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 and disclosure 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 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 and CAP Bylaws. The information collected is necessary for CAP in its role as a regulatory body. CAP will collect, use and disclose personal information only to the extent that it is reasonably required for meeting its regulatory obligations or as otherwise authorized by law.
Examples of personal information that CAP might have about its members include:
- Personal contact information, including home/email address and telephone number(s).
- Information originally submitted when applying for membership with CAP, such as written references, criminal record check information, educational history and examination results.
- Financial information, such as credit card numbers if fees were paid by credit card.
- Information received and obtained as a result of a complaint.
Examples of personal information that CAP might have 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.
Method of collecting personal information
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 it is authorized to do so by law and/or if consent is obtained. For example:
- Individuals who wish to be registered must provide the names of referees. Letters of reference are collected from these individuals.
- CAP also collects information from third parties if there is a complaint made against a member. In such circumstances, CAP exercises its authority under the HPA to collect information from individuals, such as the complainant, clients or potential witnesses.
Use of personal information
CAP uses personal information to regulate the profession of psychology under the HPA, the Psychologists Profession Regulation and CAP Bylaws. Information will normally only be used for the purposes for which it is gathered. Examples of how personal information is used are:
- To assess whether applicants meet the initial requirements for registration with 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.
- For carrying out CAP’s regulatory duties under the HPA.
Disclosure of personal information
For the most part, CAP uses personal information for internal purposes. Therefore, it is primarily CAP’s employees, 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.
CAP’s policy 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.
In some instances, CAP will be required to disclose information to third parties in a manner consistent with the uses described above. For example, 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 with respect to the professional conduct process and hearings may be made available to the public.
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's computer 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 will be 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 to public hearings. CAP may also disclose personal information as authorized by law, including 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 to 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.
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. CAP may, in its sole discretion, 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. CAP may retain personal information for a minimum of 10 years after membership ceases, at which time the information may be rendered non-identifying or securely destroyed.
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 the personal information held about them. 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 correction that was requested.
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 or mailed to the CAP’s Privacy Officer.
Persons wanting more information about CAP’s privacy guidelines or wishing to make a complaint about a privacy issue should contact:
College of Alberta Psychologists
1850 Sun Life Place
10123-99 Street NW