At Harbourview Rehabilitation Occupational Health Consultants Ltd., we strive to provide you with quality service. Since providing our service involves the collection, use, and disclosure of personal information, protecting your personal information is an essential part of us making sure you receive the best of what we at Harbourview have to offer.
We will let you know about how and why we collect, use, and disclose your personal information, obtain your consent if we need to, and handle your personal information in a way that a reasonable person would consider as the right thing to do in the situation.
Our privacy commitment includes ensuring the accuracy, confidentiality, and security of your personal information and providing you the opportunity to ask to either correct or access your personal information.
Scope of Policy
This Policy applies to our collection, use, and disclosure of your personal information. However,
this Policy does not impose any limits on the collection, use, or disclosure of business-contact information or certain publicly available information. This policy also applies to any service providers collecting, using, or disclosing personal information on behalf of Harbourview Rehabilitation Occupational Health Consultants Ltd.
What is personal and personal health information?
Personal information (PI) includes any identifying information about you. Harbourview Rehabilitation Occupational Health Consultants Ltd. collects personal information from you such as your name, date of birth, address, email, and phone contact information; and when you offer it as a means of payment, your credit card information (note that credit card information is not retained after a transaction is completed).
Personal Health Information (PHI) is any identifying information in writing or spoken about your physical or mental health; the provision of your health care; the eligibility or payment for your health care; the identity of the provider of your health care; and includes your health card number (a health care provider who does not use your health card for an authorized purpose cannot ask for the number).
Personal Information (PIPPA definition): means information about an identifiable individual and includes employee personal information but does not include
(a)contact information, or
(b)work product information.
Contact Information (PIPPA definition): means information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual.
Personal identity information (FIPPA definition): means any personal information of a type that is commonly used, alone, or in combination with other information, to identify or purport to identify an individual.
Personal Information (FIPPA definition): means recorded information about an identifiable individual other than contact information.
Harbourview Rehabilitation Occupational Health Consultants Ltd. has designated a Privacy Officer to be accountable for the organization’s compliance with the applicable privacy legislation, including the ten privacy principles set out in PIPEDA and other legislation: accountability; identifying purposes; consent; limiting collection; limiting use, disclosure and retention; accuracy; safeguards; openness; individual access and challenging compliance.
We will communicate the purpose for the collection of your personal information before or during the time of collection, unless the purpose for collecting your personal information is obvious and you voluntarily provide your personal information for such purpose. Also, we will only collect or create personal information that we need to fulfill our obligations to you, and that a reasonable person would consider as the right thing to do in the situation.
We will collect client information that we need to satisfy the following purposes:
- Contact information for the source of the client’s referral, including self-referral.
- Reason for the referral.
- Client’s full name, address, date of birth, and unique identifier (if applicable).
- To identify client preferences.
- To open and manage an account.
- To meet regulatory requirements.
We will receive your consent to collect, use, or authorize personal information (excluding some exceptions, which are listed below).
You can consent verbally, in writing, or electronically, by an authorized representative, if the reason for collecting, using, or disclosing the personal information is considered obvious and you voluntarily provide your personal information for that reason.
To provide our services, we will not require your consent for the collection, use, or disclosure of personal information beyond what is needed.
If you choose not to opt-out, consent could be implied if you are given notice and a reasonable chance to withdraw your personal information that may be used for mail-outs, and the marketing of new services or products.
Dependant on some exceptions (i.e., the personal information is necessary to provide service, or the withdrawal of consent would bar the performance of a legal obligation), you can withhold or withdraw your consent regarding us making use of your personal information for certain purposes. Your decision to withhold or withdraw your consent to uses of your personal information could limit our ability to provide a particular service or product. If this occurs, we will explain the situation to accommodate you in making your decision.
We may collect, use, or disclose your personal information without your knowledge or consent in the following circumstances:
- if its use is clearly in the interests of you (i.e., safety concerns), and consent cannot be acquired in a timely manner;
- The personal information is collected by observation at a performance where you voluntarily appear, and that is open to the public;
- When the collection, use, or disclosure of your personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When your personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt or the payment of a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
Use and Disclosure of Personal Information
We will use or disclose your personal information if needed to satisfy the purpose it was obtained, or for a use consistent with that purpose as collection occurs, including but not limited to:
- To conduct our services.
- To conduct client surveys to enhance providing our services.
- To contact our clients’ directly as to products and services that may be of interest.
- To communicate with stakeholders and other health professionals involved in your care.
Our use of your personal information will be limited in access to employees, contractors, or agents of Harbourview Rehabilitation Occupational Health Consultants Ltd. where access is needed to carry out our duties, and only to the extent needed to fulfill such duties.
We will not use or disclose your personal information for additional purposes unless we
receive your consent (barring exceptions). Moreover, unless we have prior authorization from you, we will not disclose personal information outside of Canada.
We may refuse to disclose your personal information to a patient or patient representative in the following circumstances:
- Where there is a significant likelihood of a substantial adverse effect on the physical, mental, or emotional health of the patient.
- Where there is a significant likelihood of harm to a third party.
- If the disclosure could reasonably be expected to disclose your personal information regarding another individual, which cannot reasonably be severed from the information to be disclosed.
Where you direct that part of the information be withheld, we will respect that request. If it is considered necessary to disclose the withheld information to provide or to assist in providing health care to you, we will notify the recipient as to the part of the information that is withheld.
