The College of Alberta Psychologists (CAP) is required to adhere to privacy legislation, including the Personal Information Protection Act (PIPA) that came into force in Alberta on January 1, 2004. CAP is committed to following the provisions in PIPA to ensure that the collection, use disclosure, and retention of personal information about members and other individuals is protected.
Personal information collected by CAP
Personal information means information about an identifiable individual but does not include business contact information such as business address/email and business telephone number.
CAP collects the personal information it requires in order to carry out its functions under the Health Professions Act (“HPA”), the Psychologists Profession Regulation, CAP Bylaws, and CAP Policies. The information collected is necessary for CAP in its role as a regulatory body. CAP will collect, use, disclose, and retain personal information only to the extent that it is reasonably required to meet its regulatory obligations or as otherwise authorized by law.
Examples of personal information that CAP might collect and retain about its members include, but are not limited to:
- Personal contact information, including names and former names, home/email address and telephone number(s).
- Information originally submitted when applying for membership with CAP, such as written references, criminal record check/vulnerable sector check information, educational history and examination results.
- Financial information, such as credit card numbers if annual fees were paid by credit card.
- Information collected as a result of participation in CAP’s Continuing Competence Program.
- Information received and obtained as a result of a complaint. Most of the personal information is collected from parties directly; however, investigations of complaints under the HPA authorize CAP to collect any information deemed relevant to a complaint. This could include personal information about third parties.
Examples of personal information that CAP might collect about other individuals include:
- Personal contact information, including home/email address and telephone number(s) collected in relation to the investigation of a complaint against a member.
- Personal health information about an individual relating to the investigation of a complaint against a member.
- Personal contact information, including home/email address, telephone number(s) and emergency contact information for CAP staff.
Method of collecting personal information
CAP collects personal information in several ways:
- In writing
- In person
- Verbally and/or visually (on the phone or through a virtual platform)
- Other electronic communication, such as through our website and via email.
CAP collects personal information directly from members or other individuals who come into contact with our members or CAP. CAP only collects third-party information if authorized to do so by law and/or if consent is obtained.
With respect to the CAP website, CAP reserves the right to store information on a visitor’s computer in the form of a “cookie” or similar file for purposes of recording the individuals who visit our public-facing site and log the following information for statistical purposes: internet protocol address, date and time of visit to the website, pages viewed and time spent on each page. This information is only used for statistical and website development purposes. If you visit our website, you do so voluntarily and are deemed to consent to our collection of your personal information as specified in this paragraph. The information collected is stored in a secured directory on CAP’s server located in Canada.
Use of personal information
CAP uses personal information to regulate the profession of psychology under the HPA, the Psychologists Profession Regulation, CAP Bylaws and CAP Policies. Information will only be used for the purposes for which it is gathered and/or to carry out our regulatory mandate. Examples of how personal information is used includes but is not limited to:
- To assess whether applicants meet the initial requirements for registration with the CAP.
- For completion of CAP’s membership database.
- To assess whether applicants are eligible to have their practice permit renewed or reinstated.
- To provide information, newsletters and notices to members.
- To facilitate payment of fees.
- To facilitate complaints made pursuant to the HPA.
- To address concerns made against a member.
- For carrying out CAP’s regulatory duties under the HPA.
CAP has a separate policy that states that directories, mailing lists and mailing labels will be distributed only by Council motion or on the authority of the Registrar and only when such distribution is deemed to hold regulatory or professional value to psychologists or the profession of psychology.
Disclosure of personal information
For the most part, CAP uses personal information for internal purposes. Therefore, it is primarily the CAP employees, Council, committee members, volunteers, consultants and contractors who will have access to personal information about members or other individuals in order to fulfill statutory duties and functions under the HPA, as well as the additional uses identified above. Subject to reasonable and lawful conditions, an individual may withdraw or vary consent for our collection, use, and disclosure of their personal information at any time and must send written notice to CAP for our consideration.
