1. Privacy Policy

The Canadian Foundation for the Advancement of Orthodontists (CFAO) recognizes the importance of privacy and the sensitivity of Personal Information (PI). We understand that we have an obligation to keep confidential all PI we receive from you. We are committed to protecting any PI we hold. This Privacy Policy outlines how we manage your PI and safeguard your privacy.

2. Your Privacy Rights

From January 1, 2004, all organizations engaged in commercial activities must comply with the PI Protection and Electronic Documents Act and the Canadian Standards Association Model Code for the Protection of PI which it incorporates. These obligations extend to the Canadian Foundation for the Advancement of Orthodontists (CFAO). The Act gives you rights concerning the privacy of your PI.

Canadian Foundation for the Advancement of Orthodontists (CFAO) is responsible for the PI we collect and hold. To ensure this accountability, we have developed this policy, and trained our directors and support staff about our policies and practices.

3. Why Does Canadian Foundation for the Advancement of Orthodontists (CFAO) Need PI

Canadian Foundation for the Advancement of Orthodontists (CFAO) provides educational services and products to a wide range of members and, through Smiles 4 Canada, facilitates the provisions of orthodontic treatment to the public. We require some PI to provide these services to you; create and maintain contact lists; and produce direct marketing materials concerning our services and development.

4. What PI do we collect?

PI is any information that identifies you, or by which your identity could be deduced. If we did not collect and use your PI we could not provide you with our services.

PI that we collect includes, but is not necessarily limited to, the following:

your name, home address, and home telephone and/or cell phone numbers;
your e-mail address;
financial (taxation) information
previous dental treatment information

5. How do we collect your PI?

We collect information only by lawful and fair means and not in an unreasonably intrusive way. Smiles 4 Canada, we collect your PI directly from you at thetime of your application.

6. Consent

At the time of your applicatioin to the Smiles 4 Canada program, we shall ask you to specifically consent to our collection use and disclosure of your PI.

7. Use of Your Information

We use your PI to provide our services to you and to communicate with you regarding Smiles 4 Canada, evaluate your application and facilitate your child's treatment.

Canadian Foundation for the Advancement of Orthodontists (CFAO) does not disclose your PI to any third party except the orthodontist who agrees to undertake your child's treatment. For example, we do not provide our client mailing lists to other organizations or businesses.

8. Disclosure of your PI

Under certain circumstances, Canadian Foundation for the Advancement of Orthodontists (CFAO) will disclose your PI:

when we are required or authorized by law to do so, for example, if a court issues a subpoena;
when you have consented to the disclosure;
if we engage a third party to provide administrative services to us (such as a mailing service or archival file storage) and the third party will be bound by our Privacy Policy (in this case, we will not disclose financial/taxation information);
if we retain agents or consultants to assist us in completing research relating to Canadian Foundation for the Advancement of Orthodontists (CFAO);
if the information is already publicly known.

In these instances we will only disclose such PI as is required in the circumstances.

9. Updating Your Information

Since we use your PI to provide our services to you, it is important that the information be accurate and up-to-date.

If during the course of your child's treatment any of your PI changes, please inform us so that we can make any necessary changes.

10. Is My PI Secure?

Canadian Foundation for the Advancement of Orthodontists (CFAO) takes all reasonable precautions to ensure that your PI is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

premises security;
employee training in the storage, safe guarding and use of PI;
restricted file access to PI;
deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access; and
internal password and security policies.

If we use the services of any third parties to process or store PI, we will enter into an agreement which requires them to protect this PI in a manner acceptable to us. In entering into these agreements, we do not transfer any interest in this PI to them. This is done to ensure that the PI delivered to third parties is maintained at a level equivalent to that provided for under this Privacy Policy.

11. Access to Your PI

You may ask for access to any PI we hold about you.

Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to a reasonable fee.

We also reserve the right to confirm the identity of the person seeking access to PI before complying with any access requests. Please submit your access request in writing or e-mail to our privacy officer as identified in paragraph 17.

12. Correcting Errors

If Canadian Foundation for the Advancement of Orthodontists (CFAO) holds information about you and you can establish that it is not accurate, complete and up-to-date, we will take reasonable steps to correct it.

13. Can I be Denied Access to My PI

In most cases, a client of Smiles4Canada will have access to the PI we store about him/her and his/her family. However, there may be rare occasions when your rights to access your PI are denied, for example the PIPEDA indicates that:

your rights to access your PI are not absolute;
denial of access is required or authorized by law;
when granting you access would have an unreasonable impact on other people's privacy;
when to do so would prejudice negotiations with you;
to protect Canadian Foundation for the Advancement of Orthodontists' (CFAO) rights and property; or
where the request is frivolous or vexatious.

If we deny your request for access to, or refuse a request to correct information, we will endeavor to explain why.

14. Can I request anonymity.

Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website).

15. Communicating with Us By E-Mail

You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information or requesting us to respond to you by e-mail.

16. Changes to this Privacy Policy

Since Canadian Foundation for the Advancement of Orthodontists (CFAO) regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. These changes will be posted to our web-site as soon as is practical.

17. Requests for Information Access and/or Corrections

If you have any questions, or wish to access your PI, please write to:

Privacy Officer
Canadian Foundation for the Advancement of Orthodontists (CFAO)
800-200 CONSUMERS RD.
TORONTO, ON M2J 4R4

Telephone: (416) 491-3186
Toll Free: 1-877-CAO-8800 (226-8800)
Fax: (416) 491-1670
E-mail: administration@smiles4canada.ca

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street
Ottawa Ontario, K1A 1H3
1-800-282-1376.

We may seek external advice, where appropriate, before providing a final response to individual complaints.

18. Web Site

Our website may contain links to other sites, which are not governed by this Privacy Policy.

On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable PI.