PRIVACY POLICY
Privacy of personal information is an important principle to Renita Lam, RD. We are committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the 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:
WHO WE ARE
We interact with a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, data storage companies, temporary workers to cover holidays, credit card companies, cleaners, website managers, landlords and lawyers. 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.
WHY WE COLLECT PERSONAL HEALTH INFORMATION
We collect, use, and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal health information is to provide nutrition counselling. 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 primary 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.
We also collect, use, and disclose personal health information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
You can choose not to be part of some of these related or secondary purposes (e.g., by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g. external regulation).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
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, in order to protect your privacy, we do not want to keep personal information for too long.
We keep our client files for at least ten years from the date of the last client interaction if the client was younger than 18 at the date of the last visit, at least 10 years after the date that the client turns, or would have turned, 18 years of age.
We destroy paper files containing personal health information by cross-cut shredding. We destroy electronic information by deleting it in a manner that it cannot be restored. When hardware is discarded, we ensure that the hardware is physically destroyed, or the data is erased or overwritten in a manner that the information cannot be recovered.
YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you, by contacting [contact person]. 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, if we do not know you, before providing you with this access. We reserve the right to charge $30.00 for the first twenty pages of records and 25 cents for each additional page.
We may ask you to put your request in writing. We will respond to your request as soon as possible and generally within 30 days, if at all possible. If we cannot give you access, we will tell you the reason, as best we can, as to why.
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 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. At your request and where it is reasonably possible, we will notify anyone to whom we sent this information (but we may deny your request if it would not reasonably have an effect on the ongoing provision of health care). 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.
IF THERE IS A PRIVACY BREACH
While we will take precautions to avoid any breach of your privacy, if there is a loss, theft, or unauthorized access of your personal health information we will notify you.
Upon learning of a possible or known breach, we will take the following steps:
Depending on the circumstances of the breach, we may notify and work with the Information and Privacy Commissioner of Ontario. If we take disciplinary action against one of our practitioners [or revoke or restrict the privileges or affiliation of one of our practitioners] for a privacy breach, we are required to report that to the practitioner’s regulatory College. We may also report the breach to the relevant regulatory College if we believe that it was the result of professional misconduct, incompetence, or incapacity.
DO YOU HAVE QUESTIONS OR CONCERNS?
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. They will acknowledge receipt of your complaint and ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
Our Information Officer, Renita Lam, can be reached at:
647-725-9765 or hello@renitalam.com.
They will attempt to answer any questions or concerns you might have.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
The College of Dietitians of Ontario
5775 Yonge Street, Suite 1810, Box 30
Toronto, ON, M2M 4J1
PHONE (416) 598-1725 or 1-800-668-4990
You also have the right to complain to the Information and Privacy Commissioner of Ontario if you have concerns about our privacy practices or how your personal health information has been handled, by contacting:
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Telephone: Toronto Area (416/local 905): (416) 326-3333
Long Distance: 1 (800) 387-0073 (within Ontario)
TDD/TTY: (416) 325-7539
FAX: (416) 325-9195
www.ipc.on.ca
This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.