Participation House, Markham (the “Agency”) will make every effort to ensure that any personal information including personal health information in our possession will be kept private and confidential.
The Agency is committed to maintaining privacy and to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide.
AGENCY PRACTICES:
WHO WE ARE:
The Agency collects personal information on behalf of the Cerebral Palsy Parent Council of Toronto, operating as Participation House, Markham. The Agency is a health information custodian under the Personal Health Information Protection Act, 2004 that came into effect November 1, 2004.
DUTIES OF THE HEALTH INFORMATION CUSTODIAN:
The Agency, acting as the Health Information Custodian, is required to collect only the information needed to conduct business, take reasonable steps to safeguard personal health information, take reasonable steps to ensure health records are accurate, complete and provide a written description of the practices used to protect information and contact information for questions or concerns.
The Agency will not trade or sell any Personal or Health Information.
CONSENT:
Clients, volunteers and employees must give permission or consent to the collection, use and sharing of Personal Health Information or Personal Information. This shall be documented and retained on the file of the individual. In the event that the client provides verbal consent, a witness shall be included and documented.
Implied Consent
In general, the Agency will assume that clients give consent for the sharing of health information to provide services or healthcare without requiring completion of a signed consent form. For example, when the client is transferred to a medical facility, the Agency assumes you have given permission to share your health information with the provider, unless the client specifically refuses.
Employees and volunteers will be advised of the use of any personal health information as required and as necessary, for example, in the application for benefits insurance.
Express Consent
In certain situations, the Agency will be required to request oral or written consent before sharing health information, for example, disclosing information to someone who is not a health information custodian or any other third party.
WHAT IS PERSONAL INFORMATION?
Personal information means any information that may be used to identify an individual, including, but not limited to the following:
- Age, ID numbers, income, ethnic origin, or blood type,
- Opinions, evaluations, comments, social status, or disciplinary actions,
- Employee files, credit records, loan records, medical records, existence of a dispute, intentions, (for example, to acquire goods or change jobs)
Personal information does not include the name, title or business address or telephone number of an employee.
WHAT IS PERSONAL HEALTH INFORMATION?
Personal Health Information (PHI) may be collected in the course of conducting business, processing requests and supporting the services the Agency provides. This may include identifying information about an individual in oral or recorded form as it relates to any of the following:
- his or her physical or mental health
- to providing health care, including identifying a provider of health care
- a plan of service within the meaning of the Long Term Care Act
- the donation of a body part or bodily substance
- payments or eligibility for health care
- a health number
- the individual’s substitute decision maker
- a record containing any of the above information
- information about an employee which primarily relates to the provision of health care
IMPORTANT INFORMATION ABOUT OUR PRIVACY PRACTICES-CONTACT
When we collect personal information from you, we wish you to be aware of our identity and how to contact our Privacy Officer:
Participation House, Markham
Attention: Shelley Brillinger, Executive Director
204-4261 Highway 7, Markham, ON L3R 9W6
Telephone: 905 513-2756 Fax: 905 513-7963
COLLECTING, USING AND DISCLOSING PERSONAL AND HEALTH INFORMATION
PURPOSES:
Client Related
The Agency collects, uses and discloses personal information in order to provide services to our clients. The Agency collects personal information in order to provide them with assistance during their admission or attendance at any service or program, the provision of any health related service and for Quality Control and Risk Management.
Examples of the type of personal information we collect may include the following:
Intake information for referral and or admission to any program or service, including next of kin, caregiver information, relationship, address, telephone number, disability diagnosis and prognosis, personal medical and health information, religion, and any family related information.
Information to plan, administer and evaluate any program or services funded by the Agency, including the management and reporting of information to other health or financial systems, such as OHIP and Ministries, ODSP programs and evaluating for the purposes of Quality Improvement.
General Public, Volunteers and Students:
Our primary purposes for collecting personal information are fundraising, education and training, orientation purposes and may include such information as name, address, phone numbers, age, email addresses, home information, personal experiences and interests.
Employees:
Our primary purposes for collecting personal and health information for employees is for payroll purposes, benefits and insurance application and enrollment, application for Criminal Records Check, medical and health and safety compliance, contact purposes, union related information and any other information required in the conducting of business.
WEBSITE
In order to generate website traffic reports, our website (www.participationhouse.net) collects non-personal information such as your network location (IP address), the pages you visit, time of visit, your operating system and browser.
SAFEGUARDS AND ACCESS
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have appropriate physical, technological and organizational measures to safeguard, update and secure the information we collect.
You may request access to your personal information held by us. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access.
Paper Information:
All paper information is under supervision or secured in a locked or restricted area at all times. All staff must sign a confidentiality agreement upon hiring. Any transfer of paper information shall be sealed as required and delivered by authorized persons only.
Electronic Information:
All electronic information shall be secured and may be accessed only upon provision of password on each computer on the premises. Personal information shall not be left on screen when unattended by staff.
Transferring of electronic information may be through copied disk, email or fax and shall be conducted with appropriate safeguards.
General Safeguards
Staff are trained and updated annually during the performance evaluation with respect to the following: the importance of privacy of personal information, accessing on a need-to-know basis, sensitivity in collecting or using personal information verbally where others may overhear and breach of the Agency’s policies.
Retention
Client records are retained in a secure archive for a period of ten years from the date of client’s discharge. Destruction of client records shall be in accordance with governmental regulations.
Employment, financial and general correspondence is securely stored for a period of 7-10 years after the fiscal year in which the employee was terminated and shall be destroyed in accordance with governmental regulations.
ACCESS AND CORRECTION OF PERSONAL AND HEALTH INFORMATION
Individuals have the right to access personal and health information about themselves held by the Agency. The individual may request, in writing or verbally, access to information, its use and its disclosure to third parties and therefore the Agency shall keep reasonable records of disclosure of personal information.
Information relating to a warrant, subpoena, or any investigative body shall be provided subject to the Agency’s legal advice. The Agency will handle correction requests in confidence and shall adjust records accordingly without defacing any document.
CONCERNS REGARDING COMPLIANCE
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. We are committed to resolving disputes in a timely manner. We will investigate your complaint and respond accordingly.
For general inquiries about privacy legislation and policies in the private sector, you may contact:
The Office of the Privacy Commissioner of Canada
112 Kent Street, Ottawa, Ontario K1A 1H3
Telephone: 1 (613) 995-8210
Toll-free: 1 800 282-1376
Fax: 1 (613) 947-6850
Web site: www.privcom.gc.ca
For text of the Personal Health Information Protection Act, 2004 you may access the following website:
www.e-laws.gov.on.ca/DBLaws/Statutes/English/04p03_e.htm
