Destination Wellness Privacy Policy
Last Updated April 2016
Privacy of personal information is important to Destination Wellness, which is committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for operations, in accordance with the PIPEDA. This document describes the privacy policies of Destination Wellness in an effort to be open and transparent about how personal information is handled.
What Is Personal Information?
Personal information is information about an identifiable individual. It includes information that relates to their personal characteristics (ie. gender, age, income, home address or phone number, ethnic background, family status), their health (ie. 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 (ie. an individual’s business address and telephone number), which is not protected by privacy legislation.
Who is Destination Wellness?
Destination Wellness is operated by Shelley Martin as a sole-proprietor. Consultants and agencies such as accountants, credit card companies, insurance companies, lawyers and web designers may in the course of their duties have limited access to personal information. Access is restricted as much as is reasonably possible and with assurance that they follow appropriate privacy principles.
Primary Purposes of Personal Information Collection
About Clients
The primary purpose for collecting personal information from clients is to provide safe and appropriate care. For example, information is collected about a client’s health history, current level of function, physical condition, goals of care in order to assess needs and provide treatment options and recommendations. Another primary purpose is to obtain a baseline of health and social information so that we can identify changes occurring over time. It would be rare to collect such information without express consent but may occur where we believe the client would consent if asked and it is impractical to obtain consent (ie. A family member passing a message on from a client and there is no reason to believe that the message is not genuine).
About Members of the General Public
For members of the general public, the primary purposes for collecting personal information are to provide notice of special events (ie. A community event or workshop) or to make them aware of wellness services in general or Destination Wellness in particular. We try to obtain consent before using any 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 (ie. to respond to your email message). Cookies are only used to help you navigate our website and are not used to monitor you.
About Contract Staff, Volunteers and Students
For people who are contracted to do work for Destination Wellness (ie. Accountants, consultants), the primary purpose for collecting personal information is to ensure the ability to contact them in the future (ie. for new assignments) and for necessary work-related communication (ie. sending out paycheques, yearend tax receipts). Examples of the type of personal information collected for those purposes include home addresses and telephone numbers. It would be rare to collect such information without prior consent, but it might happen in the case of a health emergency (ie. Exposure to a contagion), or to investigate a possible breach of law (ie. theft). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.
Related and Secondary Purposes of Personal Information Collection
The most common examples of related and secondary purposes of personal information collection are as follows:
· To invoice clients for goods and services 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 (ie. 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 specials or opportunities that are available, such as community events or workshops.
· Destination Wellness reviews client and other files for the purpose of ensuring provision of high quality services. In addition, external consultants (ie. auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews including reviewing client files and interviewing staff.
· Also, Shelley Martin is regulated by the College of Physiotherapists of Ontario who may inspect her records and interview her as a part of their regulatory activities in the public interest. In addition, as a professional, she will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or the CPO. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about clients, or other individuals, to support the concern (ie. improper services).
· Various government agencies (ie. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission) have the authority to review files and interview 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.
· The cost of some services provided by the organization is reimbursed by private insurance companies. 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.
· Clients or other individuals we deal with may have questions about our goods or 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 (our regulatory College also requires us to retain our client records).
· If Destination Wellness or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of records to ensure that it is a viable business that it has been honestly portrayed to the purchaser. This due diligence may involve some review of accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. 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.
· You can choose not to be part of some of these related or secondary purposes (ie. by declining to receive notice of special events or opportunities, by paying for your services immediately). We do not, however, have control over some of these related or secondary purposes (ie. external regulation).
Protecting Personal Information
Destination Wellness understands the importance of protecting personal information. For that reason, the following steps have been taken:
• 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 area at all times. In addition, passwords are used on computers and cell phones.
• Paper information is personally delivered or transmitted through sealed, addressed envelopes in person, via Canada Post or another reputable company.
• Staff is trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• 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 you might have about the services provided and for our own accountability to external regulatory bodies.
We keep our client files for a minimum of ten years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if 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 (ie. with people who are not clients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.
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. Alternatively, we may send some or the entire client file to our client.
You Can Look At Your Information
With only a few exceptions, you have the right to see what personal information Destination Wellness holds about you. Often all you have to do is ask. We can help you identify what records we might have and will also try to help you understand them (ie. short forms, technical language, etc.). We will need to confirm your identity 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 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, Shelley Martin, can be reached at:
(905)517-4395 or at shelley@destinationwellness.ca
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:
College of Physiotherapists of Ontario
375 University Avenue
Suite 901
Toronto, Ontario
M5G 2J5
Tel: 416-591-3828
Toll Free: 1-800-583-5885
Fax: 416-591-3834
email: info@collegept.org
www.collegept.org
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 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