unless we receive consent from the individual to collect it for another purpose.

5. Limiting Use, Disclosure, Retention and Destruction of Personal Information

You have the right to be informed about the anticipated disclosures of your personal information. We will use and disclose an individual’s personal information only for the purposes stated above, subject to such limitations as you may impose upon us.

Under certain circumstances we may be obliged, justified or permitted to disclose your personal information without your knowledge or consent. For example,

in which cases we will not disclose more information than is required.

We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.

We keep our client files for about five years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence (e.g., with people who are not clients) newsletters, seminars and marketing activities for about one year after the newsletter ceases publication or a seminar or marketing activity is over.

Your records and personal information will not be destroyed, except when it is consistent with law, and ethical and limitation standards required or recommended by the Provincial Traditional Chinese Medicine and Acupuncture Society (Saskatchewan) and the College of Acupuncturists of Alberta. We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or all of the client file to our client.

6. Accuracy and updating

We will maintain all personal information in our possession in as accurate, complete and up-to-date form as is necessary for the purposes for which it is to be used. If during the course of our relationship with you any of your information changes, please inform us so that we can make any necessary changes.

If you believe there is a mistake in the information, including inaccuracy or incompleteness, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the appropriate correction and notify anyone to whom we sent this information. If the information cannot be changed, your request and our decision will be noted in your chart, and we will forward that statement to anyone else who received the earlier information.

7. Safeguards – Protecting Personal Information

We understand the importance of protecting personal information. For that reason, we take all reasonable precautions to protect personal information in our possession from unauthorized access or alteration or from inadvertent destruction by security safeguards appropriate to the sensitivity of the information.

8. Openness 

We will make this Corporate Privacy Statement readily available in our Clinic and on our web-sites. Individuals may make inquiries about personal information privacy issues by contacting our Information Officer, David Ip by telephone (306-790-9378), by mail (West Lake Clinic, 105 McMurchy Avenue, Regina SK S4R 3G5) or by e-mail (davidip@westlakeclinic.ca).

9. Individual Access

With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. Such requests may be subject to a nominal disbursement fee. Individuals may request access to their personal information in our possession by contacting David Ip at West Lake Clinic.

If there is a problem we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

Exceptions to access may include:

10. Challenging Compliance

If you wish to make a formal complaint about our privacy practices, you may make it by contacting our Information Officer, David Ip. He will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal written decision with reasons.

If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. If your concern is about acupuncture and we cannot satisfy your concerns, you are entitled to contact either one or both of:

Registrar for Acupuncturists

College of Acupuncturists of Alberta

#201, 9612 – 51 Avenue NW

Edmonton AB T6E 5A6

Phone: 780-466-7787| Fax 780-466-7251 Email: assistant@acupuncturealberta.ca

Information and Privacy Commissioner for Saskatchewan

503 – 1801 Hamilton Street
Regina, Saskatchewan  S4P 4B4

Phone: 306-787-8350; 1-877-748-2298 | Fax 306-798-1603

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

112 Kent Street, Ottawa, Ontario K1A 1H3; Phone: 1-800-282-1376 | Fax 1-613-947-6850; www.priv.gc.ca

The foregoing is the Corporate Privacy Policy of West Lake Clinic, which carries on business in Canada under the same name.

How Can I Be Removed From Your Lists?

If you wish to discontinue contact with us by any or all of these methods, please notify us by any of the methods below and let us know which forms of contact you would like to be removed from.

Mail: David Ip, West Lake Clinic, 105 McMurchy Avenue, Regina SK S4R 3G5

Telephone: 306-790-9378

E-mail: davidip@westlakeclinic.ca

WLC Revised November 2021