Privacy of personal information is an important principle to Proactive Pelvic Health Centre. 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, Proactive Pelvic Health Centre, includes health care practitioners such as: Registered Physiotherapists, Registered Massage Therapists, Naturopathic Doctor, Registered Social Worker, Registered Psychotherapist, Registered Occupational Therapist, and Registered Kinesiologist. We are each trained to treat a variety of conditions although have chosen pelvic conditions as a focus of this organization. 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, computer consultants, business consultants, office cleaners, credit card companies 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.
We Collect Personal Information: Primary Purposes
Like all physiotherapy and multi-disciplinary health care centres, 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 provide assessment, treatment and other services related to your injury or illness
- To obtain payment for the assessment, treatment or other services we provide and determine any entitlement to insurance coverage or other benefits
- To identify treatment outcomes to be able to share this with referral sources.
Examples of the type of personal information we collect for those purposes include the following: name, home contact information, gender, age, education and training, marital status, sexual history, income, health history, health measurements, samples or examination results, health conditions, assessment results, diagnoses, health services provided to or received by the person, health information collected in the course of providing services, prognosis or other opinions formed during assessment and treatment, compliance with assessment and treatment, reasons for discharge condition and recommendations, occupation/ profession, community involvements and work hours. This information will allow our practitioners to understand the problems you may have, how it affects your daily function and help set personal goals and a treatment plan specific to your needs.
For members of the general public, our primary purposes for collecting personal information are as follows:
- For marketing the services we provide
- To notify about special events, workshops and courses
Examples of the type of personal information we collect for those purposes include the following: name, address 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.
For contract staff (e.g., temporary workers, physiotherapist, registered massage therapists, etc.), our primary purposes for collecting personal information are as follows:
- To ensure appropriate contact on file for emergencies
- To ensure the hire of professional and competent individuals
- To have contact information in case of changes in work schedules or for future referrals
- For any work related communication.
Examples of the type of personal information we collect for those purposes include the following: name, home contact information, education and training, health history, health conditions, occupation/ profession, community involvements, work hours, criminal involvement, disciplinary actions against the individual, existence of a dispute with the organization, intentions, involvement with the organization, letters written to the organization by the person.
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 for goods/services that are not paid for at the time and collect unpaid accounts
- To advise clients and others of special events and opportunities (ie: seminars, workshops, classes) that we have available
- Our organization reviews clients 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 organization, including reviewing client files and interviewing our staff.
- Physiotherapists are regulated by the College of Physiotherapists of Ontario (Occupational Therapists by the College of Occupational Therapists of Ontario, Massage Therapists by the College of Massage Therapy of Ontario, Social Workers by the Ontario College of Social Workers and Social Services, Psychotherapists by the College of Registered Psychotherapists of Ontario, Naturopathic Doctors by the College of Naturopaths of Ontario, and Kinesiologists by the College of Kinesiologists 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 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., private insurance, government funding). 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/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 previous records are helpful. We retain our clients’ information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services. We destroy our information ten years after the last entry (or, where we know, after the individual turns 18) at the first reasonable opportunity in order to reduce the risk of accidental or inadvertent disclosure.
- If the organization of its assets were to be sold, the 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 to the purchaser. 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 the 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 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
- 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 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 with people who are not our clients, newsletters, seminars and marketing activities for about six months after the newsletter, 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 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 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 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, Angelique Montano-Bresolin, can be reached at 235 Danforth Avenue., Suite 405, Toronto, Ontario, M4K 1N2, 647.352.7742, 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.
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 ask that you discuss those concerns with us directly. If we are not able to satisfy your concerns, you are entitled to complain to our regulatory body:
College of Physiotherapists of Ontario 416.591.3828
College of Occupational Therapists of Ontario 416.214.1177
College of Massage Therapists of Ontario 416.489.2626
Ontario College of Social Workers and Social Services 416.972.9882
College of Registered Psychotherapists of Ontario 416.479.4330
College of Kinesiologists of Ontario 416.874.4096
College of Naturopaths of Ontario 416.583.6010
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
Proactive Pelvic Health Centre Disclaimer
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Medical Health and Wellness Disclaimer
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Errors and Omissions
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Links to Other Websites
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