Privacy of personal information is an important principle at Physiotherapy and Beyond. As such 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 and if you have any questions or concerns we will do our best to address them.
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.
At Physiotherapy and Beyond as of the date of this document the staff (permanent and contract) includes four physiotherapists, one registered massage therapist, one on-call occupational therapist, one dietitian, kinesiology staff and four support staff. 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 computer consultants, office security and building maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, cleaners and lawyers. 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 and monitor their activity where possible.
Like all physiotherapy and medical offices, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purposes for collecting personal information are to provide rehabilitation services including, physiotherapy, registered massage therapy, dietetic, manual therapy, occupational therapy as well as exercise based rehabilitation programs. In order to this effectively we collect personal information. 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).
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 the Physiotherapy and Beyond clinic and its services as appropriate. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email 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. With respect to email communication in particular we will make all efforts to comply with all antispam legislation. 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 (e.g., to respond to your email message, to register for a course, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.
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, yearend 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.
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:
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
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 any personal information relating to our general correspondence (e.g., 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 with a record kept of its destruction where possible. Alternatively, we may send some or the entire client file to our client if requested for a nominal fee.
With only a few exceptions, you have the right to see what personal information we hold about you. Generally 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 are unable or cannot give you access, we will inform you within 30 days if at all possible and with the reason, as best we are able, as to why we cannot or are unable to provide 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. In order to maintain the accuracy of our information, we may ask you to provide documentation that our files or personal information are incorrect. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information as required. 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 as appropriate or required.
Our Information Officer is Raafat Rofail who can be reached at:
Physiotherapy and Beyond
8 Stavebank Road North
Phone: (905) 278-7101
Fax: (905) 278-9005
He 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. He 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 bodies:
College of Physiotherapists of Ontario
375 University Ave.
Toronto ON M5G 2J5
Phone: (416) 591-3828 / 1-800-583-5885
Fax: (416) 591-3834
College of Massage Therapists of Ontario
375 University Ave.
Toronto ON M5G 2J5
Phone: (416) 591-3828 / 1-800-583-5885
Fax: (416) 591-3834
College of Occupational Therapists of Ontario
20 Bay Street
Suite 900, PO Box 78
Phone: 416-214-1177 / 1 (800) 890-6570
College of Kinesiologists of Ontario
160 Bloor Street East
Phone: (416) 961-7000
Fax: (416) 961-7009
College of Dietitians of Ontario
5775 Yonge Street
Suite 1810, Box 30
Phone: (416) 598-1725 / 1-800-668-4990
Fax: (416) 598-0274
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
Phone (613) 995-8210 / Toll-free 1-800-282-1376
Fax (613) 947-6850
TTY (613) 992-9190