Privacy Policy

 

Privacy of personal information is an important part of our office in providing you with quality health care, and is principle to any therapeutic relationship including our Massage Therapy Practice. We understand the importance of protecting your personal information. As a Registered Massage Therapist, I am committed to collecting, using, and disclosing your personal information responsibly. (and only to the extent necessary for the goods and services we provide. We will be open and transparent as to how we handle personal information. Third document describes our privacy policies.)

 

At this time of writing, Akari Yokokawa, Registered Massage Therapist (RMT) has an administrative staff who works for her in a remote fashion.

is the only practitioner who comes in contact with your personal information are aware of the sensitive nature of the information that you have disclosed to us. They are all trained in the appropriate uses and protection of your information.

 

Below, we have outlined what our office is doing to ensure that:

  • Only necessary information is collected about you;
  • We only share your information with your consent;
  • Storage, retention and destruction of your personal information complies with existing legislation, and privacy protection protocols;

 

Do not hesitate to discuss our policies with the Clinic Director or any office staff member.

 

How Our Office Collects, Uses, and Discloses a Client’s Personal Information

 

Our office understands the importance of protecting your personal information. To help you understand how we are doing that, we have outlined here how our office is using and disclosing your information.

 

This office will collect, use and disclose information about you for the following purposes:

  • To deliver safe and efficient client care
  • To identify and to ensure continuous high quality service
  • To assess your health needs
  • To provide health care
  • To advise you of treatment options
  • To enable us to contact you
  • To establish and maintain communication with you
  • To offer and provide treatment, care and services in relation to the services available at our office
  • To communicate with other treating health-care providers, including specialists and general practitioners who are your referring and/r peripheral practitioners
  • To allow us to maintain communication and contact with you win order to distribute health-care information and to book and confirm appointments
  • To allow us to efficiently follow-up for treatment, care and billing
  • For teaching and demonstration purposes on an anonymous basis
  • To complete and submit health care claims for third party adjudication and payment
  • To permit potential purchasers, practice brokers or advisors to evaluate the clinic
  • To allow potential purchasers, practice brokers or advisors to conduct an audit in preparation for sale of the clinic
  • To deliver your files and records to the clinic’s insurance carrier to enable toe insurance company to assess liability and quantify damages, if any
  • To prepare materials for the regulating bodies and boards of our practitioners
  • To invoice for goods and services
  • To process credit card and debit payments
  • To collect unpaid accounts
  • To assist this office to comply with regulatory requirements
  • To comply generally with the law

By signing the office policies form, you have agreed that you have given your express informed consent to the collection, use and/or disclosure of your personal information for the purposes that are listed above, and as required by law. If a new purpose arises for the use and/or disclosure of your personal information, we will notify you in advance.

Be advised that your information may be accessed by regulatory authorities and for defence of legal issues.

Our office will not supply your insurer with your confidential medical history In the even this type of a request is made, we will forward the information directly to you for review and for your specific written consent.

When unusual requests are received, we well contact you for permission to release such information. We may also advise you if such a release is inappropriate.

You may, at any time, withdraw your consent for use or disclosure of your personal information, and we will explain the ramifications of that decision and the process.

You may ask to see this Privacy Policy at any time.

 

Inspired Life Health Centre Inc., the Health Information Custodian, Designates Daniel Chiang to be the contact person. He can be reached at:

 

 

He will attempt to answer any questions or concerns you might have. Any concern or complaint about our privacy practices must be made in written to the contact person. He will acknowledge receipt of your complaint, ensure prompt investigation and provide you with a written response. If he cannot satisfy your concerns, you are entitled to submit a complaint to an individual practitioner’s regulatory body.

 

This policy adheres to the Personal Health Information Protection Act, 2004.

 

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The commissioner also acts as a kind of ombuzman for privacy desputes. The Information and Privacy Commissioner can be reached at:

http://www.ipc.on.ca

 

July 2014

 

WHAT IS PERSONAL INFORMATION

 

Personal information is information about an identifiable individual. It includes information that related to their personal characteristics. These include gender, age, income, home or work addresses/phone numbers, ethnic background, family status, health history/conditions, other healthcare providers.

