WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to personal characteristics (e.g., gender, age, home address or phone number, cultural background, family status, education status), health (e.g., health history, health conditions, health services received) or activities and views (e.g. 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
Therapy Spot includes a small group of speech-language pathologists, Instructor Therapists, Psychologist, Communication Disorders Assistant and support staff. To assist us in providing services, we use consultants that may, in the course of their duties, have limited access to personal information we hold, such as: computer consultants, office security and maintenance, bookkeepers and accountants, cleaners 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.
PRIMARY PURPOSES FOR PERSONAL COLLECTING INFORMATION
Our primary purpose for collecting personal information is to provide speech-language pathology services. For example, we collect information about your health history that will be relevant to communication disorders and assist us in offering effective intervention options. A second primary purpose is to obtain a baseline of your communication skills and/or to track changes over time. It would be rare for us to collect such information without your express consent, but this might occur in an emergency (e.g., the patient/client is unconscious) or where we believe you would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from you and we have no reason to believe that the message is not genuine).
About Members of the General Public
Our primary purpose for collecting contact information about members of the public is to make them aware of speech-language pathology services in general or our services in particular. We try to obtain consent before using any personal contact information, but where this is not possible, we will, upon request, immediately remove the information from our distribution list.
About Contract Staff, Employees,Volunteers and Students
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal contact information is to ensure we can get in touch with them for employment purposes to better serve our patient/clients. 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., an infectious disease outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in our office). We also collect information in order to do performance appraisals, provide feedback to students’ instructors or write references if requested.
Related and Secondary Purposes for collecting personal information
Therapy Spot also collects, uses and discloses information for purposes related to or secondary to our primary purposes. The most common examples are as follows:
To secure payment for goods or services.
To advise patients/clients of the need for follow-up services.
To advise patients/clients and others of special events or opportunities (e.g., a seminar, a new service, a new product).
To evaluate our services and the performance of our staff. This may involve external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) to do audits and continuing quality improvement reviews of our services, including reviewing patient/client files and interviewing our staff.
To allow us to meet our regulatory obligations. The College of Audiologists and Speech-Language Pathologists may inspect our records and interview our staff as a part of their regulatory activities in the public interest. Various government agencies (e.g., Canada Customs and Revenue Agency, Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. External regulators have their own strict privacy obligations. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
To provide information to third party payers (e.g., OHIP, WSIB, private insurance, Assistive Devices Program) when they pay for the goods and services you receive from us. We will obtain your consent to disclose your personal information in these instances except in instances where there is legislative authority to collect, use or disclose the information.
To answer any questions you may have about the service you received once it is concluded. The College of Audiologists and Speech-Language Pathologists requires that we keep records for at least 10 years following your last intervention or in the case of a child, 10 years past the child’s 18th birthday.
To allow us to provide required information to a prospective purchaser if this practice or its assets are to be sold, in order to conduct a “due diligence” review of our accounting and service files. 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.
If you choose not to be part of some of these related or secondary purposes, please let us know so that we may take the appropriate measures where possible.
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. Our computers are password protected. Our cell phones are digital as these signals are more difficult to intercept.
Paper information is sealed and transmitted by reputable companies.
Special care is taken to ensure privacy when transmitting electronic information. Where we are unsure of the security of the electronic transfer of information, identifying information is removed.
External consultants and agencies with access to personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
The College of Audiologists and Speech-Language Pathologists of Ontario requires that we retain our patient/client records for 10 years past the last visit or in the case of a child, for 10 years past the child’s 18th birthday. We destroy our files within three to six months of that time. These files include your contact information. Contact directories will be updated when practicable or upon request. Contact information for members of the public is kept for 3 years unless requested to do so earlier.
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 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 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 our professional opinions. 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 OR A CONCERN?
If you have a question or a concern, you can reach Simone Friedman, Owner and S-LP, at:
1232 Dufferin Street | Toronto, ON | M6H 4C3 PHONE 416-546-3044
She will attempt 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 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 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 complain to our regulatory body, the College of Audiologists and Speech-Language Pathologists of Ontario.
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 Office of 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 www.privcom.gc.ca