Privacy Policy
	Privacy of personal information is an important principle to Family Speech Clinic. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services 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 or phone number, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to 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 Our organization, the Family Speech Clinic, includes at the time of writing, four Speech Language Pathologists, three Communicative Disorders Assistants and one receptionist. 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 also include a Montessori Teacher, Camp Counsellors, Educational Assistants, Volunteers, Dietitians, temporary support staff to cover illness, janitorial and maintenance staff. 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 Like all speech language pathology services, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purposes for collecting personal information is to provide services related to speech language pathology (e.g. assessment and treatment of articulation and language disorders, voice, neurological communication disorders, fluency, reading, writing, etc.). Examples of the type of personal information we collect for those purposes include home and work contact information (in the case of a last minute cancellation),health history including family history, developmental milestones medical history and personal characteristics such as age, language, ethnic background, occupation, education/training. This information is collected in order to help us assess and treat issues related to speech language pathology. In certain instances it will be necessary to collect information from a family member on behalf of the client, such as a client or child who has aphasia. In these situations when appropriate, we will make every effort to make the client aware of information that has been shared. Information gathered about Contract staff, Volunteers and Students Our primary purposes for collecting personal information is to ensure they can be contacted regarding clinic matters (e.g. work projects) and for necessary work related communication. Examples of the type of personal information we collect for those purposes include the following: home address and phone number, education and experience. It is rare for the clinic to collect personal information without prior consent but it may happen in individual circumstances (e.g. if a theft were to occur at the clinic). WE COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES Like most organizations, we also collect, use and disclose information for purposes related to or secondary purposes are as follows: To invoice clients for goods or services that were not paid for at the time they were incurred and to collect unpaid accounts. To advise clients that their need for services should be reviewed (e.g., to reassess their current needs and to consider modifications to their home program or need to return to treatment) To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service) that we have available. Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our clinic, including reviewing client files and interviewing our staff. Speech Language Pathologists are regulated by the College of Audiologists and Speech Language Pathologists 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, the Family Speech Clinic believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., Canada Customs and Revenue Agency, Privacy Commissioner, Human Rights 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., lawyers, accountants) who will investigate the matter and report back to us. The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., private insurance, Assistive Devices Program). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding. Clients or other individuals we deal with may have questions about our goods or 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. We retain our client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our client records). If the Family Speech Clinic or it's assets were to be sold, the purchaser would want to conduct a "due diligence" review of the Clinic's records 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 have already agreed to buy the organization's business or it's assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase. 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, out of sight 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. Paper information is transmitted through sealed, addressed envelops or boxes by reputable companies or Canada Post. 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 for our own accountability to external regulatory bodies. We keep our client files for 10 years after last contact, by phone or in person, with the client. We destroy paper files containing personal information by shredding. YOU CAN LOOK AT YOUR INFORMATION With only a few exceptions, you have the right to see what personal information we hold about you. All you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, (e.g., you are the mother of a client and only the father is known to the clinician), before providing you with this access. We reserve the right to charge a nominal fee for such 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 and detail the reason, as best we can, 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 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 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 earlier information. DO YOU HAVE A CONCERN? To address any questions or concerns you might have, our Information Officer, Beth Cranmer-Smith, can be reached at: 130 Prospect Street Newmarket, Ontario L3Y 3T5 PHONE 905.954.1312 If you wish to make a formal complaint about our privacy practises, you may make it in writing to our information officer, who 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. For more general inquiries, the 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 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 www.privcom.gc.ca
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