PRIVACY POLICY

The privacy of personal information is a requirement as per the Personal Information Protection and Electronic Services Documents Act (PIPEDA), effective January 1, 2004.

Workwise is committed to collecting, using and disclosing personal information responsibly and only to the extent necessary, for the goods and services we provide. Our goal is to be open and transparent regarding our methods in handling personal information and this document describes our policy.

WHAT IS PERSONAL INFORMATION?

Personal information is information about an identifiable individual. It includes information about personal characteristics such as age, gender, home address, phone number, gender etc. It also includes information about an individual’s health history, medical conditions, treatments or investigations. Finally, it might be information about an individual’s activities and views such as religion, politics, opinions expressed by an individual or an opinion/evaluation of an individual. Personal information is NOT the same as business information, such as an individual’s business address and telephone number, and is therefore NOT protected by privacy legislation.

WHO WE ARE

Workwise Occupational Assessment Centre Inc. employs three administrative staff. In our day-to-day work, we use a number of physicians, psychologists, vocational evaluators and occupational therapists. These professionals have regulatory bodies with Privacy guidelines to which they must adhere. We also have assurances from them that they will follow the privacy principles.

In addition to the above professionals, we use a number of consultants, temporary office staff and agencies such as computer personnel, cleaners, couriers and service providers. We restrict their access to any personal information we hold, as much as is reasonably possible. We also have their assurances that they will follow the privacy principles.

WE COLLECT PERSONAL INFORMATION (Primary Purposes)

About Clients
Like all Assessment Clinics, we collect, use and disclose personal information to serve our clients. For our clients, the primary purpose of collecting personal information is to provide assessments of their current situation, usually requested by their insurance company. Examples of the type of personal information we collect include medical history, current treatments, origin of injury and causation of current complaints.

A second primary purpose might be to ensure that the results are reproducible, such that any opinion we offer is defensible and accurate.

A third primary purpose might be to ensure that the client is served in his or her language of choice, to make appropriate preparations for the assessment and to ensure the correct assessors are utilized for the client.

It would be rare for us to collect any personal information about a client without his or her express consent. It might occur, however, in a medical emergency, where the client is unable to give consent (i.e unconscious client, suicidal) or where we believe the client would consent if asked and it is impractical to obtain consent (i.e family member passing on information regarding our client and we have no reason to believe that the message is not genuine).

For members of the general public
We do not collect personal information about the general public, and any marketing of information is done to businesses, insurance companies, health clinics etc.

About staff
For our employees, our primary purpose for collecting personal information is to ensure that we can forward to them necessary work- related information, such as year-end tax receipts, tax filings etc.

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 customers for services rendered

-The cost of some goods/services provided by the organization to clients is paid for by third parties (i.e OHIP, WSIB, auto insurance). 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, insurers, lawyers or other individuals we deal with may have questions about our goods or services after they have been received. 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 respective regulatory Colleges also require us to retain our client records).

-As part of our business, we utilize the services of physicians, psychiatrists, psychologists, physiotherapists, occupational therapists, kinesiologists, massage therapists, and vocational evaluators. These professionals are regulated by their respective Colleges, who might inspect our records and interview our staff as part of their regulatory activities in the public interest. In addition, as professionals, we are required to report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own.

-External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concerns (i.e improper services). Also, like all organizations, various government agencies have the authority to review our files and interview our staff as a part of their mandates.

You can choose not to be part of some of these related or secondary purposes (i.e by declining special offers or promotions). We do not, however, have much choice about some of these related or secondary purposes.

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 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.

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 are trained to collect, use and disclose personal information only as necessary to fulfill their duties in accordance with our privacy policy.

External consultants and agencies with access to personal information must enter 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 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 (10) years. Our client and client 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.
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.

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 clarify any information you do not understand (short forms, technical information 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, Cisela Thoren, can be reached at:

1929 Russell Road, Suite 118, Ottawa, Ontario K1G 4G3
PHONE: (613) 731-5888 ext 221

She 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. She will acknowledge receipt of your complaint, ensure that it is investigated promptly, and that you are provided with a formal decision and reasoning in writing.

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 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 ombudsman for privacy disputes. The Information and 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)
www.privcom.gc.ca