This Policy describes the privacy and confidentiality practices and commitments of the BC Centre for Disease Control (“BCCDC”) and the Provincial Health Services Authority (“PHSA”) in the operation of the SmartSexResource website (the “Site”), which is operated and maintained by the BCCDC. The purpose of the Site is to provide a confidential and trustworthy source of information related to HIV, sexually transmitted infections (STIs) and sexual health. The Site provides education, links to local resources, access to sexual health nurses, and referral to clinical and/or other professional health services, where necessary.
If you have any questions or concerns about this Policy or require any further information about the privacy practices of the BCCDC in connection with the Site, please send an email to firstname.lastname@example.org or contact:
Program Manager, Online Sexual Health Services
Clinical Prevention Services Division, BC Centre for Disease Control
The Information We Collect and How We Use It
Information Collected Automatically
PHSA uses Google Analytics, a web analytics service provided by Google, Inc. (Google), to analyze site usage, what visitors do on the Site, which browser they use, etc. This information is obtained from Internet Information Server (IIS) log files and allows us to understand how the Site is being used so that we can improve the user experience.
Google Analytics uses first-party cookies to track visitor interactions. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for the website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google’s behalf.
PHSA uses IP masking within Google Analytics to anonymize personal information collected by Google. IP masking is a customization which removes the last octet of the visitor’s IP address prior to its use and storage by Google.
For more information visit the Google Analytics Overview page.
Cookies are small amounts of information stored by your web browser software on your computer. Cookies are used to track browsing history on a website. This allows the user to interact with a website in an effective way and improves the usability of the site.
SmartSexResource uses temporary cookies (“session cookies”), which means that the information collected is deleted as soon as you leave the Site. If you have signed up for an account on SmartSexResource, you will be required to login every time.
Information Collected from You
We collect only the minimum amount of information required to provide services on the Site. Personal information will only be used for the specific purpose for which it was collected or for consistent purposes. This information will not be used for other purposes or made available to others, except as listed in the section below entitled How Else May We Use or Disclose Your Personal Information?
The following information is collected for each of the services identified:
- Ask a Question: (1) Anonymously: You can submit a question to a nurse without providing any personally identifying information. Your question will be posted anonymously, along with the answer, on SmartSexResource. (2) With notification: If you want to be notified when the answer to your question is posted, you will need to provide your email address. Your email address will be deleted from the system once the notification email is sent. Your question will be posted anonymously, along with the answer, on SmartSexResource. (3) Privately: If you do not want your question to be posted anonymously on SmartSexResource, you can request that the nurse email the answer directly to you. You will need to provide your email address. Your email address will be kept confidential.
- Live Chat with a Nurse: A temporary username is required to enter into a chat room with a nurse. We strongly discourage the use of your real name or other potentially identifying information in your username. The username that you specify will expire at the end of your chat session, meaning that you can use the same name or a different name for your next chat session.
- Creating an Account: You will need an account if you want to post comments on questions and answers in the Ask Us section. This is to protect SmartSexResource from fraudulent use (e.g., spam) and misuse. You will need to provide your email address, a username and a password to create an account. Once you have created an account, your email address and password will be required to log into your account. Because your username will display when you post a comment, we strongly discourage the use of your real name or other potentially identifying information in your username. Your account information will be kept confidential.
- Adding Comments: You will require an account to post comments on SmartSexResource. When you post a comment, your username will appear next to the comment.
- Contact form: If you have questions, comments or complaints about SmartSexResource, you can send them anonymously using the form on the Contact Us page. If you want to receive a response to your question or comment, you will need to provide your email address. Your email address will be kept confidential.
User Surveys: From time to time, the BCCDC will post a user survey on SmartSexResource. These surveys are for evaluation purposes only, to help us understand how we can improve the Site and the services that it provides. If you respond to a survey, the information that you provide will only be used for analysis and reporting, and will be provided anonymously. It will not be linked to you and cannot be used to identify you. Surveys will be hosted by FluidSurveys. All surveys will be hosted on Canadian servers and all survey data collected will be stored on Canadian servers.
How Else May We Use or Disclose Your Personal Information?
Information that you provide becomes a record subject to the Freedom of Information and Protection of Privacy Act and may be used and disclosed in accordance with that Act.
From time to time, the BCCDC engages employees, representatives, agents or contractors to perform additional work on the Site, such as maintenance or an upgrade to the Site. Access to information about our users is never granted unless it is required to do the work, and in those cases, only the minimal amount of information is made available. Any service providers or individuals who provide such work on the Site are required to provide written privacy protection and confidentiality undertakings, and owe legal obligations to maintain the privacy of all personal information.
We may disclose or share the information you provide if it is required for law enforcement purpose, if it is subject to a Court order, or if the disclosure is otherwise required by law. Disclosure of any acts that imply sexual abuse of a minor, or committing a sexual assault as well as harms to self or others, will be reported as per legal requirements (e.g.., to the Ministry of Child and Family Development).