In some instances, CAP will be required to disclose information to third parties in a manner consistent with the uses described above. For example, the information provided may need to be verified by CAP. If so, information may need to be disclosed to a third party for this purpose. CAP discloses demographic information to the Alberta Health Provincial Provider Registry as required. As permitted by the HPA, information in CAP’s membership database and decisions concerning the professional conduct process and hearings may be made available to the public in accordance with the HPA.
External consultants or contractors may also have access to personal information only if access is necessary. For example, CAP’s accountants may have access to information about membership when they conduct their annual audit. In addition, CAP computer/technology consultants may also be provided with access to personal information from time to time. If such access is necessary, and in cases where such access is provided, appropriate contractual arrangements are utilized to protect personal information.
CAP may also disclose personal information to an external party without first obtaining consent for disclosure, where such disclosure is required or permitted by PIPA or other legislation. For example, disclosure of information may occur during the complaints process. Under the HPA and the Psychologists Profession Regulation, the public has access to specific personal information, including information relating to the public register and public hearings. CAP may also disclose personal information as authorized by law, including but not limited to, under the following circumstances:
- In response to a subpoena, warrant or court order.
- Pursuant to a lawful request by a government agency.
- To report fraudulent activity or other deceptive practices to another professional regulatory body or a governmental or law enforcement agency.
- To act in urgent circumstances to protect the personal safety of members or the public.
Protection of personal information
In addition, CAP ensures the security of the personal information in its possession by taking such measures as (a) implementing technological safeguards to secure personal information that is stored in electronic form, (b) ensuring that the areas in which information is stored are reasonably secure and (c) restricting access to personal information to those with a need to access information to perform their duties.
Unless otherwise authorized by law and as outlined above, CAP will not disclose personal information without the consent of the person involved. When CAP is compelled to disclose personal information, CAP will redact information related to any third parties when appropriate. CAP will also redact any copyright materials that are not subject to release, when appropriate.
Retention of personal information
PIPA stipulates that personal information should not be retained longer than is reasonably required to fulfill the purpose for which it was collected. At the same time, such information must be retained for a reasonable period of time. In its sole discretion, CAP may destroy duplicate material that exists in both paper and electronic form.
CAP will retain personal information during the entire period that a person is a member of the CAP. CAP may retain personal information for a minimum of 10 years after membership ceases. At this time the information may be rendered non-identifying or securely destroyed.
Personal employee information
Personal employee information is information relating to an individual who is an employee of CAP. CAP’s employee personal information is collected, used, or disclosed for the purposes of establishing, managing or terminating an employment relationship and managing a post-employment relationship. Managing an employment and post-employment relationship may include determining appropriate levels of compensation, evaluating performance and administering payroll and benefits. This information is collected by CAP primarily for internal use. At times, CAP may disclose personal employee information to third parties, like payroll administrators and benefit suppliers, when necessary for the administration of payroll and benefits. We take reasonable contractual steps to ensure that third parties to whom we may disclose personal information provide a level of personal information protection comparable to our organization.
Responding to personal data breaches
A ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed. In the event of a personal data breach, in certain circumstances, CAP is legally obliged to report the breach to the appropriate Information and Privacy Commissioner. In accordance with privacy legislation, CAP will also notify the individuals directly affected by the breach, as appropriate in the circumstances.
Access and correction
Under PIPA, individuals have a right to access records containing their personal information. Upon request and subject to certain lawful restrictions, CAP will give individuals access to their own personal information in CAP’s possession. If a request is complex and requires an extensive or detailed search, CAP may, at its sole discretion, charge a reasonable fee.
If an individual requests a correction of an error or omission in the personal information, CAP will, subject to legal limitations, correct the information as soon as is reasonably possible or annotate it with the requested correction. CAP’s Privacy Officer will make every reasonable effort to assist individuals asking for access to, or correction of, their personal information and will respond as accurately and completely as is reasonably possible within the time limits specified in PIPA.
All requests for access to, or correction of, their personal information must be made in writing and must set out in sufficient detail the scope of the request. Requests should be delivered to CAP’s Privacy Officer.
For more information or to make a complaint about a privacy issue, please contact:
College of Alberta Psychologists
1850 Sun Life Place
10123-99 Street NW