CNPS Privacy Policy

The Canadian Nurses Protective Society (CNPS) recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting all personal information that we collect and maintain from you in accordance with applicable privacy laws. We have developed this privacy policy to explain the measures that the CNPS has implemented in this regard.

CNPS legal counsel are bound by the Rules of Professional Conduct set by their governing law society to keep all information received within a professional relationship confidential, both during the course of the relationship and indefinitely thereafter. These obligations relating to the protection of the privacy of personal information also extend to all employees, contractors, and agents who provide services to the CNPS. The CNPS also adheres to its obligations under Canada’s Anti-Spam Legislation and ensures that appropriate consent has been obtained prior to disseminating electronic communications.

In addition to compliance with legal and regulatory requirements, the CNPS has also implemented internal privacy policies and confidentiality agreements, and engages in ongoing education with our staff about our privacy policies and practices. Applicable laws and CNPS policies govern the protection of the personal information of CNPS employees.

By using our website, or otherwise interacting with us by telephone, email, mail, in person, online or via social media, you consent to the collection, use and disclosure of your personal information by the CNPS in accordance with the terms of and for the purposes set out in this Privacy Policy.

What is Personal Information?

Personal information is any information, recorded in any form, about an identifiable individual, or information from which an individual’s identity may be inferred or determined. This Privacy Policy does not apply to information that is anonymized or aggregated (information about more than one individual in which the identity of the individuals is not known and cannot be inferred from the information).

What Personal Information does the CNPS collect?

The CNPS may collect the following types of personal information from you:

• When you contact us to inquire about, register for or renew our services: first and last name, contact information (telephone number, mailing address, email address, nursing category, jurisdiction in which you practice nursing, nursing registration/student number, payment information, transaction history, and whether you have other sources of professional liability protection.
• When you contact us to seek legal advice: first and last name, birth year, contact information (telephone number, mailing address, email address), nursing category, jurisdiction in which you practice nursing, nursing registration/student number, area of practice, workplace or educational facility, the reason for your call, details of an incident or occurrence that you may wish to discuss, and any other information you may choose to provide.
• When you sign up online to receive our newsletters and updates: first and last name, email address, nursing category, nursing regulator, nursing registration/license or student number, preferred language of communication.
• When you register for our webinars: first and last name, email address, nursing category, jurisdiction(s) in which you practice nursing, nursing registration/licence or student number, your area(s) of nursing practice, workplace or educational facility.
• When you register for an individual CNPS website account: first name, last name, nursing regulator, nursing registration/license number, date of birth, telephone number, mailing address, email address and password.
• When you register for an individual CNPS website account as a nursing student: first name, last name, nursing school, expected year of graduation, email address, telephone number, province/territory in which you reside, preferred language of communication.
• When you submit a request for an educational session: full name, contact information (telephone number, mailing address, email address), nursing regulator, registration/licence number or CNPS ID, type of request, and details you may choose to provide about event description and attendance.
• When you visit our website or social media pages (YouTube, Facebook, Twitter and LinkedIn), the following information is collected automatically through Google Analytics: aggregate statistics about your location (country, city), language, gender, age ranges, system information and type of device used, network provider, search terms used, information about the time spent on our website; your name and publicly available information if you have chosen to follow us on social media. We do not collect information about your IP address.
• Information provided to us by member organizations about individual beneficiaries: first and last name, middle name or initial, nursing registration/license number, nursing category, registration status, date of birth, gender, contact information (telephone numbers, mailing address, email address), whether or not you have provided your consent to receive email communications from the CNPS, and the start and end dates of registration with member organizations.

Why does the CNPS collect Personal Information?

The CNPS requires personal information to:

• establish and maintain communication with nurses;
• administer the professional liability protection program, including the processing of requests for legal assistance, handling and resolution of legal proceedings;
• determine and understand nurses’ professional liability needs;
• determine whether nurses are eligible for CNPS services and professional liability protection;
• provide ongoing and future services; and
• meet legal, regulatory and professional requirements.

Collection, Use, Disclosure, and Retention of Personal Information

The CNPS limits its information collection and use to what is necessary to provide you with professional liability protection, advice and risk-management services. Your personal information may be shared among CNPS legal counsel and staff to provide you with legal services. In any instance where we wish to share your personal information with others outside of the CNPS (for example, external legal counsel that we retain on your behalf), we will generally seek your consent in writing.

In most circumstances, we will ask you to explicitly consent (in writing or verbally) to the collection, use or disclosure of your personal information. In other cases, your consent may be implied from your interactions with the CNPS. For example, when you telephone the CNPS to seek advice, or, you have previously provided us with personal information, it is implied that you are agreeing and consenting to the collection and use of your personal information in accordance with this Privacy Policy.

When you visit the CNPS website (www.cnps.ca), our registration portal, or email info@cnps.ca, any personal information collected is treated in accordance with the CNPS Privacy Policy. Privacy warnings appear on the CNPS website, email messages and facsimile transmissions as an additional measure to safeguard your information. The CNPS does not barter, trade, sell or exchange for consideration¹ any personal information it has obtained.

