Privacy Policy

 

Privacy of personal information is an important principle to Balance Chiropractic.  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 (eg.  gender, age, home address, phone number, family status), their health (eg. health history, health conditions, health services received by them) or their activities and views (eg. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).  Personal information is to be contrasted with business information (eg. an individual’s business address and telephone number), which is not protected by privacy legislation.

 

Who We Are

Our organization, Balance Chiropractic, includes at the time of writing two chiropractors, Drs. Matthew and Margaret-Anne Falconer.  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 include accountants, credit card companies, lawyers and temporary professionals to cover holidays.  We restrict their access to any personal information we hold as much as is reasonably possible.  We also have their assurance that they follow appropriate privacy principles.

 

We Collect Personal Information:  Primary Purposes

 

About Patients

Like all chiropractors, we collect, use and disclose personal information in order to serve our patients.  For our patients, the primary purpose for collecting personal information is to provide chiropractic.  For example, we collect information about a patient’s health history, including their family history, physical condition and function and social situation in order to help us assess their health needs, to advise them of their options and then provide the health care recommendations 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 patient’s express consent, but this might occur in an emergency or where we believe the client would consent if asked and is impractical to obtain consent (eg. 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 schedule appointments for new patients as well as contacting winners of trade show draws.  In such situations, only a name and phone number are collected.

 

About Contract Staff

For people who are contracted to do work for us (eg. X-ray taking), our primary purpose for collecting personal information is to ensure we can contact them for necessary work-related communication (eg. diagnosis, scheduling, sending out payment).  It is rare for us to collect such information without prior consent, but might happen in the case of a health emergency or to investigate a possible breach of law.  If contract staff 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 patients for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.

To advise patients and others of special events or opportunities (eg. a seminar, an open house, development of a new service, changes in fees).

- To check the health status of a regular patient.

- To relate radiographic findings to a patient.

-To perform necessary home visits.

 

Our clinic reviews patient 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 (eg. auditors, lawyers, practice consultants) may on our behalf do audits and continuing quality improvement reviews of our clinic, including reviewing patient files and interviewing our staff.

 

Chiropractors are regulated by the College of Chiropractors of Ontario 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.  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 patients, or other individuals to support the concern (eg.  improper services).  Also, like all organizations, various government agencies (eg. Ministry of Health, 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 part of their mandates.  In these circumstances, we may consult with professionals (eg. 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 (eg. WSIB, private insurance).  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 patients over a period of months or years for which our previous records are helpful.  We retain our patient information for a minimum of ten years after the last contact or until a child turns eighteen to enable us to respond to those questions and provide these services.

 

If Balance Chiropractic 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 (ie. 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 due to 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 all computers. 

Paper information is transmitted either through sealed, addressed envelopes or boxes by reputable shipping companies.

Electronic information is transmitted through a direct line with privacy clause included.

Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.  No documentation is released without written authorization from the patient and/or their legal guardian.

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 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 personal information relating to our general correspondence 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 all, of the patient file to our patient.

 

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 (eg. 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 an error, 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, Dr. Margaret-Anne Falconer, can be reached at:

Balance Chiropractic

858 Lancaster Drive, Kingston, ON K7P 1R6

Phone / Fax: (613) 384-6797

balance.frontdesk@gmail.com

 

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 Chiropractors of Ontario

130 Bloor St. West, Suite 902

Toronto, Ontario M5S 1N5

Phone: (416) 922-6355

Fax: (416) 925-9610

 

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 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

Toll Free: 1-800-282-1376

Fax: (613) 947-6850

www.priv.gc.ca