Privacy of personal information is an important principle to Integrative Medicine Consultants Inc (IMCI). 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, address, etc.), their health (e.g. health history, health conditions, other treatment received, etc.), or their activities and views (e.g. religion, politics, opinions, etc.). 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.
COLLECTION OF PERSONAL INFORMATION: PRIMARY PURPOSES
About Clients
Like all health practices, we collect, use, and disclose personal information in order to serve our clients. The primary purpose for collecting personal information is to provide health care. 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 may occur 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 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).
About Members of the General Public
For members of the general public, our primary purpose for collecting personal information are to provide notice of special events (e.g. a seminar or workshop) or to make them aware of clinic services in general or our clinic in particular. 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.
IMCI only collects, with the exception of cookies, the personal information you provide (e.g. email addresses) and only use that information for the purpose you gave it to us (e.g. to respond to your email message or subscribe to a newsletter). Cookies are only used to help you navigate our web site and are not used to monitor your activity.
COLLECTION OF PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES
Like most practices, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. Most common examples of our related and secondary purposes are as follows:
- To invoice clients for goods or services not paid for at the time, to process credit card payments, or to collect unpaid accounts.
- To advise clients and others of special events or opportunities (e.g., a seminar, development of news in health care).
- We are monitored by the College of Physicians and Surgeons of Ontario who may inspect our records and interview our staff as a 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 behavior 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 practices, 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). 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 or 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 our previous records are helpful. We retain our client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our client records).
- You can choose not to be part of some of these related or secondary purposes (e.g. by declining to receive notice of special events or opportunities, 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.
- Paper information is transmitted through sealed addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted either through a direct line and/or is encrypted.
- Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
- External consultants and agencies with access to personal information must enter into privacy agreements with us (e.g. confidentiality agreements).
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We 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 no want to keep personal information too long in order to protect your privacy.
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 keep any personal information relating to our general correspondence (i.e. with people who are not clients) newsletters, seminars and marketing activities for about one year 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.
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 no 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 files 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?
The information officer for IMCI is Dr. Esther Konigsberg who can be reached at:
Dr. Esther Konigsberg
Dundas University Health Clinic
438 University Avenue, Suite 104
Toronto, Ontario Canada M5G 2K8
Tel: 416-598-4999 Fax: 416-598-0606
The information officer for Dundas University Health Clinic is Dr. Laura Cory who can be reached at:
Dr. Laura Cory
Dundas University Health Clinic
438 University Avenue, Suite 104
Toronto, Ontario Canada M5G 2K8
Tel: 416-598-4999 Fax: 416-598-0606
Every attempt will be made 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 the information officer. They 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 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 make a complaint to the appropriate regulatory body. This contact information is provided below.
College of Physicians and Surgeons of Ontario
80 College Street
Toronto, Ontario M5G 2E2
Fax: 416-961-3330
Email: feedback@cpso.on.ca
Website: www.cpso.on.ca
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 Information and Privacy Commissioner of Canada oversees the administration of the privacy sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Inquiries: 1.800.282.1376 (toll-free) or 819.994.5444
Fax: 819.994.5424
TTY: 819.994.6591