Collection of Personal Health Information:

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We collect your personal health information directly from you, or from the person acting on your behalf.  Examples of the type of personal health information that we collect may include, your name, date of birth, address, health history, records of your appointments and details of the treatment that you received during your visits.  We may sometimes collect personal health information about you from other sources, if we have obtained your consent to do so, or if the law permits.

 

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, and opinion or evaluation of an individual).  Personal information is to be contrasted with business information (e.g., in individual’s business address and telephone number), which is not protected by privacy legislation.

 

Uses and Disclosures of Personal Health Information:

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We may use and disclose your personal health information for the following purposes:

• Treat and care for you;

• Receive or directly invoice for your treatment and care (e.g., WSIB, private insurer, others);

• Plan, administer and manage our internal operations;

• Conduct risk management and quality improvement activities;

• Teach;

• Compile statistics;

• Comply with legal and regulatory requirements;

• Fulfill other purposes permitted or required by law;

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Your Rights:

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You may access and correct your personal health records, or withdraw your consent for some of the above uses and disclosures (subject to legal exceptions) by contacting our contact person.

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Our Responsibilities:

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We take steps to protect your personal health and financial information from theft, loss, unauthorized access, copying, modification, use, disclosure, and disposal.

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We conduct audits to monitor and manage our privacy compliance

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We take steps to ensure that everyone who performs services for us protects your privacy and only uses your personal health information for the purposes you consented.

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We Collect Personal Information: Primary Purposes

About Clients

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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 treatment.  For example, we collect information about a client’s health history, including family history, physical condition and function and social situation, in order to help us assess what the client’s health needs are, to advise the client of his/her options and then to provide the health care the client chooses to have.  A secondary 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 clients express consent, but this might occur in an emergency (e.g., the client 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 on from our client we have no reason to believe the message is not genuine).

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We Collect Personal Information: Related and Secondary Purposes

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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:

• To invoice clients for those goods and services that were not paid for at the time, to process credit card payments, or to collect unpaid accounts.

• To advise clients that their product or service should be reviewed (e.g., to ensure a product is still functioning properly and appropriate for their current needs and to consider modifications or replacement).

• To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new product) that we have available.

• Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff.  In addition, external consultants (e.g., lawyers, auditors, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our Clinic, including reviewing client files and interviewing our staff.

• Massage Therapists are regulated by the College of Massage Therapists of Ontario who may inspect our records and interview staff as a part of their regulatory activities in the public interest.  In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own.  Also, our organization believes that it should report information suggesting illegal behaviour to the authorities.  External regulators have their own strict privacy obligations.  Sometimes these reports include personal information about our clients, or other individuals, to support our concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates.  In these circumstances, we may consult with professionals (e.g., accountants, lawyers) who will investigate the matter and report back to us.

• The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., OHIP, WSIB, private insurance, Assistive Devices Program).  These third party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.

• Clients or other individuals we deal with may have questions about our goods and services after they have been received.  We also provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful.  We retain our client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services ( our regulatory College also requires us to retain our client records).

• If 'HOIT' or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the records to ensure that it is a viable business that has been honestly portrayed to the purchaser.  This due diligence may involve some review of our accounting and service files.  The purchaser would not be able to remove or record personal information.  Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential.  Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

 

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).

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Protecting Personal Information:

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We understand the importance of protecting personal information.  For that reason, we have taken the following steps:

• Paper information is either under supervision or secured in a locked or restricted area.

• Electronic hardware is either under supervision or secured in a locked or restricted area at all times.  In addition, passwords are used on computers.  All of our cell phones are digital, which signals are more difficult to intercept.

• Paper information is transmitted either through direct line or is anonymized or encrypted.

• Electronic information is transmitted either through direct line or is anonymized or encrypted.

• Staff is trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.

• External consultants and agencies with access to personal information must enter into privacy agreements with us.

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Retention and Destruction of Personal Information:

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We need to retain personal information for some time to ensure that we can answer any questions you might have about our 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.

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We keep our client files for ten years.  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 (i.e., with people who are not clients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.

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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 all of the client file to our client.

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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 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.

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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 made a mistake, we will still agree to include our file in a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.