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, income, home address or phone number, ethnic background, family status), their health (e.g. health history, 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
The Northern Ontario Surgical Centre is comprised of doctors, registered nurses, administrative and support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold, including but not limited to computer and information technology consultants and credit card companies. 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.
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 surgical or medical 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).
Members of the General Public
We collect personal information about the general public to provide notice of special events such as a promotion, seminar or conference, and to raise awareness of services offered by the medical community in general or by Weight Loss Unlimited in particular. With the exception of general distribution advertising, we obtain consent before using any such personal information to make contact. We will, upon request, immediately remove any personal information from our distribution list.
On our website, we collect only the personal information you provide and only use that information in the manner for which you provided it, for example, to respond to your email message or to subscribe to our newsletter. Cookies are collected also, which are only used to help you navigate our website and are not used to monitor you.
About Contract Staff and Temporary Workers
We collect personal information contract staff and temporary workers in order to ensure we can contact them in the future for new assignments or contracts, 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.
Related and Secondary Purposes
Like most organizations, the Northern Ontario Surgical Centre also collects, uses and discloses 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 process credit card payments or to collect unpaid accounts.
- To advise clients that their product or service should be reviewed (e.g., to ensure a product is still current and appropriate for their 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.
- For the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, practice consultants, accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our Centre, including reviewing client files and interviewing our staff.
- Plastic Surgeons are regulated by the College of Physicians and Surgeons of Ontario who may inspect our records and interview our staff as part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. 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 part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
- The cost of some goods/services provided by the organization to the clients is paid for by third parties (e.g., OHIP, WSIB, private insurance, Assistive Devices Program). These third-party payers will have patient consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
- If the Northern Ontario Surgical Centre or its assets were to be sold, the purchaser may 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. This purchaser would not be able to remove or record personal information and would be required to provide a written confirmation agreeing to keep all personal information confidential.
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information is under supervision and/or secured in a locked or restricted area.
- Electronic hardware is under supervision and/or secured in a locked or restricted area at all times. All computers are password protected.
- External consultants and agencies with access to personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
Client medical files are retained for ten years after the last date of medical service in accordance with CPSO regulations. Client contact information required for general advertisement, promotion or education will be removed from directories at the request of the client.
When destruction is necessary, paper files containing personal information are shredded. Destruction or removal of electronic information is performed by contracted computer hardware experts.
DO YOU HAVE A QUESTION?
Our Information Officer can be reached at:
The Northern Ontario Surgical Centre • 205 Douglas Street • Sudbury, ON • P3E 1E9
PHONE (705) 523-4900 • TOLL-FREE: 1-877-523-4900 •
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. We 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 any of our professional staff we would ask that you discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
COLLEGE OF PHYSICIANS AND SURGEONS
PHONE 416-967-2600 • TOLL-FREE 1-800-268-7096 • Website: www.cpso.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.
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) 992-9190 www.privcom.gc.ca