Like all Physiotherapists, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide physiotherapy treatments. Examples of the type of personal information we collect for those purposes include the following: 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 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 services we can identify changes that are occurring 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 (e.g., the client is unconscious) 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).

For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g. a seminar or conference) or to make them aware of physiotherapy services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might collect home address, fax numbers and e-mail 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, Volunteers and Students (e.g., temporary workers, students or volunteers), our primary purposes for collecting personal information is to ensure that we can contact them in the future (e.g., for a new assignments) and for necessary work related communication (e.g., sending out paycheques, year end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a medical emergency (e.g., SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If a contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.

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 or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.

- To advise clients that their product or service should be reviewed (e.g., to ensure a product is still functioning properly and appropriate for their then current needs and to consider modifications or replacement).

- To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new product) that we have available.

- Our clinic reviews client 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 Clinic, including reviewing client files and interviewing our staff.

- Physiotherapists are regulated by the College of Physiotherapists 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 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., WSIB, private insurance, Assistive Devices Program). 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).

- If York Region Physiotherapy and Rehab inc. or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. 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 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).

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.

- Staff is 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.

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 10 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 6 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.

Our Information Officer, Sophie Bourget, can be reached at:

York Region Physiotherapy and Rehab Inc
12981 Keele Street, Unit 3
King City, Ontario
L7B 1G2
(905)833-7171

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.
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 | TOLL-FREE 1-800-282-1376 | FAX (613) 947-6850 | TTY (613) 992-9190 www.privcom.gc.ca