Updated September 24, 2014
The Canadian Resident Matching Service (“CaRMS”) has always placed the highest value on ensuring the confidentiality of applicant information, including any personal information, provided to us. In the course of providing our services, CaRMS collects personal information and we have prepared this policy to inform you about our ongoing commitment to ensuring that the personal information obtained during the course of our activities remains accurate and confidential.
What is personal information?
We consider “personal information” to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information. This policy does not cover “business contact information” (e.g. name, title, business address) or aggregated data from which the identity of the individual cannot be determined. CaRMS retains the right to use business contact information or aggregated data in any ethical way that it determines appropriate.
Why CaRMS may collect personal information
CaRMS may use the personal information provided verbally or in writing (including via electronic media) by applicants, medical schools or other third parties in order to:
- Determine an applicant’s eligibility for CaRMS’ online services;
- Provide and communicate information about CaRMS services and timetables to applicants, medical schools or other third parties;
- Collect and distribute medical school applications and documentation, to participating undergraduate institutions;
- Match applicants with postgraduate medical residency programs;
- Provide applicants’ required personal information to the undergraduate or postgraduate office or their designate at the medical school where the applicant has applied for undergraduate medical school or matched to a postgraduate medical residency.
- Provide an applicant’s social insurance number to the postgraduate office or its designate at the medical school where the applicant was matched to a postgraduate medical residency;
- Conduct surveys of applicants in order to analyze, for statistical and research purposes, such issues as demographics of applicants, influences on career choices, residency selection experiences, etc.;
- Provide application and training statistics to participating undergraduate medical schools;
- Provide match results to the residency programs where applicants are matched and to the medical schools from which applicants have graduated;
- Manage our relationship with applicants and medical schools;
- Meet legal and regulatory requirements; and
- Such other purposes consistent with these purposes.
How CaRMS collects and uses personal information
CaRMS only collects, uses and discloses personal information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes listed above. We use only fair and lawful methods to collect personal information. Personal information is routinely collected from all applicants through: CaRMS’ online services, documents submitted via regular mail, electronic mail and fax to be added to the applicant’s file, and telephone calls to the CaRMS help desk for verification purposes.
Our use and disclosure of personal information is limited to the purposes described in this policy and CaRMS does not otherwise sell, trade, barter, exchange or disclose for consideration any personal information it has obtained.
When CaRMS may disclose your personal information
CaRMS may disclose your personal information to:
- Individuals or organizations who use our application and/or residency matching services;
- Medical schools where an applicant has applied for undergraduate medical education;
- The medical school from which an applicant has graduated and the residency program(s) where an applicant has applied and is matched;
- Organizations who require the information for statistical and research purposes (e.g. BCI); and
- Individuals or organizations that perform services on behalf of CaRMS, including those involved in maintaining, reviewing and developing our systems, procedures and infrastructure, including testing or upgrading our computer systems.
Where CaRMS discloses personal information to third party organizations, CaRMS will enter into a written agreement to require that the organization use and disclose such information solely for specified permitted purposes and have appropriate safeguards for the protection of that personal information.
In some cases, the individuals or organizations that perform services on behalf of CaRMS may use or store personal information outside of Canada. Personal information stored outside Canada may be subject to different laws than those in Canada and may be accessible to law enforcement agencies outside of Canada where permitted by law. CaRMS is committed to the protection of privacy and will evaluate the privacy implications associated with disclosing personal information to a third party service provider in a given jurisdiction before establishing a relationship in which personal information will be disclosed.
Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where CaRMS is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
- Where CaRMS believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to establish or collect monies owing to CaRMS;
- Where it is necessary to permit CaRMS to pursue available remedies or limit any damages that we may sustain; or
- Where the information is public.
Where obliged or permitted to disclose information without consent, CaRMS will not disclose more information than is required.
The information submitted to CaRMS on both the applicant’s and the program’s rank order list is confidential. It will not be released or disclosed in any manner that permits individual identification of either applicants or programs.
As per the applicant agreement, CaRMS will share your personal information with the National Resident Matching Program (NRMP) if you have applied to a residency program in the United States. The NRMP uses personal information for the purpose of operating a mapping program so as to manage matches that occur in both Canada and the United States. When CaRMS sends personal information to the NRMP, it will be stored outside of Canada. As noted above, personal information stored outside of Canada will be subject to the laws of that jurisdiction.
Unless permitted by law, no personal information is collected without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose personal information after it has been collected in those cases where CaRMS wishes to use the information for a purpose not identified in this policy, not previously identified or for which the individual concerned has not previously consented.
The provision of personal information to CaRMS means that the person concerned agrees and consents that we may collect, use and disclose their personal information in accordance with this policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time.
In most cases and subject to legal and contractual restrictions, an individual is free to refuse or withdraw his or her consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, services can only be offered if a person provides personal information to CaRMS. Consequently, if an individual chooses not provide us with any required personal information, we may not be able to offer the services requested.
The accuracy and retention of personal information
CaRMS endeavors to ensure that any personal information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. CaRMS provides the opportunity for individuals to update their personal information to ensure accuracy and currency. Individuals are responsible for ensuring that their personal information is accurate and have access to change it at any time. CaRMS will use its best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records.
We keep your personal information only as long as it is required for the reasons it was collected. This period may extend beyond the end of an individual’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your personal information is no longer required for CaRMS’ purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.
Protection of personal information
CaRMS endeavors to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information. This also applies to our disposal or destruction of personal information.
CaRMS further protects personal information by restricting access to it to those employees with a need to know that information in order for us to provide our services or information.
If any employee of CaRMS misuses personal information, this will be considered a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses personal information that was provided for the purpose of providing services to or for CaRMS, this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between CaRMS and that individual or organization.
Access to your personal information
CaRMS permits the reasonable right of access and review of personal information held by us about an individual and will endeavor to provide the information in question within a reasonable time, usually within 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.
CaRMS reserves the right not to change any personal information but will append any alternative text the individual concerned believes to be appropriate.
CaRMS reserves the right to decline to provide access to personal information where the information requested:
- Would disclose (i) personal information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other confidential business information that may harm CaRMS or the competitive position of a third party or interfere with contractual or other negotiations of CaRMS or a third party;
- Is subject to solicitor-client or litigation privilege;
- Is not readily retrievable and the burden or cost of providing it would be disproportionate to the nature or value of the information;
- Does not exist, is not held, or cannot be found by CaRMS;
- Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual;
- May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
- Any other grounds under applicable legislation.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
CaRMS will not respond to repetitious or vexatious requests for access and in making such a determination, we will consider such factors as the frequency with which information is updated, the purpose for which the information is used and the nature of the information.
CaRMS will not charge you for verifying or correcting your information; however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.
Resolving your privacy concerns
In the event of questions about: (i) access to your personal information; (ii) our collection, use, management or disclosure of personal information; or (iii) this policy, please contact firstname.lastname@example.org.
CaRMS will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.