 

WHO ARE WE

Akari Yokokawa is a solo practitioner and the only Registered Massage Therapist (RMT) providing services at the time of this documents writing. She has a support staff (administrative tasks) in a remote fashion, however, no one will require regular access to her patients’ treatment record itself. Confidential information is kept locked secure in a locked cabinet, on her computer with password lock, or secured web-based booking/billing system at all times. The only that client’s treatment records will be accessed by Akari Yokokawa, RMT at the time of treatment. Our support staff will access to booking/billing system when administrative tasks being performed, however, she will never have access to clients’ treatment records.

The treatment room is not locked when Akari Yokokawa, RMT is not in the facility as other practitioners also use the room however, no physical records of her clients are kept in the treatment room thus no one cannot access to any of her clients’ information. Because this is a shared office space, there might be an occasion that we might have mutual clients or refer clients to one another, the client’s consent to share information form is provided when necessary should information that would benefit the client is wished to be shared.

 

PURUOSE OF COLLECTING CLIENT’S PERSONAL INFORMATION

Like all massage therapists, we collect, use and disclose personal information in order to serve our clients.

Primary purpose

For our clients the primary purpose for collecting personal information is

to provide massage therapy treatment. For example, we collect information about a client’s health history, including family history, physical condition and function and social situation, in order to help her assess what a client’s health needs are to advise the client of his/her options and then to provide the health care that the client choses to have.

A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing services we may identify changes that are occurring over time. It would be rare for us to collect such information without a client’s express consent, but this might occur in an emergency (e.g. a client is unconscious) or where we believe that 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 I have no reason to believe that the message is not genuine).

 

MEMBERS OF THE GENERAL PUBLIC

For members of general public, our primary purpose for collecting personal information are to provide notice of special events (e.g. a seminar or conference) or to make them aware of massage therapy services in general, or our practice in particular. For example, while we try to collect email addresses, additional phone numbers or contact information, we try to gain consent before using any such information for any other than appointment bookings/confirmations. We will remove such information immediately upon request, and will never forward any of this information to another business or practitioners distribution list.

CONTRACT STAFF

At the time, Akari Yokokawa does not contract with other RMTs, thus clients’ treatment records are not shared with other service providers. Exception is the time when Akari Yokokawa is away and the client would request a referral for other RMTs. In this case, the client’s information will be shared with client’s written consent.

Akari Yokokawa has a contract staff who helps administrative roles in a remote fashion and she has access to online booking and billing systems in order to perform this task. This contract administrative staff acknowledge the privacy policy and confidentiality of clients’ information.

 

USE OF PERSONAL INFORMATION FOR SECONDARY/RELATED PURPOSES

Like most organization, we collect, use and disclose information for purpose of related to or secondary to our primary purposes. The most common examples of related and secondary purposes are the follows:

  • To invoice clients for those goods and services that were not paid for at the time, to process a credit card payment, or to collect unpaid accounts
  • To advise clients that their product or services should be reviewed (e.g. to ensure a product is still functioning properly and appropriately for their current needs and to consider modifications or replacement)
  • To advise clients and others of special events, opportunities (e.g. seminar, new services/products)
  • We review clients file to ensure high quality of care. It is not uncommon for RMTs to be peer assessed by a member of the professional on behalf of the College of Massage Therapist of Ontario (CMTO). Records many be inspected, or we may be interviewed. This process ensures that regulatory activities are followed and the public is protected. Also like all organizations, various government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commissions etc.) have the authority to review our files and interview us as 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 and services provided by us may be paid by third parties (e.g. OHIP, WSIB, private insurance, ADP). These third party payers often have your consent or legislative authority to direct me to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
  • Clients may have questions about goods or services after they have been received. We provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful. We retain client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services. This is also required by the CMTO that these records be kept for that minimum time frame.
  • If our practice was to be sold, the purchaser would want to practice due diligence review of the records to ensure the business was viable. Purchaser would not be able to remove or record personal information. Written promise of confidentiality is required before any access to files if provided.
  • You many choose not to be part of these secondary or related 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 a choice about some of these related or secondary purposes (e.g. external regulation)

 

 

PROTECTING CLIENTS’ PERSONAL INFORMATION

We understand the importance of protecting your 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 cell phones are password protected and digital, which signals are more difficult to intercept.
  • Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies
  • Elctronic information is transmitted either through direct line or is anonymized or ancrypted.
  • A “staff” is trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this privacy policy.
  • External consultations and agencies with acess to personal information must enter information 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 question our clients migh have about the services provided and four my own accountability to external regulatory bodies, however, we do not want to keep personal information too long in order to protect our clients’ privacy.

