Privacy of personal information is an important principle to Renew Physiotherapy. We are committed to collecting, using and disclosing personal information responsibly and only information relevant to the services we provide. We also try to be open 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, phone number, ethnic background, family status), and their health (e.g., health history, health conditions, health services received by them). Personal information is to be contrasted with the business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
Our organization, Renew Physiotherapy, includes a number of professionals that may, in the course of their duties, have limited access to personal information we hold. These include physiotherapists, therapeutic massage therapists, ergonomist consultants, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, 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.
COLLECTION OF PERSONAL INFORMATION: PRIMARY PURPOSES
Like all healthcare providers, we collect, use and disclose information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide physiotherapy/massage treatment. For example, we collect information about a client’s health history, physical condition and function and social situation in order to help us assess what their needs are, to advise them of their options and then to provide information so that in providing ongoing services we can identify changes that are occurring over time.
For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a physical therapy seminar) or to make them aware of Renew Physiotherapy’s services. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We 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 clients 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 you gave it to us to use (e.g., to respond to your email message, to register, change or cancel an appointment). Cookies are only used to help you navigate our website and are not used to monitor you.
For people who are contracted to work for us, our primary purpose for collecting personal information is to ensure we can contact them for necessary work-related communication. Examples of the type of personal information collected for those purposes include home, date of birth, social insurance number 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., local pandemic outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur). 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 only as authorized by them.
COLLECTION OF 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 was not paid for at the time, to produce credit card payments or to collect unpaid accounts.
- To advise clients that their service should be reviewed (e.g., to ensure an exercise program is still appropriate for their then current needs and to consider modifications).
- 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., auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf to do audits and continuing quality improvement reviews of our clinic, including reviewing client files and interviewing staff.
- Physiotherapy Services are regulated by the College of Physiotherapists 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 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 serious 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 the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada 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., lawyers, accountants) who will investigate the matter and report back to us.
- 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. The college of Physiotherapists of Ontario requires us to retain our client records for 10 years.
If Renew Physiotherapy were to be sold, the purchaser would likely 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 with 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 College 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, as such signals are more difficult to intercept.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
- External consultants and agencies with access to personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
Renew Physiotherapy needs to retain personal information to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies.
We keep our client files for ten years.
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.
YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you. We can help 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 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 your 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 QUESTION?
We can be reached at firstname.lastname@example.org.
We will attempt to answer any questions or concerns you might have.
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 contact our regulatory body:
COLLEGE OF PHYSIOTHERAPISTS OF ONTARIO
This policy is made under the Personal Health Information Protection Act. It 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