Privacy of personal information is an important principle to VC Therapeutics. We are committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the services we provide. We attempt to be open and transparent about how we handle personal information. This document describes our privacy policies.

What is Personal Health Information?
Personal health information is information about an identifiable individual. Personal health information includes information that relates to:

• an individual’s personal characteristics (e.g. gender, age, home address or telephone number, ethnic background, employer, employment status, family status);
• the physical or mental health of the individual (including family health history);
• health (e.g. health history, health conditions, health services received by them);
• the provision of health care to the individual (including identifying the individual’s health care provider);
• payments or eligibility for health care or coverage for health care;
• activities and views (e.g. opinions expressed by an individual, an opinion or evaluation of an individual);
• the identification of the individual’s substitute decision-maker. Personal information is to be contrasted with business information (e.g. an individuals’ business address and telephone number) which is not protected by privacy legislation.
  
  

Who We Are
VC Therapeutics includes, at the time of writing, a registered massage therapist and a registered physiotherapist. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal health information we hold. These include specialists, referring health care providers, computer/software consultants, accountants, lawyers, credit card companies, and website managers. 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
Primary Purpose
Like all regulated health professionals, we collect, use, and disclose personal information in order to serve our patients. For our patients, the primary purpose for collecting personal health information is to provide appropriate, safe and effective patient care/treatment(s). For example, we collect information about a patient’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 patient’s express consent, but this might occur in an emergency (e.g. the patient is unconscious) or where we believe the patient would consent if asked and it is impractical to obtain consent (e.g. a family member passing a message on from our patient and we have no reason to believe that the message is not genuine).

Secondary Purpose
Like most organizations, 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:

• To invoice patients for goods and services that were not paid in full at the time the service was provided, to process credit card payments or to collect unpaid accounts (includes the use of collection agencies acting on our behalf).
• To advise patients that their product or service should be reviewed.
• To enable us to contact patients to schedule or confirm appointments and distribute information about the clinic (e.g. development of new service(s), arrival of new therapist, availability of new technique(s), update of clinic policies).
• To comply with external regulators. Massage therapists are regulated by the College of Massage Therapists of Ontario (CMTO) and physiotherapists are regulated by the College of Physiotherapists of Ontario, both of which may inspect our records and interview our staff as part of their regulatory
  activities in the public sector. Both regulatory bodies have their own strict confidentiality and privacy obligations. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes it should report information suggesting serious
  illegal behaviour to authorities. In addition, we may be required by law to disclose personal health information to various government agencies (e.g. Ministry of Health, children’s aid societies, Canada Customs and Revenue Agency, Information and Privacy Commissioner, etc.).
• The cost of some goods/services provided by us to patients 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.
• To facilitate the sale of our organization. If VC Therapeutics 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 the reputable purchasers who have already agreed to purchase the organization’s business or its assets would be provided access to personal information and only of the purpose of completing their due diligence search prior to closing the purchase.

You can choose to not 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 or the time service is rendered). We do not, however, have much choice about some of these related or secondary purposes (e.g. external regulation).

Browsing our Website, E-mailing our Clinic & Booking

Online We do not collect any personal identifiable information when browsing our site, with the exception of cookies, which are only used to help you navigate our website and are not used to monitor you.

When you book an appointment online or e-mail our clinic, we collect personal information necessary to provide you with the service(s) you have requested (e.g. respond to your email, book an appointment).

Marketing and Personal Information
Your personal information will never be provided to anyone outside the clinic for marketing purposes.

Our clinic will not supply your personal medical/identifiable information to any third party without your written consent. You may withdraw your consent for use and disclosure of your personal information at any time.

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, strong passwords are used on all computers and mobile devices.
• Personal health information is only stored on mobile devices if necessary. All personal health information stored on mobile devices is protected by strong encryption.
• We try to avoid taking personal health information home to work on there. However, when we do so, we transport, use and store the personal health information securely.
• Paper information is transferred through sealed, addressed envelopes or boxes by reputable companies with strong privacy policies.
• Electronic information is transmitted through either a direct line or is anonymized or encrypted.
• Our staff members are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• We do not post any personal information about our clients on social media sites.
• 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 service(s) 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 longer than necessary.

We keep our client files for at least 10 years from the date of the last patient interaction or from the date the patient turns 18.
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 Records
With only a few exceptions, you have the right to see what personal information we hold about you by simply contacting our clinic. We can 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. In the event of photocopying your chart, 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:

• We will contain the breach to the best of our ability, including by taking the following steps if applicable
• Retrieving hard copies of personal health information that have been disclosed
• Ensuring no copies have been made
• Taking steps to prevent unauthorized access to electronic information (e.g. change passwords, restrict access, temporarily shut down system)
• We will notify affected individuals
• We will provide our contact information in case the individual has further questions
• We will provide the Commissioner’s contact information and advise the affected individual of their right to complain to the Commissioner
• We will investigate and remediate the problem by:
  • Conducting an internal investigation
  • Determining what steps should be taken to prevent future breaches (e.g. changes to policies, additional safeguards)
  • Ensuring staff is appropriately trained and conduct further training if required
    
    

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 have any questions or concerns you can contact our Information Officer, Amanda Vogan, at:
VC Therapeutics
15-279 Weber St. North
Waterloo, ON N2J 3H8
519-208-2352
amanda@vctherapeutics.ca

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. Amanda 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.

If you have concern about 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 bodies:

College of Massage Therapists of Ontario 810-1867 Yonge St. Toronto ON M4S 1Y5
Tel. 416-489-2626 ext. 4149
Toll Free 1-800-465-1933 ext. 4149 Fax 416-489-2625
professionalconduct@cmto.com www.cmto.com

College of Physiotherapists of Ontario 800-375 University Ave. Toronto ON M5G 2J5
Tel. 416-591-3828 ext. 227
Toll Free 1-800-583-5885 ext. 227 Fax 416-591-775
investigations@collegept.org
www.collegept.org

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
1400-2 Bloor Street East, Toronto, Ontario M4W 1A8
Tel. 416-326-3333
Toll Free 1-800-387-0073
TDD/TTY. 416-325-7539
info@ipc.on.ca
www.ipc.on.ca

This policy is made under the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3. It is a complex statute and provides some additional exceptions to the privacy principles that are too detailed to set out here.