Privacy of personal information is an important principle to Therapy Specialties. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the provision of high quality health care. 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 agency, Therapy Specialties, includes Occupational Therapists, Physiotherapists, Speech and Language Pathologists, Registered Dietitians, Social Workers and support staff. We may use consultants and agencies that, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office maintenance workers, accountants, temporary workers to cover holidays, website managers, cleaners, interpreters and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their written assurance that they follow appropriate privacy principles.

WE COLLECT PERSONAL INFORMATION :
PRIMARY PURPOSES

About Clients

We collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting information is to provide assessment and 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. A secondary 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 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 paycheques, 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 our agency). 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.

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 examples of our related and secondary purposes are as follows:

• To invoice clients or agencies for services rendered
• Our agency 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 agency including reviewing client files and interviewing our staff.
• Therapy Specialties' professional staff are regulated by their respective colleges (including The College of Occupational Therapists of Ontario, The College of Physiotherapists of Ontario, The College of Audiology and Speech and Language Pathology of Ontario, Dietitians of Canada and The Ontario College of Social Workers and Social Service Workers) who may inspect our records and interview our staff 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. Our organization believes that it should report information suggesting serious illegal behavior to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information abut our clients, or other individuals, to support the concern (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commissioner, etc.) have the authority to review our files and interview our staff as 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 therapy services provided by the agency 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.
• Clients or other individuals we deal with may have questions about our therapy 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 very helpful. We retain our client information a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory Colleges also require us to retain our client records).
• If Therapy Specialties or its assets were to be sold, the purchaser would want to conduct a "due diligence" review of the agency'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.

PROTECTING PERSONAL INFORMATION

We understand the importance of protecting personal information. For that reason, we have taken the following steps that are supported through agency policy and procedure:

•  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 or conversations are void of identifiers.

•  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.

•  Staff are 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. However, we do not want to keep personal information longer than required in order to protect your privacy. We keep our client files for a minimum of ten years.

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. 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.). 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 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 the information. If we not agree that we have made a mistake, we still will 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 Privacy Officer can be reached at:

Therapy Specialties
183 Erie Avenue , Brantford N3S 2G8
PHONE (519) 750-0345 or 1-877-336-3363

and 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 Privacy Officer. This person 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 the appropriate regulatory bodies.

The College of Occupational Therapists of Ontario
20 Bay Street, Suite 900
Toronto , Ontario M5J 2N8
Telephone: 1-800-890-6570
http://www.coto.org/

The College of Physiotherapists of Ontario
230 Richmond St. W., 10th Floor
Toronto, ON M5V 1V6.
www.collegept.org  

The College of Audiology and Speech and Language Pathology of Ontario
160 Bloor St. E., Suite 1125
Toronto, Ontario M4W 1B9
Telephone: 416-975-5347 or 1-800-993-9459
TTY: 416-975-8726
Fax: 416-975-8394
http://www.caslpo.com/

Dietitians of Canada
480 University Avenue, Suite 604
Toronto, ON M5G 1V2
Telephone: 416-596-0857
Fax: 416-596-0603
http://www.dietitians.ca/

The Ontario College of Social Workers and Social Service Workers
80 Bloor St. W, Suite 700
Toronto, ON M5S 2V1
Phone: 416-972-9882
Fax: 416-972-1512
http://www.ocswssw.org/

This policy is made under the Personal Information and Electronic Documentations Act. This 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 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:

112 Kent Street
Ottawa , ON
K1A 1H3
Phone (613)995-8210 or 1-800-282-1376
FAX (613)947-6850
TTY (613)992-9190
www.privcom.gc.ca