Purpose of Policy
1. Privacy of personal information is governed by the Personal Information Protection and Electronics Documents Act (“PIPEDA”). This policy describes the way Filosofi Holistic Health Centre (“Filosofi”) collects, uses, retains safeguards, discloses and disposes of personal information, and states Filosofi's commitment to collecting, using and disclosing personal information responsibly. This policy is based on the standards required by PIPEDA, and Filosofi's interpretation of these responsibilities.
2. A copy of Filosofi Holistic Health Centre's Privacy Policy is provided to any client on request.
Background
3. Filosofi Holistic Health Centre is a health centre comprised of multiple regulated and un-regulate health care professionals who provide the following services to clients and patients:
a) Professional health care services including but not limited to: chiropractic (network spinal analysis), therapeutic massage and other services from time to time.
b) Classes, seminars and retreats related to the above mentioned services.
Personal Information
4. 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, 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, however, does not include business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
Accountability
5. Lisa Silfwerbrand is the Privacy Officer and is responsible for the monitoring of information collection and data security, and ensuring that all staff receives appropriate training on privacy issues and their responsibilities. The Privacy Officer also handles personal information access requests and complaints. The Privacy Officer may be contacted at privacy@filosofi.ca.
Primary Purpose
6. Personal information is collected and disclosed in order to ensure the best possible care for our patients and clients. For example, Filosofi collects a personal health history about patients to assist health care professionals in developing a quality health care program to best meet the patient's needs. Personal information may be disclosed with consent to related third parties to receive payment (ex. insurance, WSIB, MVA).
Secondary Purposes
7. Personal information is also collected to be able to notify patients of upcoming events, additional services of potential interest, health classes and promotions. This applies to current, past and potential clients. Other related purposes include:
a) to invoice clients, process credit card payments, or to collect unpaid accounts
b) to remind patients of scheduled appointments, or that it is time for a patient to contact us to schedule an appointment
c) Communication to patients may include email, newsletters, cards, telephone reminders and other means of communication. Telephone messages may be left from time to time on an answering machine or through an answering service.
Consent
8. Consent is required to be obtained by lawful means from individuals at the time of collection, prior to the use or disclosure of the personal information. Filosofi may collect personal information without consent where reasonable to do so and where permitted by law.
9. By providing personal information to Filosofi Holistic Health Centre, individuals are consenting to the use of the information for the purposes identified in this policy.
10. In determining the form of consent to use, Filosofi will take into account the sensitivity of the information.
11. Filosofi will not, as a condition of a product or service, require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill the specified purpose.
12. An individual may withdraw consent to the collection, use or disclosure of personal information at any time, subject to legal or contractual restrictions. The Privacy Officer will advise the individual of the implications of such withdrawal.
Limiting Collection
13. All personal information will be collected fairly, by lawful means and for the purposes as specified in this policy.
Limiting Use, Disclosure and Retention
14. Personal information will not be used or disclosed by Filosofi for purposes other than those for which it was collected as described herein, except with the consent of the individual or as required by law.
15. Information disclosed to a third party with consent from the individual shall be protected by a third party agreement to limit use and disclosure.
16. Personal information will be retained for up to ten years from the last contact with the Individual.
17. Filosofi may disclose personal information to a government authority that has asserted its lawful authority to obtain the information or where Filosofi has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court or otherwise as permitted by applicable law.
18. Documents will be destroyed by way of shredding and electronic files will be deleted in their entirety. When hardware is discarded, Filosofi will ensure that the hard drive is physically destroyed.
Accuracy
19. Filosofi will use accurate and up-to-date information as is necessary for the purposes for which it is to be used, to minimize the possibility that inappropriate information may be used to make a decision about an individual.
Safeguards
20. Personal information is protected by security safeguards appropriate to the sensitivity of the information against loss or theft, unauthorized access, disclosure, copying, use or modification.
21. Methods of protection and safeguards include, but are not limited to, locked filing cabinets, restricted access to offices, security clearances, need-to-know access and technological measures including the use of passwords, encryption and firewalls.
22.. The following steps will be taken to ensure security:
a) Paper information is either under supervision or secured in a locked or restricted area.
b) Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.
c) Paper information is transmitted through sealed, addressed envelopes or in boxes by reputable courier/delivery companies.
d) Electronic information is transmitted either through a direct line or is encrypted.
e) Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this policy.
f) External consultants and agencies with access to personal information will provide Filosofi with appropriate privacy assurances.
