Fraser Pelvic Health - Privacy Policy
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Privacy policy
Privacy of personal information is an important principle to Fraser Pelvic Health. 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 (for example: gender, age, income, home address or phone number, ethnic background, family status), their health (ie. health history, health conditions, health services received by them) or their activities and views (ie. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (ie. an individual’s business address and telephone number), which is not protected by privacy legislation.
Who We Are
Fraser Pelvic Health, at the time of writing, includes:
1 Orthopaedic/ Pelvic Health Physiotherapist (Michelle Fraser, PT)
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 maintenance, bookkeepers and accountants, credit card companies, website managers, 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. Each has signed a confidentiality agreement and a privacy agreement.
We Collect Personal Information
Primary Purpose For Collecting Personal Information
About Clients
Like all health care practitioners, 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 health care 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 (ex. the client is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (ex. a family member passing a message on 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 are to provide notice of special events (ex. a seminar or conference) or to make them aware of health care services in general or Fraser Pelvic Health services 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, for any reason, this is not possible, we will upon request immediately remove any personal information from our distribution list.
On our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose for which you provided it (ex. to respond to your email message, to register for a course, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.
About Contract Staff, Volunteers and Students
For people who are contracted to do work for us, our primary purpose for collecting personal information is to ensure that we can contact them in the future (ex. for new assignments) and for necessary work-related communication (ex. 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 (ex. a SARS outbreak) or to investigate a possible breach of law. If 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.
Related and Secondary Purposes For Collecting Personal Information
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 goods or 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 (ex. to ensure a product is still functioning properly and appropriate for their then current needs and to consider modifications or replacement)
· To advise clients and others of special events or opportunities that we have available (ex. a seminar, development of a new service, arrival of a new product)
· 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 (ex. auditors, lawyers, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of Fraser Pelvic Health, including reviewing client files and interviewing our staff.
· Physiotherapists are regulated by a regulatory body who may inspect our records and interview our staff as part of their regulatory activities in the public interest. External regulators have their own strict privacy obligations.
· In addition, as professionals, we will report serious misconduct, incompetence or incapacity or other practitioners, whether they belong to other organizations or our own. Also, Fraser Pelvic Health believes that it should report information suggesting serious illegal behaviour to the authorities. Sometimes these reports include personal information about our clients or other individuals to support the concern. Also, like all organizations, various government agencies (ex. Canada Revenue Agency, Information and Privacy Commissioner of Ontario, Human Rights Commissions, 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 (ex. lawyers, accountants) who will investigate the matter and report back to us.
· The cost of some goods/ services provided by Fraser Pelvic Health to clients is paid for by third parties, for example, by private health insurance). 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 or 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 10 years after the last contact to enable us to respond to those questions and provide these services. Our regulatory colleges also require us to retain our client records.
· If Fraser Pelvic Health or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the business’ 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 Fraser Pelvic Health 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 secondary purposes (ex. by declining to receive notice of special events or opportunities, by paying for your services at the time of service). We do not, however, have much choice about some of these related or secondary purposes (ex. external regulation).
Protecting Personal Information
Personal information is stored by Fraser Pelvic Health in both electronic and paper formats.
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
· At all times, electronic hardware is either under supervision or secured. Additionally, passwords are used on computers.
· All of our cell phones are digital, as such signals are more difficult to intercept.
· Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies
· Electronic information is transmitted either through a direct line or is anonymized or encrypted
· All affiliated with Fraser Pelvic Health are trained to collect, use and disclose personal information only as necessary to fulfil 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
· No documents containing patient identifiers/ personal information are removed from the premises of Fraser Pelvic Health.
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.
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, then we will remove such contact information right away. We keep any personal information relating to our general correspondence (ex. 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.
We destroy paper files containing personal information by shredding by a third party. We destroy electronic information that is stored locally by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some of or the entire client file to our client.
You Can Look at Your Information
With only 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 (ex. 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, then we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if possible and tell you the reason, as best we can, 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 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 Question?
Our Information Officer, Michelle Fraser, can be reached at the following address. She will attempt to answer any questions or concerns you may have.
Fraser Pelvic Health
603-1375 Dupont Street
Toronto, Ontario
M6H 4J8
fraser@fraserpelvichealth.com
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and ensure 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
This policy was developed in accordance with 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.
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 type of ombudsman for privacy disputes. The Office of the Privacy Commissioner of Canada can be reached at:
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
Online Information Request Form is available at www.priv.gc.ca/cu-cn/index_e.asp
Fax: (819) 994-5424
TTY: (819) 994-6591
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3