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Cherrytree Physiotherapy Policy Statement
Privacy of personal information is an important principle to Cherrytree Physiotherapy Clinic.
We are committed to collecting, using and disclosing personal information responsibly and
only to the extent necessary for the goods and 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 their personal characteristics (e.g., gender, age, 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 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, Cherrytree Physiotherapy Clinic, includes at the time of writing one
Physiotherapist and one support staff.
WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES
About Clients
Like all physiotherapists, we collect, use and disclose personal information in order to serve
our clients. For our clients, the primary purpose for collecting personal information is to
provide physiotherapy 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 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. 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).
About Members of the General Public
For members of the general public, our primary purposes for collecting personal information
are to make them aware of Cherrytree Physiotherapy services in general or our clinic in
particular. 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, for any reason, possible,
we will upon request immediately remove any personal information from our distribution list.
About Contract Staff, Volunteers and Students
For people who are contracted 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 type 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 a health
emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft
were to occur in the clinic). If contract 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 or secondary to our primary purposes. The most common examples of our related and
secondary purposes are as follows:
• To invoice clients for goods or services that were not paid for at the time, to
collect unpaid accounts.
• To advise clients that their product or service should be reviewed (e.g., to ensure a
product is still functioning properly and appropriate for their then current needs and to
consider modifications or replacement).
• To advise clients and 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 clinic reviews client and other files for the purpose of ensuring that we in addition,
external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation
programs) may on our behalf do audits and continuing quality improvement reviews of our
Clinic, including reviewing client files and interviewing our staff.
• Cherrytree Physiotherapy is regulated by the College of Physiotherapists of Ontario
who may inspect our records and interview our staff as a part of their regulatory activities in
the public interest. Also, like all organizations, various government agencies (e.g., Canada
Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights
Commission, etc.) have the authority to review our files and interview our staff as a part of
their mandates.
• The cost of some goods/services provided by the organization to clients is paid for by
third parties (e.g., OHIP, WSIB, private insurance, Assistive Devices Program). 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 for many of our
clients 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 (our regulatory College also
requires us to retain our client records).
• lf the Cherrytree Physiotherapy Clinic or its assets were to be sold, the purchaser
would want to conduct a “due diligence” review of the Clinic’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 the 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). 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:
• Paper information is either under supervision or secured in a locked or
• 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, as such signals are more difficult to intercept.
• Paper information is transmitted through sealed, addressed envelopes or boxes by
reputable companies.
• Electronic information is transmitted either through a direct line or is anonymized or
encrypted.
• Staff is trained to collect, use and disclose personal information only as necessary to
fulfill their duties and in accordance with our privacy policy.
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, we do not want to keep personal information too long
in order to protect your privacy. We keep our client files for about ten years. 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 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.). 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 a nominal fee for such requests. If there is a problem we may ask you to put your
request in writing. If we cannot give you access, we will tell you within 30 days if at all
possible and tell you the reason, as best we can, as to why we cannot give you 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 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 still 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 A QUESTION?
Our Information Officer, Girma Begna, can be reached at: 55 Cherrytree Drive, Brampton, ON
| L6Y 3P6, PHONE (905) 456-2248. He will attempt to answer any questions or concerns you
might have. If you wish to make a formal complaint about our privacy practices, you may
make it in writing to our Information Officer. He 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 about the professionalism or competence of our
services or the mental or physical capacity 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: COLLEGE OF PHYSIOTHERAPISTS OF ONTARIO
230 Richmond Street West 10th Floor Toronto, Ontario M5V 1V6 www.collegept.org 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. For more general inquiries, the Privacy Commissioner of Canada oversees the
administration of the privacy legislation in the private sector. The Commissioner also acts as
a kind of ombudsman for privacy disputes. The Privacy Commissioner can be reached at: 112
KENT STREET | OTTAWA, ONTARIO | K1A 1H3 PHONE (613) 995-8210 | TOLL-FREE 1-800-282-
1376 | FAX (613) 947-6850 | TTY (613) 992-9190 www.privcom.gc.ca
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