WHAT IS PERSONAL INFORMATION?
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 health care professionals, we collect, use and disclose personal information in order to serve 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, and function 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.
WE COLLECT PERSONAL INFORMATION: Related and Secondary Purposes
Like most organizations, we also collect, use and disclose information for purposes 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.
We review clients and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our RMTs. In addition, external consultants (e.g., auditors, practice consultants) may on our behalf do audits and continuing quality assessment reviews of our clinic, including reviewing client files and interviewing our RMTs.
Registered Massage Therapists are regulated by the College of Massage Therapists of Ontario (CMTO). The CMTO may inspect our records and interview our RMTs as a part of their regulatory activities in the public interest. Also, the CMTO requires us to 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., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our RMTs 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 services provided by the clinic to clients is sometimes paid for by third parties (e.g., private insurance e billing). 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 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.
PROTECTING PERSONAL INFORMATION We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Paper information is secured in a locked filing cabinet.Electronic hardware is safe coded via passwords. Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
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 questions the client may have about the services provided and for our own accountability to external regulatory bodies.
We keep our clients files for 10 years according to our College regulations.
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. 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 not 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 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 have 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.