Openness
23. Filosofi will publicize information about its policies and practices relating to the management of personal information. This information is on Filosofi's web site or upon request by contacting the Privacy Officer, privacy@filosofi.ca.
24. The information available to the public includes:
a) The name or title, address and telephone number of Filosofi Holistic Health Centre's Privacy Officer.
b) The forms that may be used to access personal information or change information.
c) A description of the type of personal information held by Filosofi Holistic Health Centre, including a general statement of its approved uses.
Individual Access
25. Upon written request, and with assistance from Filosofi Holistic Health Centre, an individual may be informed of the existence, use and disclosure of his or her personal information and will be given access to that information. As well, an individual is entitled to be informed of the source of the personal information along with an account of third parties to whom the information has been disclosed.
26. Requested information will be disclosed to the individual within 30 days of receipt of the written request at no cost to the individual, or at nominal costs relating to photocopying expenses, unless there are reasonable grounds to extend the time limit.
27. If personal information is inaccurate or incomplete, it will be amended as required.
28. An individual may be denied access to his or her personal information if:
a) This information is prohibitively costly to provide;
b) The information contains references to other individuals;
c) The information cannot be disclosed for legal, security or commercial proprietary purposes;
d) The information is subject to solicitor-client or litigation privilege.
29. Upon refusal, Filosofi Holistic Health Centre will inform the individual the reasons for the refusal and the associated provisions of PIPEDA.
Challenging Compliance
30. An individual may challenge Filosofi's compliance with this policy and PIPEDA, by submitting a challenge in writing to our Privacy Officer at privacy@filosofi.ca.
31. Upon receipt of a written complaint, Filosofi Holistic Health Centre will:
a) Record the date the complaint is received;
b) Notify the Privacy Officer who will serve in a neutral, unbiased capacity to resolve the complaint;
c) Acknowledge receipt of the complaint by way of telephone conversation and clarify the nature of the complaint within three days of receipt of the complaint;
d) Appoint an investigator using Filosofi personnel or an independent investigator, who will have the skills necessary to conduct a fair and impartial investigation, and who will have unfettered access to all files and personnel, within ten days of receipt of the complaint.
e) Upon completion of the investigation and within 25 days of receipt of the complaint, the investigator will submit a written report to Filosofi Holistic Health Centre.
f) Notify the complainant of the outcome of the investigation and any relevant steps taken to rectify the complaint, including any amendments to policies and procedures, within 30 days of receipt of the complaint.
IP Address
32. When the user's web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer's "IP address."
33. Filosofi may collect, use and disclose IP Addresses during its course of business.
Cookies
34. Cookies are small text files that a Web browser transfers to and from your hard drive for record keeping purposes. Cookies make life easier for you by saving your passwords, purchases, and preferences while you're at our site. The use of cookies is an Internet standard, and you'll find cookies at most major Web sites.
35. The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on websites.
36. Filosofi Holistic Health Centre does not use cookies to identify specific individuals.
Copyright and Legal Disclaimer
37. This web site is a product of Filosofi Holistic Health Centre. The information on this Web site is provided as a resource to those interested in our services. Filosofi Holistic Health Centre disclaims any representation or warranty, express or implied, concerning the accuracy, completeness or fitness for a particular purpose of the information. Persons accessing this information assume full responsibility for the use of the information and understand and agree that Filosofi Holistic Health Centre is not responsible or liable for any claim, loss or damage arising from the use of this information. Reference to specific products, processes or services does not constitute or imply recommendation or endorsement by Filosofi. Filosofi also reserves the right to make changes at any time without notice.
38. Links made available through this website may allow you to leave the Filosofi Holistic Health Centre site. Please be aware that the internet sites available through these links are not under the control of Filosofi. Therefore, Filosofi does not make any representation to you about these sites or the materials available there. Filosofi is providing these links only as a convenience to you, and in no way guarantees these links and the material available there. Filosofi is not responsible for privacy practices employed by other companies or websites.
Applicable Law
39. This site is created and controlled by Filosofi Holistic Health Centre in the
Contact Information