Privacy of personal information is an important principle to The Health Network. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. This document has been designed to openly describe our privacy policies.

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g. gender, age, home address or phone number), their health (e.g. health history, health conditions, treatments received) or their activities or views. Personal information does not include business information (e.g. an individual’s business address or telephone number), which is not protected by privacy legislation.

The Health Network is a multi-disciplinary health care facility, offering registered massage therapy, physiotherapy and chiropractic care, as well as custom orthotics. In addition to our staff and regulated health care practitioners, we use a number of consultants and agencies, that may, in the course of their duties, have limited access to personal information we hold. These include but are not limited to, bookkeepers and accountants, lawyers, maintenance and cleaners, credit card companies, website managers, data entry consultants, insurance companies, other regulated health care professionals, individuals representing our legislative bodies (e.g. CMTO, CPO, CCO), property management and security services. We restrict their access to any personal information we hold as much as reasonably possible. We also have their assurance that they follow appropriate privacy principles.

Like all regulated health care practitioners, we collect, use and disclose personal information in order to serve our clients. Our primary purpose for collecting personal information is to provide safe, effective treatment, designed for the individual client’s needs. Health history information, including physical and health conditions, aid our therapists in assessing your health requirements, designing a treatment plan for you and monitoring changes and improvements in your health. All personal information collected has been done so in accordance with our regulatory bodies. This information is always collected with the client’s express consent.

On occasion, our clients may receive mail or email notifying them of clinical changes or additional services. If you do not wish to receive this information, please notify one of our staff and your personal information will be removed from our distribution list.

For therapists contracted to do work for us (e.g. massage therapists, physiotherapists, chiropractors), as well as consultants and agencies, our primary purpose for collecting personal information is to ensure we can contact them for necessary work-related communication (e.g. schedule, paycheques, tax receipts).

We also collect personal information for the following reasons;

• To invoice clients for goods or services, process credit cards and personal cheques as well as collect unpaid accounts.
• Third Party Billing- consent is required to share personal information needed on claim and billing forms in order to collect third party billing.
• To inform our clients of changes to the clinic or new services being offered.
• Recall visits and product review.
• Appointment reminders and missed appointments.
• Quality Control and Risk Management – To ensure we offer high quality service, files may be reviewed for the purpose of continuing quality improvement reviews (to ensure clinical notes and records are meeting and exceeding basic college requirements)
• External Regulation- All Regulated Health Care Practitioners are governed by the practice’s individual regulatory body (e.g. College of Massage Therapists of Ontario, College of Physiotherapists of Ontario, College of Chiropractors of Ontario) as well as The Regulated Health Care Practitioners Act. These groups may, on occasion, inspect our records and interview therapists as part of their regulatory activities in the public interest. In addition, we are required to report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own.
• Government Agencies- Various government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission) have the authority to review our files and interview our staff and therapists as part of their mandates.
• Responding to client questions pertaining to goods and services they have received at The Health Network.
• In the event of sale of business, the purchaser would conduct a "due diligence" review of clinical records to ensure it is a viable business that has been honestly portrayed by to the purchaser.

Please note, you can choose not to participate in some of these related or secondary purposes (e.g. by declining to receive notifications via mail/email, by not participating in third party billing). Unfortunately, a few of the secondary purposes are mandatory (e.g. External Regulation, Government Agencies).

We understand the importance of protecting personal information. For that reason, we have taken the following steps to ensure your right to privacy;

• 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, all computers are password locked and protected.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted through a direct line.
• Staff and Therapists are trained to collect, use and disclose personal information only as necessary to fulfill their duties in accordance with our privacy policy and meet the requirements of their regulatory bodies.
• External consultants and agencies with access to personal information must enter into privacy agreements with us.
• All files are in trust of The Health Network and are therefore not permitted to leave the premises. Information is not shared with outside practitioners, lawyers, insurance companies etc, without express written consent from the client.

Please note that legal authority to disclose personal information without consent exists in the following circumstances:

• To the organization’s lawyer,

• For debt collection purposes,

• To comply with a subpoena, warrant or court order,

• At the request of a government institute for national security, law enforcement or administration,

• At the initiative of the organization, to provide information to a government institute or a specified investigative body relating to law enforcement or national security,

• At the initiative of a specified investigative body relating to law enforcement,

• Where there is an emergency that threatens the life, health or security of an individual so long as the person to whom the information relates is then advised in writing right away,

• Publicly available information specified in regulation (e.g., telephone directories, professional directories, statutory registries, court records and information provided by the individual to newspapers, magazines and books),

• To an archive,

• 20 years after death of the people to whom the information relates or after 100 years after the record was made,

• specific research situations, or,

• Where disclosure is required by law.

In accordance with the RHPA and CMTO, all client files are retained for a minimum of ten years. Paper files containing personal information are destroyed by shredding. Electronic information is destroyed by deletion, and in the event that the hardware is discarded, it is physically destroyed so no information can be retrieved. Alternately, we may send some, or all of the client file directly to the client.

You have the right to see what personal information we hold about you, with only a few exceptions. We can help you identify what records we have and assist you in clarifying any information you do not understand (e.g., short forms, technical language, etc.).

Due to the large volume of requests received on a daily basis, we ask that a minimum of seven days be allowed to respond to specific requests. Depending on the nature of the request, a written request may be required. We reserve the right to charge a nominal fee for requests which may be time consuming or require research or paper copies.

In the event that we cannot give you access to your personal information, we will inform 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 an error in your personal information, you have the right to ask to have it corrected. This applies only to factual information and not to any professional opinions we may have formed. We may request you provide documentation that our file is incorrect. Where we agree upon an error, it will be corrected and notification will be forwarded to those whom shared this information. Where we disagree upon an error, you may provide a brief statement which we will include in your file and notification will be forwarded to those whom shared this information.

If you have any questions or concerns regarding our Privacy Policy, you can reach our Information Officer, Carla Martin at;

The Health Network
43 Oxford Street West
London, ON N6H 1R5
Telephone: (519) 433-7400
Fax: (519) 434-9940
Email: thnrmt@aol.com

If you wish to make a formal complaint about our privacy policies, you may contact our Information Officer in writing. 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 therapists we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:

The College of Massage Therapists of Ontario
1867 Yonge Street, Suite 810
Toronto, On M4S 1Y5
Telephone: (416) 489-2626
Toll Free: (800) 465 1933
Fax: (416) 489-2625
Website: www.cmto.com
Email: cmto@cmto.com

This policy is made under the Professional Information Protection and Electronic Documents Act, which is a complex Act and may provide 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 Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

www.privcom.gc.ca