Proximity Institute (“Proximity”) is committed to protecting and safeguarding the privacy and security of your personal information (“Personal Information”). Proximity is a not-for-profit organization with a mandate to enable effective leadership for the Ontario hospital sector.
The federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) which came into effect provincially on January 1, 2004 applies to private-sector organizations across Canada that collect, use or disclose personal information in the course of a commercial activity (defined as any particular transaction, act, or conduct, or any regular course of conduct that is of a commercial character, including the selling, bartering or leasing of donor, membership or other fundraising lists). Proximity does not engage in commercial activity and therefore is not covered by this Act.
To demonstrate our continued commitment to the protection of personal information, Proximity has adopted the Canadian Standards Association’s 10 Privacy Principles that underpin both Canadian and Ontario privacy legislation in respect of visitors.
What personal information do we collect?
Personal information is defined as information about an identifiable individual including their information that pertains to the use of Proximity services. Personal Information does not include information that is business contact information, is publicly available information, such names, addresses, telephone numbers and electronic addresses when listed in a public directory or made available through directory assistance or other similar sources. In the event a visitor uses their home contact information, personal cell phone, or personal email as business contact information, Proximity considers the contact information provided as business contact information.
Proximity is committed to respecting the privacy of every person who visits our website or uses our services/resources. Personal Information is maintained securely in accordance with industry practices and using methodology commensurate to the sensitivity of the information. We limit the collection of Personal information to what is required to fulfill the purposes for which it was collected. We will only collect, use, and disclose your personal information in accordance with the consent you provide. Personal information that may be collected includes but is not limited to the following:
- Name
- Address
- Telephone/fax numbers
- Email address
- Education / Curriculum vitae
- Use of Proximity’s services
How we use information that is automatically obtained?
Cookies
Proximity’s website stores cookies on your computer when you access its’ website. A cookie is a small text file placed on your computer, mobile device or any other device (e.g., tablet) by a website, that uniquely identifies you and contains details of your browsing history on that particular website.
Cookies are used to improve visitor experience, understand general traffic patterns and how visitors use the website. This information may be used to evaluate website performance and support improvements. We install cookies to administer our website and help it function. Information collected using cookies may include, but is not limited to, data to track frequency of visits, pages visited, web browser used, and location (city) of visitors. We do not store sensitive personal information (i.e., mailing addresses, account passwords) in the cookies we use.
Most web browsers accept cookies, however, usually you can set your browser to refuse cookies. If you set your browser to refuse cookies, you will need to enter your information (e.g., name, email address) when engaging with some of the interactive areas on the website each time. If you prefer to avoid the use of cookies on this website, first you must disable the use of cookies in your browser and then delete the cookies saved in your browser associated with this website. You may use this option for preventing the use of cookies at any time. If you would like to delete cookies or instruct your web browser to delete or refuse cookies, visit the official help pages of the web browser you are using. Proximity uses third party cookies such as Google Analytics to track website usage.
How Proximity maintains and protects your personal information?