We keep our clients file for about ten years. Our client and contact directories are as much more difficult to systemically destroy so we remove such information when we can if it does not appear that we will be contacting you again. However, if the client asks, we will remove such contact information right away. We keep any personal 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 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 all of the clients to our clients.

 

CLIENTS CAN LOOK AT YOUR INFORMATION

With only an few exception, a client has the right to see what personal information we hold about you. Often all they have to do is ask. We can help them identify what records we may have about you. We will also try to help them understand any information they do not understand (e.g. short forms, technical languages, etc.), we will need to confirm your identity, if we do not know them, before providing them with this access. We reserve the right to charge a fee for such request, If these is a problem we may ask them to put your request in writing. If we cannot give them access, we will tell them within 30 days if at all possible and tell them the reason, as best we can, as to why we cannot give you access.

If a client believes there is a mistake in the information, they have a right to ask for it to be corrected. This applies to factual information and not to professional opinion we many have formed. We may ask them to provide documentation that our files are incorrect. Where we agree that we made a mistake, we will make the correction, and notify anyone that may have received the incorrect information. If we do not agree that we have made a mistake, we will still agree to include this in our file a brief statement from the client on the point and we will forward this statement to anyone else that received the earlier information.

 

 

DO YOU HAVE QUESTIONS?

As the information officer, we can be reached at info@careforlymph.com  or (647)939-2273. We will attempt to answer any questions or concerns you might have.

If you wish to make a formal complaint about our private practices, you may make it in writing to us, we 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 or questions about the professionalism or competence of our services or our mental or physical capacities, we would ask that you discuss with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body;

 

COLLEGE OF MASSAGE THERAPIST OF ONTARIO (CMTO)

1867 Yonge Street, Suite 810, Toronto. ON  M4S1Y5

416-489-2629, (800) 465-1933, fax (416) 489-2625, cmto@cmto.com, www.cmto.com

This policy is made under the Professional Information Protection and Electronic Documents Act. that is a complex Act and provides some additional exceptions to privacy principles that are too detailed to set out here. There are some rare exceptions to tp the commitments set out above.

For more general inquiries, the information and privacy commissioner of Canada overseas the administration of the privacy legislation in the private sector. The Comissioner also acts as a kind of ombudsman for privacy disputes. The information and Privacy Comissioner can be reached at;

112 kent Street, Ottawa. ON, K1A1H3

613-995-8210, 1-800-282-1376, fax 613-947-6850, TTY 613-992-9190

www.privcom.gc.ca

 

 

STATEMENT OF INFORMATION PRACTICES

 

Collection of Personal Health Information

We collect personal health information directly from our clients, or from the person acting on their behalf. Types of information we may collect are, their name, date of birth, address, health history, records of their visits, details of the treatment(s) they received from us. We may sometimes collect personal health information about them from other sources, if we have obtained their consent to do so, or if the law permits.

 

Use and Disclosure of Personal Health Information

We may use their personal health information for the following purposes;

  • Treat and care for the clients;
  • Receive or directly invoice for their treatment and care (e.g. WSIB, private insurance);
  • Plan, administer and manage our interanal operations;
  • Conduct risk management and quality improvement activities;
  • Teach;
  • Complies statistics;
  • Comply with legal and regulatory requirements; and
  • Fulfill other purposes permitted or required by law.

 

YOUR RIGHTS

You may access and correct your personal health records or withdraw your consent for some of the above uses and disclosures (subject to legal exceptions), at any time by contacting us.

 

OUR RESPONSIBILITIES

We take steps to protect our clients’ privacy and health records from thief, unauthorized access, copying, modification, use, disclosure, and disposal. We conduct audits to manage privacy compliance. We take steps to ensure that anyone providing services in facility is aware of privacy policy, protection, are that our clients’ information is only used as is consented for.

 

CONTACT US

For additional questions or information, you may contact us at

info@careforlymph.com

(647)939-2273

 

 

You have the right to file a complaint with the Privacy Commissioner/Ontario if you think we have violated your rights.

The Commissioner can be reached at:

2 Bloor Street East, Suite 1400, Toronto, Ontario, M4W1B4.

Tel 418-326-3333 / 1-800-387-0037