Protecting Your Privacy

OUR PRIVACY POLICY

Privacy of personal information is an important principle to Swanson & Associates. 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. All staff members who come in contact with your personal information are aware of the sensitive nature of the information that you have disclosed to us. This document describes our privacy policies.

PRIMARY PURPOSES for collecting your personal information

In order to serve our clients, we need to collect, use and disclose personal information, to provide quality rehabilitation services. As such we collect your health information to assess your rehabilitation needs, advise you of your options and then provide the rehabilitation services that you need and choose to have.

  • To obtain a baseline of information in order to track progress over time. 
  • To enable us to contact you.

SECONDARY PURPOSES for collecting your personal information

We also collect use and disclose information for purposes related secondarily to our primary purposes.  The most common examples of our secondary purposes are:

  • To invoice for goods or services or to collect unpaid accounts.
  • To advise clients and others of special events or opportunities that we have available
  • To answer client questions about treatment after the conclusion of services.

Occupational Therapists are regulated by the College of Occupational Therapists of Ontario    (COTO). Registered Nurses are regulated by the College of Nurses of Ontario (CNO) and Speech Language Pathologists are governed by the College of Audiologists and Speech-Language Pathologists of Ontario (CASLPO)

These agencies 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 organization 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 their reports include personal information about our clients, or other individuals, to support their concerns (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.

Our regulatory colleges of Ontario require us to retain our client records for a minimum of ten years after the last contact.

PROTECTING your 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. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.
  • 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.
  • Staff members are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.

RETENTION & DESTRUCTION your personal information

We keep our client files for 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 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 will try to help you understand any information you do not understand. We will need to confirm your identity if we do not know you before providing you with this access. If we cannot give you access we will tell you within 30 days if at all possible and we will give 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.

We keep our client files for 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 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.

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 will try to help you understand any information you do not understand. We will need to confirm your identity if we do not know you before providing you with this access. If we cannot give you access we will tell you within 30 days if at all possible and we will give 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 QUESTION?

Our Information Officer, Susan Scott Swanson, will attempt to answer any questions or concerns you might have.  She can be reached at:

1729 Bank Street, Suite 305
Ottawa, ON  K1V 7Z5
Tel: 613-260-1935

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 our professional staff, we would ask that you discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to contact our regulatory bodies:

COTO
20 Bay Street, Suite 900
Toronto, ON  M5J 2N8
Tel: 1-800-890-6570
www.coto.org

CASPLO
3080 Yonge St., Ste.5060
Toronto, ON M4N 3N1
Tel: 1-800-993-9459
www.caslpo.com

CNO
101 Davenport Rd.
Toronto, ON  M5R 3P1
Tel: 1-800-387-5526
www.cno.org

This policy is made under the Personal Information Protection and Electronic Documentations Act (PIPEDA), a complex act that 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 inquires, the Information and  Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Information and Privacy Commissioner can be reached at:

112 Kent St.
Ottawa, ON  K1A 1H3
Tel: 613-995-8210
Toll free: 1-800-282-1376
Fax: 613-947-6850
www.privcom.gc.ca