Privacy of personal information is an important principle to our organization. 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.
Lead the Way Affiliates’
Privacy of personal information is an important principle to our organization. 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.
WHO WE ARE
Our organization includes physiotherapists, massage therapists, chiropodists, kinesiologists and
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 accountants, bookkeepers,
computer consultants, office maintenance, credit card companies, cleaner, lawyers and payroll
services. 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 Rehabilitation and Health Care Centres, we collect, use and disclose personal information in order to serve our clients.
For our clients, the primary purposes for collecting personal information are as follows: to provide you with physical rehabilitation services. For example, we collect information about a client’s health history, including their family history, physical condition 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 information without the client’s 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 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 (e.g., a seminar, conference) or to make them aware of physiotherapy/massage therapy 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.
On our website we will only collect, with the exception of cookies, the personal information you
provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a seminar, to subscribe to our newsletter).
About Contract Staff, Volunteers and Students
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for
collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, yearend tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. 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:
- 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 service should be reviewed.
- To advise clients and others of special events or opportunities (e.g., seminars, development
of a new service) 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, the external
consultants (e.g., lawyers, 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 staff.
- Physiotherapist are regulated by the College of Physiotherapists of Ontario, Massage
Therapists are regulated by the College of Massage Therapists of Ontario, Chiropodists are
regulated by the College of Chiropodists of Ontario and Occupational Therapists are regulated by the College of Occupational Therapists of Ontario who may inspect our records and
interview our staff as a part of their regulatory activities in the public interest. In addition, as
professionals we 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 serious illegal behaviour to authorities.
External regulators have their own strict privacy obligations. Sometimes these reports
include personal information about our clients, or other individuals, to support the concern
(e.g., improper services). Also, like all organizations, various government agencies (e.g.,
Canada Customs and Revenue Agency, 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., lawyers, accountants) who will
investigate the matter and report back to us.
- The cost of some of the goods/services provided by the organization to clients is paid for by
third parties (e.g. WSIB, private insurance, auto insurance, OHIP). 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 ten 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 a Clinic or its assets were to be sold, the purchaser would want to conduct a “due
diligence” review of the Clinic’s 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
special offers or promotions, 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:
- 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 through sealed, addressed envelopes or boxes by reputable
- Electronic information is transmitted either through a direct line or is anonymized or
- Staff is trained to collect, use and disclose personal information only as necessary to fulfill
- External consultants and agencies with access to personal information must enter into
privacy agreements with us.
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 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
with people who are not our clients, newsletters, seminars and marketing activities for about six
months after the newsletter, 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, Lori Neill, can be reached at:
555 George St. N., Peterborough, ON K9H 3S1
PHONE: 705 741-2284
She will attempt to answer any questions 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. She 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 question 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
College of Physiotherapists of Ontario
375 University Ave, Suite 901 Toronto, On M5G 2J5
College of Massage Therapists of Ontario
1867 Yonge St. Suite 810, Toronto, On M4S 1Y5
College of Chiropodists
180 Dundas St. W, Suite 2102, Toronto, On M5G 1Z8
College of Occupational Therapists of Ontario
20 Bay Street, Suite 900, PO Box 78 Toronto, On M5J 2N8
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. 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