Additionally, we will record the type of information released to the you and when; and we will inform you on how your information is being used and disclosed.
Retaining Personal Information
If we use your personal information to decide on a matter that directly relates to you, we will keep such information for at least one year so that you have a reasonable chance to request access. Additionally, we will keep your personal information to the extent it is reasonable to assume the defined purpose or any legal or business purpose has been fulfilled.
We will ensure your record is retained safely and securely stored for at least 16 years from the date of the last entry in the record or in the case of a minor, the date is 16 years after the day the client reached or would have reached 19 years old, whichever is later.
The record may be maintained after the 16-year period if we reasonably know a piece of health information will be needed after this time for a valid reason, such as ongoing care, or a legal proceeding.
Accuracy of Personal Information
We will make every reasonable effort to make sure your personal information is accurate and complete in circumstances it may be used to execute a decision about you or disclosure to another organization. To fulfill this, you may request (however, may not demand) correction as to your personal information to ensure its accuracy and completeness. To correct such personal information, a request is required in writing that includes sufficient detail to identify the personal information and the correction intended. If the personal information signifies inaccuracy or incompleteness, and we are satisfied on reasonable grounds the request should be executed, we will correct the information as needed and as soon as reasonably possible and send the corrected information to whichever organization to which the personal information was disclosed in the previous year. If the correction is not made, we will make note of a client’s correction request in the file.
Securing Personal Information
We are devoted to ensuring the security of your personal information to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, by making reasonable security arrangements, including encryption.
The following security measures will be followed to ensure that your personal information is appropriately protected:
- All therapy records are stored in locked filing cabinets.
- Computer access is password protected.
- All emails/fax transmissions contain a notice at the bottom regarding confidentiality procedures if the information is sent to the wrong address or phone line inadvertently.
- If information has been lost or stolen, or accessed without client authorization, reasonable efforts will be made to notify the client involved.
We will also utilize suitable security measures while destroying clients’ personal information, such as:
- Deleting files from personal computers and servers;
- A list of names and dates regarding the records that have been destroyed is maintained in perpetuity or until no longer necessary, in accordance with statutory requirements;
In addition to the above, we will continue to review and update our security policies and controls as technology evolves to ensure continuing personal information security.
Access to Personal Information
You have a right to access your personal information, which is subject to certain limited exceptions:
- The information is solicitor-client privilege;
- the disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;
- the information was collected or disclosed without consent for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed;
- the information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act (i)under a collective agreement, (ii)under an enactment, or (iii)by a court;
- the information is in a document that is subject to a solicitor’s lien.
If you need access to your personal information for whichever reason(s), a request to access your personal information is required in writing, providing enough detail to identify the personal information you are seeking. Also, if an applicant is acting on behalf of another person, written proof of the authority of the applicant to make the request is required.
Upon request, we will make every reasonable effort to assist you by responding without delay and doing so openly, accurately, and completely. We will notify you how we utilize your personal information, specifying to whom it has been disclosed (if applicable).
The requested information will be available within 30 business days, or we will provide you with written notice of an extension if additional time is needed.
A minimal fee may be charged for services providing access to personal information. If a fee applies, we will notify you of the cost and ask for additional direction, regarding whether we should proceed with the request.
If a request is refused fully or partially, we will notify you in writing, detailing the reasons for refusal and the options available; moreover, we will provide the name, position title, business address and telephone number of an officer or employee of our organization, or public body affiliated with our organization, who can answer your questions about the refusal.
We may collect, use, and disclose your personal information for the purposes of facilitating or collecting payment for our services or to determine any entitlement to insurance coverage or other benefits.
Harbourview Rehabilitation Occupational Health Consultants Ltd. believes that securing your personal information is an indispensable part of our job. We have carried out reasonable administrative, technical, and physical safeguards to protect against loss, theft, or unauthorized access, use, copying, modification, disclosure, and disposal of personal information in our custody.
In some cases, we may share your personal health information with third parties such as vendors, suppliers, or providers responsible for administering our programs or other services.
We may collect, use, and disclose personal information for the purposes of risk management, security, or otherwise to improve the quality of Harbourview Rehabilitation Occupational Health Consultants Ltd services, including the evaluation and monitoring of those services.
Legal & Compliance
We may disclose your personal information where required or permitted by law. For example, we may provide your personal information to respond to a search warrant or other legally valid inquiry or order. We may also disclose personal information for certain proceedings and to investigate or prevent actual or suspected loss or harm to persons or property.
We may transfer any information we have about you in connection with a proposed or completed merger or sale involving all or part of Harbourview Rehabilitation Occupational Health Consultants Ltd.
Questions and Complaints
The Privacy Officer is responsible for ensuring Harbourview Rehabilitation Occupational Health Consultants Ltd.’s compliance with this policy and the Personal Information Protection Act. and Freedom of Information and Protection of Privacy Act.
Any complaints, concerns, or questions as to Harbourview Rehabilitation Occupational Health Consultants Ltd.’s compliance you may have should be in writing to the Privacy Officer. If the Privacy Officer cannot resolve the concern, you may also write to the Information and Privacy Commissioner of British Columbia.
Our Privacy Officer is Mr. Dominic Shew.
He can be contacted at:
(Office Fax) 604-951-4282