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, TaraL Prashad, includes at the time of writing 1 massage therapist. I use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information I hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, cleaners and lawyers. I restrict their access to any personal information I hold as much as is reasonably possible. I also have their assurance that they follow appropriate privacy principles.
COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES About Clients Like all massage therapists, I 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 massage therapy treatment. For example, I 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 I 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 I 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 I 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 purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of massage therapy services in general or our clinic in particular. For example, while I try to use work contact information where possible, I might collect home addresses, fax numbers and email addresses. I try to obtain consent before using any such personal information, but where this is not, for any reason, possible, I will upon request immediately remove any personal information from our distribution list.
On our website I only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a course, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.
About Contract Staff, Volunteers and Students For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure I can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out pay cheques, yearend tax receipts).
Examples of the type of personal information I 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 health emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the office). If contract staff, volunteers or students wish a letter of reference or an evaluation, I will collect information about their work-related performance and provide a report as authorized by them.
I COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES Like most organizations, I 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 Ire 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 I have available.
Our clinic reviews client and other files for the purpose of ensuring that I 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.
Massage therapists are regulated by the College of Massage Therapists 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, I 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, I 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., OHIP, 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 I deal with may have questions about our goods or services after they have been received.
I also provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful. I 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 Tara Prashad or its assets have to be sold, the purchaser would want to conduct a “due diligence” review of the office’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 to receive notice of special events or opportunities, by paying for your services in advance). I do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION I understand the importance of protecting personal information. For that reason, I 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. 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.
External consultants and agencies with access to personal information must enter into privacy agreements with us. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION I need to retain personal information for some time to ensure that I can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, I do not want to keep personal information too long in order to protect your privacy. I keep our client files for about ten years. Our client and contact directories are much more difficult to systematically destroy, so I remove such information when I can if it does not appear that I will be contacting you again. However, if you ask, I will remove such contact information right away. I keep any personal information relating to our general correspondence (i.e., with people who are not clients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over. I destroy paper files containing personal information by shredding. I destroy electronic information by deleting it and, when the hardware is discarded, I ensure that the hard drive is physically destroyed
DO YOU HAVE A QUESTION? Our Information Officer, __Tara Prashad, can be reached at: 647 231 3528 She will attempt 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 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, I would ask you to discuss those concerns with us. However, if I cannot satisfy your concerns, you are entitled to complain to our regulatory body: COLLEGE OF MASSAGE THERAPISTS OF ONTARIO 1867 Yonge Street, Suite 810, Toronto, ON M4S 1Y5 (416) 489-2626, (800) 465-1933, facsimile (416) 489-2625, firstname.lastname@example.org, www.cmto.com
1-The on line booking, "Notero.com”, and record keeping company is HIPAA compliant and they state "We have implemented technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes. You acknowledge that you provide your personal information at your own risk."
Accessibility Policy Guide to the Accessibility Standards for Customer Service, Ontario Regulation 429/075AODA Section 2. In this Act, “disability” means,(a) any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,(b) a condition of mental impairment or a developmental disability,(c) a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,(d) a mental disorder, or(e) an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
The office of Tara L Prashad, RMT has set in place a process for people for have physical and other types of disability. We have a manned elevator for people with physical disabilities. Notice need to be given to ensure the person who manages the elevator is available. Accommodation for any other disabilities can be discussed prior to your appointment. Pet policy: My office is entirely welcoming of assistance pets. Please consider your time to your self and if you need or want your pet with you. Please give notice of the pet and the nature of the need to have your pet present