Personal information will be collected, whenever possible, directly from the individual concerned. There are circumstances, however, in which personal information about third parties may be collected and disclosed without the third party’s knowledge and consent. For example, to conduct its ordinary business, the CNPS must collect personal information about third parties when there is an occurrence, potential legal proceedings, or actual legal proceedings involving a nurse.

Sharing Personal Information with Third Parties

The CNPS may be required or permitted to share your personal information with third parties in the following limited circumstances:

• where required or permitted by applicable law (e.g. pursuant to legislation, subpoena or court order);
• with third-party service providers, which require the information to provide the CNPS with administrative services such as technical support, communications with our members, processing payment for membership, financial or legal advice, and insurance coverage, and the service providers are provided with access to your personal information solely for the purpose of providing these services to us;
• when we retain a law firm or lawyer on your behalf in order to provide you with legal advice and assistance;
• for any other purpose to which you consent; or
• if the information is publicly known.

In any of these circumstances, except where you provide your consent, the CNPS will only disclose the minimum information required.

When can the CNPS disclose your personal information without consent?

The CNPS may disclose your personal information without your consent where:

• it is required by law or by order or requirement of a court, administrative agency or governmental tribunal;
• it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
• it is necessary to permit us to pursue available remedies or limit any damages that we may sustain;
• the information is public as permitted by law;
• it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or
• it is necessary for the purpose of a prospective business transaction if the information is necessary to determine whether to proceed with the transaction or to complete the transaction, or a completed business transaction where the information is necessary to carry on the activity that was the object of the transaction.

Where required or permitted to disclose information without consent, we will not disclose more information than is required.

How long do we retain your personal information?

We retain your personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. As such, we may keep your account information after the termination of your account.

When your personal information is no longer required for the purposes for which it was collected, we will destroy, delete, erase or convert it into an anonymous form.

Where do we store your personal information?

We store your personal information on CNPS servers located in Canada.

Updating Personal Information

To provide you with professional liability services, it is important that your information be accurate and up-to-date. If your information changes, please inform the CNPS so we can make any necessary changes to our records.

Security

The CNPS implements physical, technical and organizational measures to protect your personal information from loss, unauthorized access, modification, disposal or disclosure. Steps that we have taken include the following: physical security of the premises and internal office; restricted access to personal information to authorized staff; and use of technological safeguards such as security software and firewalls, internal passwords, encryption, and security policies.

A “breach of security safeguards” is defined as the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards. In case of a breach of security safeguards involving your personal information under our control, we will comply with our notification and reporting requirements in accordance with applicable privacy laws. We will keep a record of all privacy breaches in accordance with our legal obligations.

Access and Amendment

You may request access to personal information we have about you, information about how your personal information has been and is being used, and the names of individuals or organizations to whom the CNPS has disclosed your personal information (except in situations where disclosure was to a CNPS service provider for routine administrative purposes).

If the CNPS has information about you that is not accurate, complete or up to date, we will work with you to take steps to correct it.

The right to access your personal information is not absolute. There are limited reasons for denying access, such as prohibitive cost; information that includes references to other individuals; security or proprietary reasons; information that is protected by solicitor-client or litigation privilege; information collected during the investigation of a legal matter; or information that cannot be disclosed for other legal reasons.

Your choices with respect to the collection, use and disclosure of your Personal Information

Depending on the products, services or your use of our website, your choices may include the following:

• Unsubscribing from receiving promotional emails. You may sign up for our mailing lists in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive promotional emails from us, you may choose to unsubscribe at any time by clicking on the “unsubscribe” link in our emails or by contacting us at info@cnps.ca.
• Opt-Outs. You may contact us to opt out of the use or sharing of your personal information by calling 1-800-267-3390 or emailing info@cnps.ca.
• Analytics Tools. You may opt out of the use of your personal information for analytics purposes through Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Links to External Websites

The CNPS has no control over external third-party websites and resources, and you acknowledge and agree that the CNPS is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by this Privacy Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. The CNPS is not responsible for the privacy or security practices or the content of external websites, services or products.

Changes to this Privacy Policy

The CNPS regularly reviews all of its policies and procedures. We may make changes to this Privacy Policy from time to time. When amendments to the Privacy Policy are made, a notice will be posted on the CNPS website.

Requests for Access or Questions

If you have any questions concerning our handling of your personal information, or wish to request access to, or correction of, your personal information held by the CNPS, please contact:

Privacy Officer
Canadian Nurses Protective Society
700 – 160 Elgin Street
Ottawa, ON K2P 2P7
1-800-267-3390
Email: privacy@cnps.ca

If you are dissatisfied with our handling of your personal information, please set out your concerns in writing and forward them to:

Chief Executive Officer
Canadian Nurses Protective Society
700 – 160 Elgin Street
Ottawa, ON K2P 2P7

1. Consideration is a basic, necessary element for the existence of a valid contract that is legally binding on all parties. It can include some right, interest, profit or benefit accruing to one party. Black’s Law Dictionary, Sixth Edition, St. Paul, West Publishing, 1990, 306.