Privacy of personal information is an important principle to the Kemptville Chiropractic Clinic and Dr. Parnell Crook Chiropractic Professional Corporation. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We try to be open and transparent about how we handle personal information. This document describes our privacy policies.
What is Personal Health Information?
Personal health information is information about an identifiable individual (e.g. name, date of birth, gender, home address, email address, phone numbers, and health related numbers etc.). Personal health information also includes information that relates to:
• the physical or mental health of the individual (including family health history);
• the provision of health care to the individual (including identifying the individual’s health care provider);
• payments or eligibility for health care or coverage for health care;
• the identification of the individual’s substitute decision-maker.
Who We Are
Our organization, Kemptville Chiropractic Clinic and Dr. Parnell Crook Chiropractic Professional Corporation, includes three Chiropractors and two support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal health information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, lawyers, temporary workers to cover holidays, debit card companies, website managers and cleaners. 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.
Why We Collect Personal Health Information
We collect, use and disclose personal information in order to serve our patients.
For our patients, the primary purpose for collecting personal health information is to ensure our patients are provided with the best care possible. For example, we collect information about a patient’s health history, including their family history, their
physical condition (record of examination findings) in order to help us assess our patients, and to arrive at a diagnosis. We can then determine our patient’s health needs and formulate a treatment plan so that we can advise our patients about 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.
For our patients, secondary purposes for collecting health information:
We also collect, use and disclose personal health information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
1) To obtain payment for services or goods provided. Payment may be obtained from the individual, WSIB, private insurers or others. This may be in the form of an invoice or letter, and for the purpose of collecting payment for care received at our clinic.
2) To communicate with our patients, (appointment reminders, missed appointments either by phone or electronically by email. There may be occasion that a voice message is left on an answering machine or with the person answering the phone. We may also call out a patient’s name in the clinic reception area to direct them to the appropriate treatment room and health provider.
3) To conduct quality improvement and risk management activities. We review client files to ensure that we provide high quality services, including assessing the performance of our staff. External consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may conduct audits and quality improvement reviews on our behalf. It is also possible that health information will be disclosed during audits by government appointed agencies as part of their quality assurance and compliance reviews.
4) Our professionals are regulated by the College of Chiropractors of Ontario who may inspect our records and interview our staff as a part of its regulatory activities in the public interest. The College of Chiropractors of Ontario has its own strict confidentiality and privacy obligations. 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 illegal behaviour to the authorities. In addition, we may be required by law to disclose personal information to various government agencies (e.g. Ministry of Health, children’s aid societies, Canada Customs and Revenue Agency, Information and Privacy Commissioner, etc.).
5) To educate our staff and students. We value the education and development of future and current professionals. We will review client records in order to educate our staff and students about the provision of health care.
6) To facilitate the sale of our organization. If the organization or its assets were to be sold, the potential purchaser would want to conduct a “due diligence” review of the organization’s records to ensure that it is a viable business that has been honestly portrayed. The potential purchaser must first enter into an agreement with the organization to keep the information confidential and secure and not to retain any of the information longer than necessary to conduct the due diligence. Once a sale has been finalized, the organization may transfer records to the purchaser, but it will make reasonable efforts to provide notice to the individual before doing so.
Protection of personal information for the General Public
For members of the general public, our primary purpose for collecting personal information is for public awareness of our services in general or our clinic in particular. On our website we only collect, with the exception of cookies (cookies are small files that are stored on your device), the personal information you provide and only use that information for the purpose you gave us. For example, to respond to the public’s email messages left for us through our website. Kemptville Chiropractic Clinic does not use any personal information from the general public or from patients, or from cookies, during visits to our website.
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 restricted area. When the clinic is closed, the clinic is locked and only Doctors and regular staff have access to keys to the clinic.
• Electronic hardware is either under supervision or secured in a restricted area. In addition, strong passwords are used on all computers and mobile devices.
• Personal health information is only stored on mobile devices if necessary. All personal health information stored on mobile devices is protected by strong encryption.
• Sometimes it may be necessary for us to bring your personal health information home with us to work on there. In those circumstances, we transport, use and store the personal health information securely.
• Paper information is transferred through sealed, addressed envelopes or boxes by reputable companies with strong privacy policies.
• Electronic information is either anonymized or encrypted before transmission and from a direct line.
• We do not post any personal information about our clients on social media sites and our staff members are trained on the appropriate use of social media sites.
• 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, in order to protect your privacy, we do not want to keep personal information for too long. We keep our patient files for at least seven years from the date of the last patient interaction or from the date the patient turns 18. We destroy paper files containing personal health information by cross-cut shredding or incinerating the private information. We destroy electronic information by deleting it in a manner that it cannot be
restored. When hardware is discarded, we ensure that the hardware is physically destroyed or the data is erased or overwritten in a manner that the information cannot be recovered.
You Can Look at Your Records
With only a few exceptions, you have the right to see what personal information we hold about you, by contacting Dr. Parnell Crook (information officer). She can help you identify what records we might have about you. She will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). She will need to confirm your identity, if she does not know you, before providing you with this access. Fees cannot be charged for collecting and using personal health information. Only reasonable fees can be charged for the disclosure of personal health information. The information and Privacy Commissioner of Ontario has established guidelines for charging fees for this purpose which we reserve the right to follow. According to decisions made by the Information and Privacy Commissioner, it is reasonable to charge $30.00 for processing a request and copying the first 20 pages, and then 25 cents for every additional page. Dr. Crook may ask you to put your request in writing. She will respond to your request as soon as possible and generally within 30 days, if at all possible. If she cannot give you access, she will tell you the reason, as best she can, as to why.
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. At your request and where it is reasonably possible, we will notify anyone to whom we sent this information (but we may deny your request if it would not reasonably have an effect on the ongoing provision of health care). 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.
If there is a Privacy Breach
While we will take precautions to avoid any breach of your privacy, if there is a loss, theft or unauthorized access of your personal health information we will notify you. Upon learning of a possible or known breach, we will take the following steps:
• We will contain the breach to the best of our ability, including by taking the following steps if applicable
o Retrieving hard copies of personal health information that have been disclosed
o Ensuring no copies have been made
o Taking steps to prevent unauthorized access to electronic information (e.g., change passwords, restrict access, temporarily shut down system)
• We will notify affected individuals
o We will provide our contact information in case the individual has further questions
o We will provide the Commissioner’s contact information and advise the affected individual of their right to complain to the Commissioner
• We will investigate and remediate the problem, by:
o Conducting an internal investigation
o Determining what steps should be taken to prevent future breaches (e.g. changes to policies, additional safeguards)
o Ensuring staff is appropriately trained and conduct further training if required
Depending on the circumstances of the breach, we may notify and work with the Information and Privacy Commissioner of Ontario. If we take disciplinary action against one of our practitioners [or revoke or restrict the privileges or affiliation of one of our practitioners] for a privacy breach, we are required to report that to the practitioner’s regulatory College. We may also report the breach to the relevant regulatory College if we believe that it was the result of professional misconduct, incompetence or incapacity.
Do You Have Questions or Concerns?
Our Information Officer, Dr. Parnell Crook, can be reached at:
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, and ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
You also have the right to complain to the Information and Privacy Commissioner of Ontario if you have concerns about our privacy practices or how your personal health information has been handled, by contacting:
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Telephone: Toronto Area (416/local 905): (416) 326-3333
Long Distance: 1 (800) 387-0073 (within Ontario)
TDD/TTY: (416) 325-7539
FAX: (416) 325-9195
This policy is made under the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3. It is a complex statute and provides some additional exceptions to the privacy principles that are too detailed to set out here.