WHAT IS PERSONAL INFORMATON

Personal information is information about an identifiable individual. Personal information includes information that relates to: an individual’s personal characteristics (e.g., gender, age, home address or phone number, education and training, family circumstances); health (e.g. history, health conditions, health services received); or, activities and views (e.g., occupation/profession, ideas and concerns expressed by an individual). Personal information is different from business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

WHO WE ARE

Our organization, Centre for Neurodiagnostic Services, includes one neuropsychologist, and non-registered therapists working under the supervision of a licensed psychologist. From time to time we also include psychologists in Supervised Practice and on occasion, psychological students working under the supervision of a licensed psychologist.

OUR PRIMARY PURPOSES FOR COLLECTING PERSONAL INFORMATION ARE SUMMARIZED BELOW.

About Clients

We collect, use and disclose personal information only in order to provide psychological services to our clients. For example, we collect information about a client’s health history, physical condition and function and social situation in order to help us assess what their mental health needs are, to advise them of their options and then provide the psychological services they choose to have. A second primary purpose is to obtain a baseline and ongoing record of psychological functioning so that in providing psychological services we can monitor treatment progress and identify changes that occur over time.

In some situations, the primary purpose of collecting personal information would be to conduct an assessment to provide a professional opinion about the individual’s psychological functioning. With the client’s consent, the opinion would be reported to the appropriate person or agency, for example, an insurance company, such as The Workplace Safety and Insurance Board (psychological/legal reports).

It would be rare for us to collect or disclose personal information without the client’s expressed consent, but this might occur in an emergency situation (in this case the client would be notified in writing as soon as possible) or if 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 the message is not genuine).

If a friend or family member of a client contacts the Center for Neurodiagnostic Services and wants to tell us something about a client (1) we will not acknowledge that the client is a patient, (2) we will not receive the information, and (3) we will let the client know about the contact.

There are several reasons for this conduct:
* To acknowledge to another person that an individual is a patient is a breach of the patient's right to privacy.
* The client has ownership of their own health and personal information. Our client can choose when, how, and if they want the Center for Neurodiagnostic Services to know something. It is not appropriate for us to collect information about the client without their permission.
* The patient has a right to decide whose voice is heard in the therapy room. It is their choice if they want us to hear the opinions or thoughts of that other person. That other person cannot intrude into the therapy session without our patient's permission.

Our duty is to you, our patient, not to the other person, with whom we have no relationship. Further, we have no way to assess the validity of the other person's report or their motivation.

About Members of the General Public who call for information about our services

For members of the general public, our primary purpose for collecting personal information (e.g., contact numbers) is to make them aware of the range of psychological services available in our clinic and to direct them to the appropriate clinician.

HERE ARE SOME ADDITIONAL REASONS WHY WE COLLECT PERSONAL INFORMATION.

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 services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
* Psychologists in supervised or autonomous practice are regulated by the College of Psychologists of Ontario who may inspect our records and interview our psychologists as a part of their regulatory activities in the public interest. The College of Psychologists of Ontario has its own strict privacy obligations.
* The cost of some services provided by the organization to clients is paid for by third parties (e.g., private insurance and WSIB). 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 (e.g., WSIB).

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 restriction area at all times. Encryption and passwords are used on computers.
* Paper information is transmitted through sealed, addressed envelopes or boxes by reputable couriers or Canada Post.
* Electronic information is transmitted through dedicated line only to people and agencies that have a privacy policy.
* All members of Centre for Neurodiagnostic Services are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.

LIMITS TO PROTECTION OF PRIVATE INFORMATION

Limits to the protection of private information include: legally mandated disclosure to Children’s Aid Society, College of Psychologists of Ontario and Court orders to release information, search warrants for a file in a criminal or legal case, and subpoenas.

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.

* Clients or other individuals we deal with may have questions about our 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 for the last contact to enable us to respond to those questions and provide these services. The College of Psychologists of Ontario also requires us to retain our client records. For clients who are seen before the age of 18, records are retained for ten years following their 18th birthday.

* If the Centre for Neurodiagnostic Services were sold none of the client records would be transferred to or accessed by the new owners.

* We destroy electronic information by deleting it and when the hardware is replaced or discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or all of the client file to our client. Personal information that is not part of the permanent clinical file is shredded.

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., abbreviations, technical language, etc.). We may need to confirm you identity, if we do not know you, before providing you with access. We reserve the right to charge a fee for such requests. 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 is Dr. Amena Syed. She can be reached at:

Centre for Neurodiagnostic Services
4950 Yonge St., Toronto, Ontario M2N 6K1
(416) 362-7933

Dr. Syed 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 written decision with reasons.

This policy is made under the Personal Information Protection and Electronic Documents Act.

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 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 1 800-282-1376
Fax (613) 947-6850 TTY (613) 992-9190
www.privcom.gc.ca