Privacy of personal information is an important principle to Dundas University Health Clinic. 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, address, etc.), their health (e.g. health history, health conditions, other treatment received, etc.), or their activities and views (e.g. religion, politics, opinions, etc.). 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.
COLLECTION OF PERSONAL INFORMATION: PRIMARY PURPOSES
Like all health clinics, we collect, use, and disclose personal information in order to serve our clients. The primary purpose for collecting personal information is to provide multidisciplinary health care treatment. 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 may occur 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 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 purpose for collecting personal information are to provide notice of special events (e.g. a seminar or workshop) or to make them aware of clinic 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.
Dundas University Health Clinic only collects, with the exception of cookies, the personal information you provide (e.g. email addresses) and only use that information for the purpose you gave it to us (e.g. to respond to your email message or subscribe to a newsletter). Cookies are only used to help you navigate our web site and are not used to monitor your activity.
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 paychecks, 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 (e.g., SARS) or to investigate a possible breach of law (e.g., if theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or and evaluations, we will collect information about their work related performance and provide a report 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. Most common examples of our related and secondary purposes are as follows:
- To invoice clients for goods or services 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 such as an orthotic 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 (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 do audits and continuing quality improvement reviews on our Clinic, including reviewing client files and interviewing out staff.
- All of our practitioners are monitored by their respective regulatory bodies (except Shiatsu) 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 behavior 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 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. lawyers, accountants) 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 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 College also requires us to retain our client records).
- If Dundas University Health Clinic or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’s records to insure 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).
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.
- Paper information is transmitted through sealed addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted either through a direct line and/or is encrypted.
- External consultants and agencies with access to personal information must enter into privacy agreements with us (e.g. confidentiality agreements).
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We 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 no want to keep personal information too long in order to protect your privacy.
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 one year after the newsletter ceases publication or a 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.
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 no 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 files 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?
The information officer for Dundas University Health Clinic is Dr. Laura Cory who can be reached at:
Dr. Laura Cory
Dundas University Health Clinic
438 University Avenue, Suite 104
Toronto, Ontario Canada M5G 2K8
Tel: 416-598-4999 Fax: 416-598-0606
Every attempt will be made to answer any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to the information officer. They 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 concern about the professionalism or competence of our services or 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 make a complaint to the appropriate regulatory body. This contact information is provided below.
College of Chiropractors of Ontario (CCO)
130 Bloor Street West, Suite 902
Toronto, Ontario Canada M5S 1N5
Tel: 416.922.6355 Fax: 416.925.9610
Email: email@example.com Web: www.cco.on.ca
College of Physiotherapists of Ontario
230 Richmond Street West, 10th Floor
Toronto, Ontario Canada M5V 1V6
Tel: 416.591.3828 Toll Free: 1.800.583.5885 Fax: 416.591.3834
Email: firstname.lastname@example.org Web: www.collegept.org
College of Massage Therapists of Ontario
1867 Yonge Street, Suite 810
Toronto, Ontario Canada M4S 1Y5
Tel: 416.489.2626 Toll Free: 1.800.465.1933 Fax: 416.489.2625
Email: email@example.com Web: www.cmto.com
Ontario Association of Naturopathic Doctors
344 Bloor Street West, Suite 602
Toronto, Ontario Canada M5S 3A7
Tel: 416.233.2001 Fax: 416.233.2924
Email: firstname.lastname@example.org Web: www.oand.org
College of Chiropodists of Ontario
180 Dundas Street West, Suite 2102
Toronto, Ontario Canada M5G 1Z8
Tel: 416.542.1333 Toll Free: 1.877.232.7653 Fax: 416.542.1666
Email: email@example.com Web: www.cocoo.on.ca
The Shiatsu Therapy Association of Ontario
73 Bathurst Street, Suite 306
Toronto, Ontario Canada M5V 2P6
Tel: 416.923.7826 Toll Free: 1.877.923.7826
Email: firstname.lastname@example.org Web: www.shiatsuassociation.com
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 Information and Privacy Commissioner of Canada oversees the administration of the privacy sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Inquiries: 1.800.282.1376 (toll-free) or 819.994.5444