What is personal information?
Personal information is information about an identifiable individual. Personal information includes information that related to their personal characteristics (e.g. Gender, age, income, home address or phone number, ethnic background, family status), their health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, 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
We collect personal information: Primary purpose:
Like all massage therapists, 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 massage therapy 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 are occurring over time. It would be rare for us to collect such information without the client’s express (written) consent, but this might occur in an emergency (e.g., the client is unconscious) 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 my 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 purposes for collecting personal information is to provide notice of special events (e.g., a seminars or conferences) or to make them aware of massage therapy services in general at 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 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. 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 for (e.g., to respond to your email message, to register for a course, to notify and remind you of booking dates and times). Cookies are only used to help you navigate our website and are not used to monitor you.
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 example of related and secondary purposes is 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. To advise clients that their product or service should be reviewed (e.g., to ensure a product 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 may have available. Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may on my behalf do audits and continuing quality improvement reviews of our clinic, including reviewing client files only if they have the authority by law to do so. Massage therapists are regulated by the College of Massage Therapists of Ontario who may inspect our records and interview us as 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 Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview us as a part of their mandates. In these circumstances, we may consult with professions (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. We retain your client information for a minimum of 10 years after the last contact to enable us to respond to questions you may have about products or services you have previously received. (The College of Massage Therapists of Ontario also requires us to retain your client records).
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). 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. In addition, passwords are used on computers. All of my cell phones are digital, which signals are more difficult to intercept. Paper information is transmitted through sealed, addressed envelopes or through personal email addresses. Electronic information is transmitted through a direct line or secured site. External consultants and agencies can only collect personal information if you provide written notice of what type of information is to be released and to whom.
Retention and destruction of personal information
We need to retrain personal information for 10 years 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 not want to keep personal information too long in order to protect your privacy. We keep our client files for about 10 years. Our client and contact directories are much more difficult to systematically destroy, we remove such information when we can and when 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 until after the newsletter ceases publication or a seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We employ reputable companies to perform the shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire client file to the client. Privacy Breach In the event of a privacy breach, Core Elements Advanced Massage Therapy will notify its clients of the theft, loss or unauthorized access to their personal information.
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.) 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 the 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 your file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information. If you wish to make a formal complaint about our privacy practices, you may make it in writing. We will acknowledge receipt of your complaints: investigate it promptly and ensure 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, please discuss this with Dawn Oehring. If we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
COLLEGE OF MASSAGE THERAPISTS OF ONTARIO
1867 Yonge Street, Suite 810 Toronto, ON M4S 1Y5
416-489-2626, (800) 465-1933
Facsimile (416) 489-2625