Authority for the Collection
The BCCDC is collecting information from you for the purpose of providing the information and services you are requesting on the Site. The BCCDC makes every effort to avoid any unnecessary collection of personal information, but some of our services require you to provide a small amount of information that may identify you (e.g., email address).
The collection of any personal information you provide is permitted in accordance with section 26(c) of FIPPA, which allows the BCCDC to collect personal information for purposes related to and necessary for its operating programs and activities.
How We Protect Your Personal Information
The privacy and security of your personal information is of great importance to the BCCDC, and we protect the information you provide on SmartSexResource by taking the measures described below. We collect only the minimum amount of information required to ensure that our services are as confidential and private as possible. However, the Internet is not completely secure, as third parties may unlawfully intercept or access communications. While we are committed to protecting your personal information, we cannot guarantee its absolute security.
The BCCDC takes the following measures to protect your personal information:
- For the protection of your privacy and the privacy of others, we strongly discourage you from including any personal information about yourself or others in any content that you post to the Site.
- All BCCDC employees, representatives, agents and contractors must comply with Provincial Health Services Authority and BCCDC privacy and confidentiality requirements.
- We use many methods (encryption, firewalls, restricted access to data, etc.) to protect your information against unauthorized access, collection, use, disclosure or disposal.
- We limit the number of BCCDC employees who can access the non-public information you provide on our site (e.g., email address, username, chat transcripts). Only those employees with a need to know have access to this information.
- Any information used for statistical, reporting, site evaluation and site improvement purposes is not linked with any information that could be used to identify you.
- We do not communicate with you by email except to respond to a question that you have asked. We will never sell or provide your email address to other companies, entities or individuals.
- All questions submitted using the Ask A Question feature will be reviewed by a moderator and any identifying information will be removed before questions and answers are posted on the Site.
- Any new comments posted to the Site will be reviewed by the moderator within three (3) business days (except on long weekends) to identify and delete any content that may identify individuals.
You can modify or delete your account information at any time. The record of your account is not saved anywhere outside of the Site.
Content that you submit to the Site (except for your account information) will be retained indefinitely. This includes the following information:
- Questions that you send to a nurse using the Ask A Question feature,
- Chat room conversations using the Chat feature,
- Comments that you add using the Add A Comment feature.
- Any comments or questions that you submit using the Contact Us form.
We retain this information indefinitely to maintain the continuity of the information on the Site, to evaluate the use and value of the Site, and to retain a record of any advice provided by the nurses, as required by the College of Registered Nurses of British Columbia.
When you are logged into your account, you can delete any comments that you have added to the Site. Deleted comments will no longer display on the Site but a record of these comments will be retained indefinitely for the purposes explained above.
The Internet is not a fully secured method for communicating. Information that is submitted over the Internet, including through a website or email, is subject to interception or incorrect routing. This means that if you send a message using the Contact Us page or another e-mail address published on SmartSexResource, the information provided may be intercepted. If you use the Ask A Question feature and request that the nurse email you the answer directly, the email may also be intercepted. Please consider this before submitting any information to SmartSexResource.
The BCCDC is not responsible for any damages suffered by individuals as a result of the email transmission of information that is sent to or from the BCCDC. The BCCDC is not responsible for any errors or changes made to information that is transmitted by email.
Cookies are small amounts of information that a website places in a file associated with the web browser on your computer. Cookies are used by SmartSexResource to collect non-personal information that allows the user to interact with the Site in an effective way and improves the usability of the Site.
SmartSexResource uses temporary cookies (“session cookies”), which means that the information collected is temporary in nature and is deleted as soon as you close your browser. If you have signed up for an account on SmartSexResource, you will be required to login every time.
Accessing and Updating Your Personal Information
You can update your account information or delete your account at any time. You can also delete any comments that you have posted and they will no longer display on the Site. A log of all comments will be retained indefinitely, stored on a secured Provincial Health Services Authority server.
To delete any comments that you have made, log into the website, locate your comment that you wish to remove (in the Ask Us section) and click Delete Comment.
To delete your account, you must follow a two-step process. First, log into the website and on your profile page, click the Delete Account button. You will see a second page that asks you to confirm that you want to delete your account – click the Delete button on this page. Second, you will receive an email asking you to complete the account deletion process. Click on the link in the email to complete the process.
SmartSexResource contains links to other websites. The BCCDC is not responsible for the privacy practices of these websites. Please review the privacy policies for these sites and make sure that you agree with their policies before proceeding.
Tips For Protecting Your Privacy
- Your email address and password are required to access your SmartSexResource account. Do not share your password with anyone.
- The information that you post on SmartSexResource in the form of questions or comments is publically available to everyone using the internet. Do not post anything that you want to keep private.
- When posting content to SmartSexResource (e.g., questions, comments), do not include your name or someone else’s name and do not provide any other information that can be used to identify you or someone else.
- Clear your browser history and cache after each use of the Site or use your browser’s anonymous browsing mode.
- Use an email account with a name that is not linked to your real name or other information which could identify you.
Copyright © 2018. Provincial Health Services Authority. All Rights Reserved.
Last revision date: August 2018