As part of our standard of care we promise to provide the highest standard of treatment and care for you and your family. Part of that promise is the protection of your personal information.
Privacy of personal information is an important principle to Pathways Therapy. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be 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 their personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status), their health (e.g. 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.
Who we are
Our organization, Pathways Therapy, provides rehabilitation services. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These may include but are not limited to lawyers or accountants retained by Pathways Therapy. We restrict their access to any personal information we hold as much as it is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
We collect personal information
Like all health professionals, 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 physiotherapy / occupational 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 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 our 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 are to provide notice of special events (e.g. a seminar or conference) or to make them aware of physiotherapy / occupational therapy services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and e-mail addresses. 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 the personal information you provide any only use that information for the purpose you gave it to us (e.g. to respond to your e-mail message, to register for a course, to subscribe to our newsletter).
About Contract Staff, Volunteers and Students
For people who are contracted to do work for us (e.g. temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending out pay cheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. 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. a SARS outbreak) or to investigate a possible breach of law (e.g. if a theft were to occur in the clinic). 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.
Why we collect personal information
Like all rehabilitation businesses, we collect, use and disclose personal information in order to serve our clients.
For our clients, the primary purposes for collecting personal information are as follows:
- To obtain contact information so that we may contact you if necessary, for example to inform you of an appointment time
- To provide appropriate treatment to our clients
- To identify any contraindications to treatment
- In order to contact clients when necessary
- In order to provide clients with information regarding Pathways Therapy and the services we provide
Examples of the type of personal information we collect for those purposes include information such as name, address, telephone number and health information relevant to an individuals care.
For members of the general public, our primary purposes for collecting personal information are so that we may provide interested parties with information regarding Pathways Therapy and our services. Examples of the type of personal information we collect for those purposes include name, address, telephone number or other contact information
When we investigate, audit or assess a person for someone else (e.g. such as for a legal investigation, financial audit, medical assessment), our primary purposes for collecting personal information are so that we may contact the individual for which the assessment is being completed and so that we may collect any data which may be relevant for completing the assessment. Examples of the type of personal information we collect for those purposes include contact information such as name, address, telephone number and health information relevant to completing the assessment of the individual.
Related and secondary purposes requiring Pathways Therapy to 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: so that we may contact you about Pathways Therapy services that may be of interest to you or to send you information, such as newsletters, that may be of use to individuals receiving our services.
The most common examples of our related and secondary purposes are as follows:
- To invoice clients for goods or services that were not paid for at the time the service was rendered, to process credit care 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 have available.
- Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our clinic, including reviewing client files and interviewing our staff.
- Our regulated health professionals are registered with their respective regulatory college, who may inspect our records and interview our staff as a 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 our 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 to us.
- The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g. 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.
- 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 the Pathways Therapy clinic or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the clinic’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our 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 (e.g. by declining to receive notice of special events or opportunities, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g. external regulation).
- You can choose not to be part of some of these related or secondary purposes (e.g. by declining special offers or promotions, by paying for your services in advance). 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 our cell phones are digital, which signals are more difficult to intercept.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted either through a direct line or is anonymized or encrypted.
- 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. 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, 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 information right away.
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 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 no 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 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 concern?
Our Information Officer, Stephanie Boyd, can be reached at Pathways Therapy office at (519) 885-4211 extension 222 to address 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.
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
Fax: (613) 947-6850
TTY (613) 992-9190