At SL3, are very concerned with protecting your privacy. We have, and always will, respect the privacy of your health information.
What is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information that relates to personal characteristics (e.g., gender, age, home address or phone number, language spoken, marital status), health (e.g., health history, health conditions, health services received) or activities and views (e.g. 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
SL3 consists of SLP, Irini Atkinson. To assist her in providing services, Irini will use a limited number of consultants or agencies (such as accountants, lawyers) that may, in the course of their duties, have limited access to personal information she holds.
Reasons for Collecting Personal Information About Clients
Like all speech-language pathologists, Irini’s primary purpose for collecting personal information is to provide speech, language, literacy, learning and/or cognitive services. Irini collects the following information (note that not all information is collected for all clients – Irini will only collect what she needs for each individual client):
Contact info (name, address, phone, email)
Insurance info (claim number, policy number, adjuster, company)
Gender
Age
Language
Education / training / occupation
Community involvements
Family status and home environment
Health history
Assessment results
Health services provided to or received by the person
Health and social information (including opinions expressed by the person) collected during the course of assessment or treatment
Prognosis and other opinions formed during assessment or treatment
Compliance with assessment and treatment
Reasons for discharge, discharge condition and recommendations
Irini collects this information in order to stay in contact with you, to help her assess what your needs are, to advise you of your options and then to provide you with the individualized health care you choose. This information also forms a baseline of health and social information so that in providing ongoing health services, Irini can identify changes that are occurring over time.
Irini also collects contact and service provision information for the following secondary purposes:
To secure payment for goods and services.
To contact you to determine the need for follow-up services
To provide examples (anonymized) for teaching purposes.
To allow her to meet our regulatory obligations; the College of Audiologists and Speech-Language Pathologists may inspect Irini’s records and interview her as a part of their regulatory activities in the public interest; various government agencies (e.g., Canada Revenue Agency, Privacy Commissioner, Human Rights Commission, etc.) have the authority to review Irini’s files and interview her as a part of their mandates; external regulators have their own strict privacy obligations
To provide information to third party payers (e.g., private insurance) when they pay for the goods and services you receive from Irini
To provide information for accounting and tax purposes
To answer any questions you may have about the service you received once it is concluded
Irini will obtain your consent to disclose your personal information in these instances except in instances where there is legislative authority to collect the information.
It would be rare for Irini to collect any personal information without your express consent, but this might occur in an emergency (e.g., you are unconscious) or where she believes you would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from you and Irini has no reason to believe that the message is not genuine).
Protecting Personal Information
Irini understands the importance of protecting personal information. For that reason, she has taken the following steps:
Irini no longer keeps a paper file that has any information beyond the first name of the client and possibly date of birth; all documentation is secured in an encrypted electronic medical record with a server housed in Canada
Any electronic information stored on portable devices (e.g., disks, memory sticks, laptop computers) is anonymized
Any paper information that is anonymized and/or locked out-of-sight and/or under supervision
Electronic hardware is either under supervision or secured in a locked or restricted area
Irini’s servers meet and exceed security standards and privacy requirements, both for physical and electronic access, encryption and back up
Three levels of passwords are required to access health data and all three levels are changed every three months
Special care is taken when transmitting electronic information; unless you have specifically requested otherwise, confidential information is password protected when being emailed, or sent via secure encryption such as Secure Docs
Where Irini is unsure of the security of the electronic transfer of information, identifying information is removed
External consultants and agencies with access to personal information must demonstrate their adherence to privacy laws
Reports and/or progress notes are only sent to outside parties for whom the information will be helpful, and only with your written consent
Retention and Destruction of Personal Information
Irini needs to retain personal information for some time to ensure that she can answer your questions about the services provided and for our own accountability to external regulatory bodies.
The College of Audiologists and Speech-Language Pathologists of Ontario requires that Irini retain her client records for 10 years past the last visit or in the case of a child, for 10 years past the 18th birthday.
Working notes and recordings are destroyed regularly throughout intervention, as Irini transfers the information into progress notes and reports which are uploaded to a secure electronic medical record.
Irini destroys paper documents containing personal information by shredding. She destroys electronic information by deleting it.
You Can Look at Your Information
With only a few exceptions, you have the right to see what personal information Irini holds about you. Irini can help you understand any information you do not understand (e.g., short forms, technical language, etc.). She will of course need to confirm your identity before providing this access. Irini reserves the right to charge a nominal fee for such requests.
If there is a problem, Irini will ask for the request in writing. If she cannot provide access, she will tell you within 30 days if at all possible and explain the reason, as best she can, as to why she cannot provide 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 not professional opinions. Irini may ask for documentation that her files require correction. Where she agrees that a mistake was made, she will make the correction and notify anyone to whom we sent this information. If she does not agree that there is a mistake, she will still agree to include in the file a brief statement from you on the point and will forward that statement to anyone else who received the earlier information.
Questions or Concerns?
Irini can be reached at:
Phone: (905) 999 0918
Email: irini@SL3.ca
Formal complaints about her privacy practices can be made in writing to Irini. She will acknowledge receipt of the complaint, ensure that it is investigated promptly, and that you are provided with a formal decision and reasons in writing.
This policy is made under the Personal Information Protection and Electronic Documents Act and the Personal Health Information Protection Act. These are complex Acts and provide 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.
The Office of the Information and Privacy Commissioner of Ontario oversees the administration of the privacy legislation in Ontario. The Commissioner also acts as an ombudsperson for privacy disputes. The Office of the Information and Privacy Commissioner of Ontario can be reached at:
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
Tel: 1-800-387-0073