Privacy of personal information is an important principle to Swanson & Associates. We are committed to collecting, using and disclosing personal information responsibly and only as necessary for the services we provide. We also try to be transparent about how we handle personal information. All staff members who come in contact with your personal file 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
- To provide the highest quality of service. In order to provide our clients with quality rehabilitation services, we need to collect, use and disclose personal information. As such, we collect your health information to assess your rehabilitation needs, advise you of your options and then provide the appropriate rehabilitation services.
- To obtain a baseline of health information in order to track progress over time.
- To enable us to contact you
Secondary Purposes for Collecting Your Personal Information
In addition to our primary purposes, we collect use and disclose information for other related purposes. The most common examples of these secondary purposes are:
- To invoice for goods or services or to collect unpaid accounts.
- To advise clients and others involved with the file of special events or opportunities that we have available.
- To answer client questions about treatment after the conclusion of services. Our regulatory colleges of Ontario require us to retain our client records for a minimum of ten years after the last contact.
- 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); Speech Language Pathologists are regulated by the College of Audiologists and Speech-Language Pathologists of Ontario (CASLPO); and Physiotherapists are regulated by the College of Physiotherapists of Ontario (CPO).
These agencies may inspect our records and interview our staff as part of their regulatory activities. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to another organization or our own. Our organization believes that it should report information suggesting serious illegal behaviour to the authorities.These 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).
- 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 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.
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 and restricted area.
- Electronic hardware is either under supervision or secured in a locked and/or restricted area. In addition, passwords are used on all computers. All of our cell phones are digital; this type of signal is more difficult to intercept.
- Paper information is transferred in sealed, addressed envelopes or boxes by reputable companies.
- Encryption is used for the storage of electronic information.
- Transmission of electronic information is either encrypted or is kept anonymous.
Retention & Destruction of Your Personal Information
We keep our client files for a minimum of ten years. Our client and contact directories are more difficult to systematically destroy, so we remove such information if it does not appear that we will be contacting you again. However, if you ask, we will remove your contact information right away. We destroy paper files containing personal information by shredding. We delete electronic information, and when the hardware is discarded we ensure that the hard drive is physically destroyed. Alternatively we may send some or the entire file to our client.
You can Look at Your Information
You have the right to see what personal information we hold about you. All you have to do is ask. We will try to help you understand any information that seems unclear. 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 and explain the reasoning behind that decision, 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 there is an error we will make the correction and notify anyone to whom we sent this information. If we do not agree, we will still 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 Health Information Custodian, 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 firstname.lastname@example.org
If you wish to make a formal complaint about our privacy practices, you may do so in writing and address it to our Health Information Custodian. She will acknowledge receipt of your complaint and ensure that it is investigated promptly and that you are provided with a formal decision and explanation 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:
20 Bay Street, #900, Toronto, ON M5J 2N8
3080 Yonge St., #5060,Toronto, ON M4N 3N1
101 Davenport Rd. Toronto, ON M5R 3P1
275 University Avenue, #901,Toronto, ON
250 Bloor Street East, Suite 1000 Toronto, ON M4W 1E6
This policy is made under and complies with the Personal Information Protection and Electronic Documentations Act (PIPEDA). For details of some rare exceptions to the commitments set out above, please refer to this Act.
For more general inquires, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Privacy Commissioner can be reached at:
112 Kent St., Ottawa, ON K1A 1H3
Tel: 613-995-8210 Toll-free: 1-800-282-1376