Protection of personal information is of utmost importance to our organization. We will collect, use and disclose personal information responsibly and only to the extent necessary for the services we provide. This document describes our privacy policies.
PERSONAL INFORMATION DEFINITION
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics, their health or their activities and views. Personal information is to be contrasted with business information, which is not protected by privacy legislation.
WHO WE ARE
Our organization provides medical examination services in the areas including but not limited to Orthopaedics, Neurology, Neuropsychology, Physiatry, Psychiatry, Psychology, Dentistry, Family Medicine, Occupational Therapy Services, Kinesiology, Physiotherapy, Chiropractic 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. We restrict their access to any personal information we hold as much possible. We also have their assurance that they follow appropriate privacy principles.
WE COLLECT PERSONAL INFORMATION
We collect, use and disclose personal information in order to serve our clients. We collect personal information for our clients to provide independent medical examination services. For example, our examiners collect information about a client’s health history, including their family history, physical condition and social situation in order to assess what their health status is, and to answer specific questions posed by the referring source. It would be rare for us to collect information without the client’s express consent, but this might occur in an emergency or where we believe the client would consent if asked.
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 referral sources for goods or services that were provided, and to provide transportation and interpretation services to our clients.
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 may do audits and continuing quality improvement reviews of our Clinic, including reviewing client files and interviewing staff.
Consultants are regulated by their professional Colleges, and as professionals, they 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 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. 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 most of the goods/services provided by our organization to clients is paid for by third parties (e.g. auto insurance). These third-party payers often have client consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to 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 (Regulatory Colleges also require our examiners to retain 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. We do not, however, have much choice about some of these related or secondary purposes.
PROTECTING PERSONAL INFORMATION
We have a secure system in place for protecting our personal information files.
It is as follows:
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.
Electronic information is transmitted either through a direct line or is anonymized or encrypted.
Paper information is either under supervision or secured in a locked or restricted area.
Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
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 confidentiality agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We must keep personal information for some time to ensure that we can answer any questions that may arise about the services provided and for our own accountability to external regulatory offices. However, we do not want to keep personal information too long in order to protect your privacy. Our closed client files are stored at a secured and offsite facility and are systematically destroyed. 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
You have the right to see what personal information we hold about you, with only a few exceptions. 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. We will need to confirm your identity before providing you with this access. We reserve the right to charge a nominal fee for such requests. If there is a third party payer involved, 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 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 our medical examiners 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.