Privacy of personal information is an important principle to Rebalance Sports Medicine. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
WHAT IS PERSONAL HEALTH INFORMATION?
In Ontario, personal health information is covered under the Personal Health Information Protection Act (PHIPA). Personal Health Information is very broadly defined in PHIPA and includes the following components:
Rebalance Sports Medicine collects, retains, destroys when appropriate, and discloses all personal health information in accordance with PHIPA. Please see our brochure “Your Health Information and Your Privacy in Our Office” for more information.
WHO WE ARE:
Our organization Rebalance Sports Medicine includes at the time of last revision consultant physiotherapists, consultant registered massage therapists, consultant chiropractors, consultant pilates instructors, consultant naturopaths, consultant sports physicians and administrative support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays/vacations, credit card/merchant terminal services provider companies, cleaners and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES
Like all physiotherapy/rehabilitation clinics we collect, use and disclose personal information in order to serve our clients.
For our clients, the primary purpose for collecting personal information is to provide physiotherapy and related (registered massage therapy, chiropractic, fitness) services. For example, we collect information about a client’s health history, including their family history, physical condition and function and social situation in order to help us assess what their health needs are, to advise them of their options and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that are occurring over time. It would be rare for us to collect such information without the client’s express consent, but this might occur in an emergency (e.g. the clients is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message from our client and we have no reason to believe that the message is not genuine).
About Members of the General Public
For members of the general public, our primary purposes for collecting personal information to provide notice of special events (e.g. seminar or conference) or to make them aware of physiotherapy and related services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason possible, we will upon request immediately remove any personal information from our distribution list.
About Contract Staff, Volunteers and Students
For people who are contracted to do work(e.g., temporary workers/students/volunteers), our primary purposes for collecting personal information is to ensure that we can contact them in the future (e.g. for new assignments) and for necessary work-related communication(e.g. sending out paycheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g. a SARS outbreak) or to investigate a possible breach of law (e.g. if a theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.
WE COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES
Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Please note that as e-mail is not a secure medium we do not as a policy initiate transmission of any personal or personal health information or identify a patient/client in an email unless specifically requested to do so by him/her. We only use email for general communications. If you choose to send us an email containing any personal or personal health information, it is implied that you have consented to providing us with this information in this manner. If you have concerns about your information being intercepted by an unauthorized party, you should consider contacting us by phone or another secure method of communication.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We keep our client files for about 10 years from the date of last entry (or 10 years past the age of 18 if the client was under 18 at the time of the last entry. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our clients, newsletters, seminars and marketing activities for about 2 years after the newsletter ceases publication, seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire client file to our client.
YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
DO YOU HAVE A CONCERN?
Our Information Officer, Alishah Merchant can be reached at Rebalance Sports Medicine, 110 Yonge St. Suite 905, Toronto, Ontario, M5C 1T4, phone (416) 777-9999 to address any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer(s). He/they will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory bodies:
COLLEGE OF PHYSIOTHERAPISTS OF ONTARIO
375 University Ave. Suite 901, Toronto, Ontario, M56 2J5
COLLEGE OF MASSAGE THERAPISTS OF ONTARIO
1867 Yonge St. Suite 810, Toronto, ON M4S 1Y5
COLLEGE OF CHIROPRACTORS OF ONTARIO
130 Bloor St W. Suite 902, Toronto, ON M5S 1N5
This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. Specific policies pertaining to personal health information are made under the Personal Health Information Protection Act.
For more general inquiries, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Privacy Commissioner can be reached at:
112 KENT STREET | OTTAWA, ONTARIO | K1A 1H3
PHONE (613) 995-8210 | TOLL-FREE 1-800-282-1376 | FAX (613) 947-6850 | TTY (613) 992-9190 www.privcom.gc.ca
Inquiries pertaining to personal health information in Ontario can be directed to:
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, ON, M4W 1A8
Phone: 416-326-3333 or 1-800-387-0073