We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. This document describes our privacy polices in accordance to the Regulated Health Professions Act and the Massage Therapy Act (1991), and the Personal Health Information Protection Act (PHIPA).
WHAT IS PERSONAL INFORMATION?
Personal information is information about identifiable individuals. Personal information includes information that relates to:
an individual’s personal characteristics (e.g., gender, age, income, home address or telephone number, ethnic background, family status);
health (e.g., health history, health conditions, health services received by them);
activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual).
Personal information is different from business information (e.g., an individual’s business address and telephone number). This is not protected by privacy legislation.
WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES
Like all medical professions, 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 treatment. For example, we collect information about a client’s health history, including their family history, physical condition, 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 on going health services we can identify changes that occur over time.
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 was not paid for at the time, to process credit card payments or to collect unpaid accounts.
Our clinic reviews clients 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, practice consultants) may on our behalf do audits and continuing quality improvement reviews of our Clinic, including reviewing client files and interviewing our staff.
Registered Massage Therapists are regulated by the College of Massage Therapists of Ontario (CMTO). The CMTO 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., 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 goods/services provided by the organization to clients is often paid for by third parties (e.g., motor vehicle accident insurance, private insurance). These third party payers often have the client’s 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 retain our client information for a mandatory minimum of ten years after the last contact to enable us to respond to those questions and provide these services.
BOOKING ONLINE: WHAT INFORMATION DO WE COLLECT?
We do not collect any Personally Identifiable Information when browsing our site. We may, however, collect information such as time of day, browser type and IP address. This information is used to make improvements on our site.
When you book an appointment online we collect personal information necessary to provide you with the service you have requested.
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 secure in a locked or restricted area at all times. In addition, passwords are used on computers. Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
Electronic information is transmitted either through a direct line or has identifiers removed or is encrypted.
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 question the client may have about the services provided and for our own accountability to external regulatory bodies.
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.
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