| Principle 1 – Accountability | 1.1. Proximity is committed to respecting the privacy and maintaining the confidentiality of personal information, whether written, verbal, electronic, photographic or stored on any other medium. Proximity has designated the Operations Officer as our Privacy Officer who can be reached at lina@proximityinstitute.com. 1.2 Proximity has policies and procedures in place to implement and comply with this Privacy Policy, including procedures relating to the collection, handling, storage and destruction of Personal Information. 1.3 Proximity is responsible for Personal Information transferred by it to third parties, if any, for processing on its behalf. Proximity uses contractual means to provide an appropriate level of protection for such transferred information. Third parties entering into a business relationship with Proximity are required to adhere to the Privacy Principles, this Privacy Policy, PIPEDA, CASL and any other applicable law dealing with the protection of Personal Information. |
| Principle 2 – Identifying Purposes | 2.1 Proximity identifies the purposes for which Personal Information is being collected at or before the time of such collection. Generally, Proximity collects Personal Information for the following purposes: (a) To understand and distill visitor and health care system leadership needs; (b) To develop, enhance, and provide services and supports; 2.2 In the event that Proximity is required to use, disclose or collect Personal Information for a purpose that is not listed above and in respect of which consent has not been previously granted, your Personal Information will not be used or disclosed without first identifying the new purpose and obtaining your consent, unless otherwise exempted from doing so under PIPEDA. |
| Principle 3 – Obtaining Consent for Collection, Use or Disclosure | 3.1 Proximity collects Personal Information by fair and lawful means and obtains your consent (or of a person authorized to consent on your behalf) for the collection, use or disclosure of his or her Personal Information. 3.3 You may withdraw consent to use your Personal Information at any time, subject to any legal or contractual restrictions and upon giving Proximity reasonable notice by contacting us at info@proximityinstitute.com. Proximity will inform you of the implications, if any, of withdrawing consent and how to do so. |
| Principle 4 – Limiting Collection of Personal Information | 4.1 Proximity limits the collection of Personal Information to that which is reasonably necessary for the identified purpose(s). |
| Principle 5 – Limiting Use, Disclosure and Retention | 5.1 Proximity does not use or disclosure Personal Information for purposes other than those for which it was collected, except with the consent of the individual, or as permitted or required by law. Where personal information is stored outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s government, courts, or law enforcement or regulatory agencies. |
| Principle 6 – Accuracy | 6.1 Proximity takes reasonable steps to keep Personal Information accurate, complete and up to date as is necessary for the identified purpose(s). |
| Principle 7 – Security Safeguards | 7.1 Proximity protects Personal Information from unauthorized access, use and disclosure by establishing and maintaining appropriate security safeguards. |
| Principle 8 – Openness | 8.1 Proximity’s Privacy Policy is posted on its website and informs about the type of Personal Information it may collect and what it is used for. |
| Principle 9 – Obtaining Access to Personal Information | 9.1 Upon request and in accordance with the requirements under PIPEDA, Proximity will provide access to your Personal Information and details about the use and disclosure of that information. You shall be able to challenge the accuracy and completeness of your Personal Information and to have it corrected, as and when appropriate by contacting us at info@proximityinstitute.com. 9.2 In certain circumstances Proximity may not be able to give you access to all Personal Information it holds about you. For example, this may be the case when the information is unreasonably costly to provide, the information contains references to other individuals, the information cannot be disclosed for legal, security or proprietary reasons, or the information is subject to solicitor client or litigation privilege. In the event Proximity declines to grant you access to Personal Information, Proximity will explain and give reasons for denying access in writing and the recourse available to you. 9.3 Proximity will make reasonable efforts to respond to your request for access to your Personal Information no later than 30 days after receipt of the written request, and at a minimal or no cost. You will be informed of any extensions to the time limit and your right to contact the Privacy Commissioner regarding the extension of time. |
| Principle 10 – Challenging Compliance | 10.2 All complaints and/or questions should be directed, in writing, to the Privacy Officer at Proximity: Lina Pallotta Operations Officer Proximity Institute 200 Front Street West, Suite 2501 Toronto, Ontario M5V 3M1 Email: lina@proximityinstitute.com |
Links to other websites
Proximity’s website contains links to other websites. Proximity is not responsible for the content or privacy practices of these websites. We encourage you to read the privacy statements of these linked websites, as their policies may differ from our own.
Our approach to unsolicited emails
Proximity is committed to safeguarding electronic information and complying with Canada’s Anti-Spam Legislation (“CASL”) which came into effect July 1, 2014.
Proximity does not send or condone unsolicited email, or “spam”. In various places on our website, we may request information from you. For example, we may ask for your perspective on a leadership dilemma through a question and upon submission of your response, ask if you’d like to further discuss. You will only receive an email if you have requested further engagement. Proximity complies with CASL and seeks consent, as required by CASL, before communicating any commercial electronic messages.
If you feel you’ve received unsolicited email from Proximity, please send a message to our Privacy Officer.
Updates to this policy
We may make changes to this policy from time to time. Any changes we make will become effective when we post a modified version of the policy on our website. If the changes we make are significant, we will provide a more prominent notice as required by applicable laws.
Where to learn more
To learn more about the collection, use, disclosure and protection of your personal information or to request access or make a complaint, please contact Lina Pallotta at
lina@proximityinstitute.com
Last Reviewed: December 3, 2021
