Privacy Policy

The protection of your private personal information (PI) is one of the priorities at this website of Shobrook Gardens  (Shobrook). Due to the nature of the business of Shobrook, Shobrook is required to collect essential Personal Identifiable Information (PII) as is dictated by law. Additionally, Shobrook is committed to collecting, using and disclosing your PII responsibly, and only to the extent necessary for the goods and services Shobrook provides to you. This document describes how Shobrook's privacy policies are in alignment with PHIPA, PIPEDA, and the Digital Privacy Act, in addition to Shobrook's own strict privacy policies & procedures.

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PHIPA:

The Provincial; (Ontario) Personal Health Information Protection Act was established in Ontario in 2004. This legislation governs the collection, use and disclosure of personal health information, which is confidential data regarding a client's mental and physical health.

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PIPEDA:

The Federal; (Canada) Personal Information Protection and Electronic Documents Act sets the ground rules for how private-sector organizations collect, use, and disclose personal information in the course of for-profit, commercial activities across Canada. PIPEDA generally applies to personal information held by private sector organizations that are not federally-regulated, and conduct business everywhere in Canada.

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Digital Privacy Act:

The Federal; (Canada) The requirement for "valid consent" to the collection, use and disclosure of personal information. Every organization that collects, uses and discloses personal information in the course of commercial activity in Canada (with a few exceptions) must follow new mandatory data breach record-keeping, reporting and notification rules or face significant non-compliance consequences.

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What Is Personal Information (PI)/ Personally Identifiable Information (PII)?
Personal information is information about an identifiable individual. PII includes information that relates to
their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background,
family status), their health (e.g., health history, health conditions, health services received by them) or their
activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an
individual). 

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What Is NOT Personal Information?
What is not considered to be Personal Information is business related information (e.g., an individual's business
address, business title, business email address and business telephone number), all of which is not protected by
privacy legislation.

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Your Personal Information:  
Shobrook is required to collect PII information in regards to yourself which will include; legal name, date of
birth, place of residence; basically all relevant contact information, in order to provide you with optimal service.

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Shobrook's, support personnel (accountants, legal representatives, IT tech's) and administrative staff, etc; are
all required to uphold Shobrook's strict policies and procedures in addition to the stringent protection and
management of your confidential PII.

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In the course of doing business, Shobrook may use a number of consultants, agencies and resources that may,
in the course of their duties, have access to your personal information. Including but not limited to; computer
consultants & technicians; office security; legal service providers; etc. Shobrook proactively restricts access to
your PII and has engaged these resources and possibly others under strict contracts to insure they follow
appropriate privacy policies and procedures which are required by law to protect your PII.

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Collection of Personal Information: Primary Purposes

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About Clients
Like all Service providers, Shobrook may collect, use and disclose PII in order to serve you the client.

• If Shobrook's practice or its assets were to be sold, the purchaser would conduct a "due diligence" review of Shobrook's records to ensure that it is a viable business which has been honestly portrayed. This due diligence may involve some review of the accounting and service files. The purchaser would not be able to remove or record personal information. Additionally, before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to purchase the organization's business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

 

Members of the General Public;

Shobrook's primary purpose for collecting a limited amount of your personal information including your email
address; is to provide notice of appointments or other services.

• Upon your request, Shobrook will remove any reasonable personal information from the contact list. Shobrook does not use, share, sell, or in any way distribute your information in any manner other than it's original intended use as was provided by you.

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Protecting Your Personal Information

Shobrook understands the importance of protecting all private information. For that reason, Shobrook has
taken the following steps:

• Paper information is either under constant supervision, or secured in a locked or restricted area.

• Digital information is secured by passwords & electronic hardware either constantly under supervision or secured in a locked or restricted area at all times. In addition; strong passwords are used on all computers.

• When paper information is transferred, it is in sealed, envelopes or boxes, and by reputable bonded courier companies.

• Electronic/Digital information is transmitted either through a direct line (fax), is anonymized and/or is encrypted.

• Shobrook is trained to collect, use and disclose personal information only as necessary to fulfill the duties, in accordance with this strict privacy policy and the guidelines of Government Regulations.

• External consultants and agencies with access to your personal information must enter into privacy agreements with Shobrook, or sign confidentiality agreements prior to any transfer of private information or access to any PII in the course of providing their services to Shobrook.

• Any unauthorized or unnecessary access to any personal information is prohibited.

 

Retention and Destruction of Personal Information

Shobrook is required to retain personal information for various time frames in accordance with Government
Regulations. Additionally, to ensure that Shobrook can answer questions you might have about the services
provided and for their own accountability to external regulatory bodies.

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Shobrook will retain client information for a minimum of seven years after the last contact/entry. Otherwise if
you ask in writing, Shobrook will remove "reasonable" contact information right away. Shobrook will keep any
personal information relating to general correspondence (e.g., with people who are not clients) newsletters,
seminars and marketing activities for approximately six months after the newsletter ceases publication or a
marketing activity is over. Paper files containing personal information are destroyed by shredding. Shobrook
destroys electronic information by deleting it and, prior to the hardware being discarded; the memory device,
or hard drive is physically destroyed.

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You Can Look At Your Information
Under the Privacy Act; you have the right to see what personal information Shobrook has in the files regarding
you within reason, and the provisions of the governing bodies, or law. Often all you have to do is contact
Shobrook's Information Officer in writing. Shobrook will need to confirm your identity before providing you
with this access. Shobrook reserves the right to charge a nominal fee for each of these requests. Please put your
request in writing only. If Shobrook cannot give you access, Shobrook will inform you by letter or email within
30 days and provide you with the reason why Shobrook cannot give you access.
                     
If you believe there is an error in Shobrook's information regarding you; you have the right to request it to be
corrected. This request can only apply to factual information, and not financial. You will be required to provide
documentation to support your request for the correction of the files. In the event Shobrook does agree that
Shobrook has an error in the file on you, Shobrook will make the correction and notify those to whom Shobrook
has been authorized by you to send this information originally. If Shobrook does not agree that Shobrook has an
error, Shobrook will still agree to include a brief statement from you on the point in the file and Shobrook will
forward a copy of that statement to those who received the earlier information.

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Do You Have a Request or a Question?
Office Admin
1 Elgin Park Drive
Uxbridge, ON, L9P 1Y7
Phone: (905) 852 4156 Fax: (905) 852 4812
Email officeadmin@shobrookgardens.com
                               
Shobrook will, to the best of their ability, attempt to answer any questions or concerns you might have or
provide direction as to where your answers can possibly be found. If you wish to make a formal complaint
regarding these privacy practices; you may make it in writing to Shobrook Office Admin; the Information Officer
(contact information above). Receipt of your complaint will be acknowledged and investigated promptly and you
will be provided with a formal decision and reasons in writing.

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If you have a concern about the professionalism or competence of Shobrook, Shobrook would ask you to
discuss those concerns with their Office Admin as is provided in the contact information above. If Shobrook
cannot satisfy your concerns, you are entitled to contact the regulatory body (the following information lists are
maintained on a best-efforts basis) as follows:

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Notice: the following list is maintained on a best-efforts basis

 

For more Privacy information and inquiries;

The Privacy Commissioner of Canada
https://www.priv.gc.ca/en/contact-the-opc/

The Information and Privacy Commissioner of Ontario
https://www.ipc.on.ca/about-us/contact-us/