1. OBJECTIVE OF POLICY
ONFORM coaching is a health coaching business based in Ottawa, Ontario, Canada. ONFORM coaching recognizes that privacy is important, and is committed to protecting information and maintaining high standards of confidentiality regarding the collection, use, and disclosure of the personal information it collects from its clients. ONFORM coaching collects personal information directly related to its clients in a fair, open, and lawful manner.
(a) to disclose what types of information are collected;
(b) to disclose how such information will be used and to whom it may be further disclosed;
(c) to allow for an opportunity to have any information which is submitted be excluded from uses other than the primary uses for which it was submitted; and
(d) to provide information on how personal information is retained and how it may be accessed.
2. INFORMATION COLLECTED
The Act gives individuals rights concerning the privacy of their personal information, and holds ONFORM coaching responsible for the information that it collects and retains. Personal information is any information that identifies a person, or by which a person’s identity could be deduced.
ONFORM coaching must collect and use personal information of its clients in order to properly provide health coaching services, but restricts the collection of personal information to only that information that is necessary for providing said services.
Wherever possible ONFORM coaching collects personal information directly from the client at the initial stages of the health coach and client relationship, through intake forms or other related documents. In most cases, ONFORM coaching shall ask the client to specifically consent to the collection, use, or disclosure of personal information.
3. USE OF PERSONAL INFORMATION
ONFORM coaching processes personal information only for the purposes for which it was collected and in accordance with this Policy. ONFORM coaching collects personal information for the following limited purposes:
(a) to establish a health coach and client relationship;
(b) to provide health coaching services to clients;
(c) to establish and maintain a client list; and
(d) for internal purposes including research and business development.
Under only the following circumstances will ONFORM coaching disclose the personal information it collects:
(a) when required to satisfy any applicable law, regulation, legal process or enforceable governmental request;
(b) when the client has consented to the disclosure;
(c) when the health coaching services provided require ONFORM coaching to provide client information to third parties;
(d) when it is necessary to establish or collect fees;
(e) when it is necessary to prevent harm to the client, another person, or a child;
(f) if ONFORM coaching has a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
(ii) detect, prevent, or otherwise address fraud, security or technical issues; or
(iii) protect against imminent harm to the rights, property or safety of ONFORM coaching, its users or the public as required or permitted by law.
ONFORM coaching takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where personal data is stored.
ONFORM coaching makes information about its policies and practices respecting the collection and maintenance of personal information available to all interested parties. Clients may request access to any personal information that is held about them by ONFORM coaching. ONFORM coaching is committed to maintaining accurate, complete, and up-to-date personal information, and is pleased to answer any questions clients may have regarding the collection and maintenance of personal information.
6. CHANGES TO THIS POLICY
ONFORM coaching regularly reviews all of its policies and procedures, and as such may change this Policy from time to time.