Privacy of personal information is an important principle to all of us at the Center for Pediatric Excellence. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for services we provide. We are 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 an individual’s personal characteristics (e.g. gender, age, home address or phone number, education and training, family circumstances); health (e.g. health history, health conditions, health services received); or, activities and views (e.g. occupation/profession, ideas and concerns expressed by an individual). Personal information is different from business information which is not protected by privacy legislation.
Our organization, Center for Pediatric Excellence, includes physicians, physician assistants, psychologists, psychometrists, occupational therapists, and administrative assistants as well as students in the above fields.
REASONS FOR COLLECTING PERSONAL INFORMATION
We collect, use, and disclose personal information only in order to provide medical, psychological and allied health care provider services to our clients. For example, we collect information about a client’s health history, including their family history, physical condition and function and social situation to help us assess what their health needs are, to advise them of their options and then to provide the services they choose to have. We also obtain a baseline and ongoing record of functioning so that in providing services we can monitor treatment progress and identify changes that occur over time.
In some situations, the primary purpose of collecting personal information would be to conduct an assessment to provide a professional opinion about the individual’s functioning. With the client’s consent, the opinion would be reported to the appropriate person or agency, for example, an insurance company, Workplace Safety and Insurance Board, psychological/legal reports, no-fault automobile insurance, Children’s Aid Society and rehabilitation companies.
It would be rare for us to collect or disclose personal information without the client’s express consent, but this might occur in an emergency (in this case the client would be notified in writing as soon as possible) or if 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).
For members of the general public who have contacted us, our primary purposes for collecting personal information (e.g. contact numbers, email etc.) are to make them aware of the range of services available in our clinic and to direct them to the appropriate service provider.
HERE ARE SOME ADDITIONAL REASONS WHY WE COLLECT PERSONAL INFORMATION.
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 services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
- Psychologists, Physicians and Occupational therapists are regulated by their respective College’s (ie. College of Physician and Surgeons of Ontario). Regulating colleges may inspect our records and interview our service providers as a part of their regulatory activities in the public interest. The regulating colleges also have their own strict privacy obligations.
- The cost of some services provided by the organization to clients is paid for by OHIP or by third parties (e.g. private insurance, WSIB, automobile insurance, First Nations and Inuit Health Branch, Canadian Forces, CUPE). 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 (e.g. Canadian Forces identification, First Nations identification).
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. Passwords are used on computers.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable couriers or Canada Post.
- Electronic communication is on authorization of individuals and/or through a secure portal
LIMITS TO PROTECTION OF PRIVATE INFORMATION
Limits to the protection of private information include: legally required disclosure to the Children’s Aid Society, Regulatory Colleges of the health care service providers and Court orders to release information, search warrants for a file in a criminal or a legal case, subpoenas, sexual abuse of a patient to the regulatory body of the regulated health care provider and legally required disclosure to the Retirement Homes Regulatory Authority and the Director of long-term care facilities.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to 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.
- Clients or other individuals we deal with may have questions about our 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. The College of Psychologists of Ontario also requires us to retain our client records. For clients who are seen before the age of 18, records are retained for ten years following their 18th birthday.
- If Center for Pediatric Excellence were sold, none of the client records would be transferred to or accessed by the new owners.
- We destroy electronic information by deleting it and, when the hardware is replaced or discarded, we ensure that the hard drive is physically destroyed. Personal information that is not part of the permanent clinical file is shredded.
- In the case of the psychologist’s retirement or death, the client records are given to another psychologist for safe-keeping but not for examination.
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. abbreviations, technical language, etc.). We may need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a fee for such requests. 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 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?
Our Information Officer is Dr. Judy van Stralen. She can be reached at:
Center for Pediatric Excellence
206-1637 Woodroffe Avenue, Ottawa, ON, K2G 1W2
Tel 613-726-7355 Fax 613-726-7567
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 written decision with reasons.
This policy is made under the Personal Information Protection and Electronic Documents Act.
For more general inquiries, the Information and 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 Information and Privacy Commissioner can be reached at:
30 Victoria Street
Gatineau, QC K1A 1H3 or J8X 0B3
Phone (819) 994-5444 or 1-800-282-1376 | Fax (819) 994-5424 | TTY (819) 994-6591
Our policy is also determined by and is compliant with The Ontario Personal Information Act. The Ontario Information and Privacy Commission can be reached at 1-800-387-0073 – www.ipc.on.ca. or at Registrar, Information and Privacy Commissionaire of Ontario, 2 Bloor Street W., Suite 1400, Toronto, ON M4W 1A8