Privacy of personal information is an important principle to Plum Heath Inc. We are committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also strive 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 telephone number, ethnic background, 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, Plum Health Inc., includes at the time of writing, a director, office staff, an accountant, and a number of clinical staff and consultants; these include Rehabilitation Therapists (RTs) and Personal Support Workers (PSWs). We also have other consultants and agencies that may, in the course of their duties, have limited access to personal information that we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, insurers of the company, temporary workers to cover holidays, website managers, cleaners, and lawyers. We restrict their access to any personal information that 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
We collect, use, and disclose personal information in order to serve our clients. For our healthcare clients, the primary purpose for collecting personal information is to provide care and treatment. For example, we collect information about a client’s health history, including their family history, physical condition and function and social situation in order to help us assess what their health needs are, to advise them of their options and then to provide the health care they choose to have.
A second 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).
For our staff and consultants, the primary purpose for collecting personal information is to ensure that we can contact them in the future. Examples of the types of personal information that we collect for those purposes include business addresses and telephone numbers, and information gained in interviews relating to the nature of the work.
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 services offered by Plum Health Inc. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not possible for any reason, 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). Cookies are only used to help you navigate our website and are not used to monitor you.
About Staff, Volunteers and Students
For people who are hired 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. sending out paycheques, year-end tax receipts). Examples of the types 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 health emergency (e.g. COVID-19 outbreak; SARS outbreak) or to investigate a possible breach of law (e.g. if a theft were to occur in the office). If staff, volunteers, or students wish a letter of reference or an 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 information for purposes related to our secondary purposes. The most common examples of our related and secondary purposes are as follows:
- To invoice clients for goods or services not paid for at the time, or to collect unpaid accounts.
- To advise clients that their service should be reviewed.
- To advise clients or others of special events or opportunities (e.g. a seminar, development of a new service, arrival of a new product) that we have available.
Our company 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, on our behalf, external consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may do audits and continuing quality improvement reviews of our company, including reviewing client files and interviewing our staff.
Our consultants are regulated by their respective professional colleges (e.g. the College of Occupational Therapists 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 behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) who 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. WSIB, private insurance, Office of the Public Guardian and Trustee). 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 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.
If Plum Health Inc. or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the company’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 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 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). However, we do not have much choice about some of these related or secondary purposes (e.g. external regulations).
Protecting Personal Information:
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Clinical information is kept for 10 years from the time of closing a file
- Paper information is either under supervision or secured in a locked and 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, with signals that are more difficult to intercept than analogue.
- Paper information is transmitted in sealed, addressed envelopes or boxes via courier or Canada Post First Class Mail
- Electronic data is transmitted in encrypted format and is backed up to our encrypted, secure site and a separate back-up is kept in a different secure location
- 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, to protect your privacy, we do not want to keep personal information longer than necessary.
We keep our client files for ten years (paediatric files are kept for 10 years from the 18th birthday). 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 (i.e. with people who are not clients), newsletters, seminars and marketing activities for about six months and the newsletter ceases publication or a seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire client file to our client.
You Can Look at Your Information:
With only a few exceptions, you have the right to see what personal information we hold about you. Often, 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.). Before providing you with this access, we will need to confirm your identity. We reserve the right to charge a nominal fee for such requests.
We may ask you to put your request in writing. If we cannot give you access, then within 30 days we will tell you why we cannot give you access.
If you believe there is a mistake in the information we have on record, 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 sent this information. If we do not agree that we have made a mistake, we will 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 Any Questions?
We can be reached at (647) 875-2022 or at 1-(888)-354-1049. Alternatively, you can email us at firstname.lastname@example.org for further information.