Marketplace Chiropractic Privacy Policy

Privacy of personal information is an important principle to us here at Marketplace Chiropractic. We are committed to collecting, using and disclosing personal information responsibly, and only to the extent necessary for the services and goods we provide. We also try to be open and transparent as to how we handle personal information. 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), their health (e.g., health history, health conditions, health services) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information must 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

At Marketplace Chiropractic, we have two chiropractors, and two assistants. Marketplace Massage Therapy Clinic subleases space and operates a massage therapy clinic in our facility. We use several consultants and agencies that may, in the course of their duties, have limited access to the personal information we hold. These include computer consultants, office maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, cleaners, and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES

About Clients

Like all chiropractors, we collect, use, and disclose personal information, to serve our clients. For our clients, the primary purpose for collecting personal information is to provide chiropractic care. For example, we collect information about a client’s health history; including their family history, physical condition and function, and social situation, to help us assess their health needs. This allows us to advise them of their options and then to provide the health care they choose. A second primary purpose is to obtain a baseline of health and social information, so that in providing ongoing health 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).

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 chiropractic services in general or our clinic. We try to obtain consent before using any such personal information, but where this is not possible, we will upon request immediately remove any personal information from our distribution list.

On our website we 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. For further details regarding our website privacy policy please refer to https://www.marketplacechiropractic.ca/info/privacy/.

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 we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., to ask questions regarding work done, to send out paycheques and yearend 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 health emergency (e.g., a SARS outbreak) or to investigate the possible breach of the law (e.g., if a theft were to occur in the clinic). If contract staff, volunteers, or students, wish a letter of reference or any evaluation, we will collect information about their work related performance and provide a report as authorized by them.

WE COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES

Like most organizations, we also collect, use, and disclose personal 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 services and goods 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 appropriately for their then current needs and to consider modifications or replacement).

To advise clients and others of special events and opportunities (e.g., a seminar development, 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 are provide high quality service, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, practical consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our clinic, including client files and interviewing our staff.

Chiropractors are regulated by the College of Chiropractors 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 behavior to the authorities. External regulators have their strict privacy obligations. Sometimes these reports include personal information about our clients or other individuals, to support the concern (e.g. improper services). Like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Right 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., lawyer, accountant) who will investigate the matter and report back to us.

The cost of some services/goods provided by our clinic to clients is paid for by third parties (e.g. OHIP, WSIB, private insurance, Assistive Devices Program). In order to demonstrate client entitlement to this funding, these third party payers have your consent or legislative authority to direct us to collect or disclose to them certain information.

Our regulatory college requires that we retain our client information for a minimum of ten years after the last contact, or 10 years from when a minor becomes of legal age, if no longer receiving care. Retaining records for this period enables us to answer questions clients or other individuals we deal with may have about our goods and 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. If our clinic or its assets were to be sold, the purchaser would want to conduct a (due diligence) review of the clinics record 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 show substantial interest in buying 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). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation). We will always request your consent when possible.

PROTECTING PERSONAL INFORMATION

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. All of our cell phones are digital, which signals are more difficult to intercept.
Paper information is transmitted through sealed and addressed envelopes or boxed by reputable companies.
Electronic information is transmitted anonymized, sent through a reputable encryption service provider, or released to you in another capacity if you request and consent to that method.
Staff are 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.

RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

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 longer than necessary to protect your privacy.

We keep our client files for about ten 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 (e.g., 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.

We destroy paper files containing personal information by shredding. We destroy all electronic information by deleting it and when the hardware is discarded we ensure that the hard drive is physically destroyed personally or by a reputable computer service provider. Alternatively, we may send some or all of the client file to the client.

YOU CAN LOOK AT YOUR INFORMATION

With only a few exceptions, you have the right to see what personal information we have about you. We can help you identify what personal records we possess and will try to help you understand any information you do not understand (e.g., short forms, technical language). We will need to confirm your identity before providing you with this access. We reserve the right to charge a nominal fee for file copy requests.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days, if possible. We will also tell you, as best we can, the reason as to why we cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we have sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the information.

DO YOU HAVE A QUESTION?

Our Information Officer, Dr. Micael Carreira, can be reached at:

80 Marketplace Avenue, Unit 2
Ottawa, Ontario K2J 5G3
(613) 823-1255
drmike@marketplacechiropractic.ca

He will attempt to answer any of your questions or concerns.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He 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 our staff, we would appreciate it if you discussed those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:

College of Chiropractors of Ontario

The policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA). That is a complex act and provides 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 inquiries, the information and Policy 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:

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

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