Regarding Contract Staff, Volunteers, and Students

For persons contracted to perform services for South City Physiotherapy (e.g., temporary workers), South City’s primary purpose for collecting personal information is to ensure it can contact them in the future as required for business purposes (e.g., sending out paychecks, year end tax documents), or to offer additional contracts for service.(e.g., for new assignments).

Examples of the types of personal information collected for those purposes include home addresses, telephone, and SIN numbers.

Related and Secondary Purposes

(for the collection of personal information)

Like most organizations, South City Physiotherapy also collects, uses and discloses information for purposes related to, or secondary to its primary purposes. The most common examples of related and secondary purposes are as follows:

(a) To invoice clients for goods or services that were not paid for at the time of delivery, to process credit card payments, or to collect unpaid or overdue accounts.

(b) 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).

(c) 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 is available.

(d) Client and other files are reviewed for the purpose of ensuring that high quality services are provided, and of assessing the performance of clinic staff. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may on behalf of South City perform audits and continuing quality improvement reviews, including reviewing client files and interviewing clinic staff.

(e) Physiotherapists are regulated by the College of Physiotherapists of Ontario who may inspect clinic records and interview clinic staff as a part of their regulatory activities in the public interest. In addition, as professionals, clinic staff will report serious misconduct, incompetence or incapacity of other practitioners, whether they are associated with South City or another clinic.

(f) South City believes it has an obligation to report information suggesting serious illegal behaviour to the authorities.

(g) External regulators have their own strict privacy obligations. Sometimes these reports include personal information about clients, or other individuals to support a given concern (e.g., improper services). Various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review clinic files and interview staff as a part of their mandates. In these circumstances, South City may consult with professionals (e.g., lawyers, accountants)
(h) The cost of some goods/services provided by the clinic to clients is paid for by third parties (e.g., OHIP, WSIB, private insurance, Assistive Devices Program.) These third-party payers often have client consent or legislative authority to direct South City to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.

(i) Clients or other individuals South City deals with may have questions about goods or services provided, after they have been received. The clinic also provides ongoing services for many of its clients over a period of months or years for which previous records are helpful. Client information is retained for ten years after the last contact to enable the clinic to respond to those questions and provide these services. (Compliance with College regulations also requires us to retain our client records).

(j) If South City Physiotherapy or its assets were to be sold, any prospective purchaser would want to conduct a “due diligence” review of the Clinic’s records to ensure that it was a viable business, and that its operations had been honestly portrayed to the purchaser. This due diligence might involve some review of accounting and service files. No prospective purchaser would be able to remove or record personal information. Further, before being provided access to any files, any prospective purchaser would be required to sign a confidentiality agreement. Only a reputable prospective purchaser who had already entered a conditional agreement to purchase 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.

Any client 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, or by paying for services in advance). South City Physiotherapy does not however have any option regarding compliance with the directives of some external regulatory bodies.

Protecting Personal Information

South City Physiotherapy understands the importance of protecting personal information. For that reason, the following steps have been taken:

(a) Paper information is always either under the direct personal supervision of an authorized individual, or secured in a locked or restricted area.

(b) Electronic hardware is always either under the direct personal supervision of an authorized individual, or secured in a locked or restricted area. Additionally, passwords are used on all computers.

(c) Paper information is only ever transmitted through sealed, addressed envelopes or boxed and maintained in secure storage by reputable companies.

(d) Electronic information is always transmitted either through a direct line or it is anonymized or encrypted before transmission.

(e) All Clinic staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties, and always do so in a manner that is in accordance with our privacy policy.

(f) External consultants and agencies with access to personal information must enter into privacy agreements with South City Physiotherapy.

Retention & Destruction Of Personal Information

South City Physiotherapy needs to retain personal information for some time to ensure that it can respond to questions clients or external regulatory bodies might have about the services provided. (Client files must be maintained for ten years after the last treatment, other business files for seven years). In the interest of protecting personal privacy, South City does not keep personal information longer than it is required to by regulation.

Paper files containing personal information are destroyed by shredding. Electronic information is destroyed by deleting it and, before hardware is discarded, any hard drives are physically destroyed. Alternatively, if requested by a client to do so, South City will turn some of, or the entire client file over to the client.

Access To Your Information

With few exceptions, individuals have the right to see what personal information South City or any other organization may hold about them.

South City is always happy to identify what records it holds regarding an individual. Due to the medical nature of its clinic practice, it is also always willing to help individuals understand any information held (e.g., short forms, technical language, etc,).

In cases where the South City staff member receiving a request for access to personal information, does not personally know the identity of the person making the request, the identity of the person making the request must be confirmed before access is provided. South City reserves the right to charge a nominal fee for such requests.

If there are any issues with a verbal request for access to personal information, South City will require that the request be put in writing. If South City still cannot comply with the request for access, it will, within 30 days, provide a written response detailing why access cannot be provided.

If an individual believes there is a mistake or incorrect information being maintained in South City Physiotherapy’s files, that individual has the right to ask that the information be corrected. (This applies to factual information, and not to any professional opinions South City and or its professional staff may have formed.)

In such a case, an individual may be asked to provide documentation supporting the claim that information contained in South City files is incorrect. Where South City agrees that an error has been made, South City will make any required correction and update any person or organization to whom this incorrect information was disclosed. If South City does not agree that an error has been made, South City will still agree to include in its files a brief statement from the dissenting individual on the point, and will forward that statement to any person or organization who received the original information now in dispute.