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PRIVACY POLICY
Our Commitment to Privacy
We, at Nancy Haston & Associates Inc. (NHA), are committed to keeping confidential all personal information about you - the people to whom we provide service - our clients and workers (herein known as clients). As well, we protect the privacy of information pertaining to our customers and employees. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. In compliance with the Federal Government’s Personal Information Protection and Electronic Documents Act (PIPEDA), we have developed a Privacy Policy and processes related to the handling of personal information. Our policy is summarized below and may be amended from time to time.
What is personal information?
Personal information is information about an identifiable individual. This may include, but is not limited to:
name, address, telephone number(s), e-mail address
gender, date of birth, ethnic background, family and marital status
past and present medical and health information
insurance coverage
past and present daily activities (self-care, community, leisure, school and work)
employment and income information.
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
NHA is a private disability management company providing rehabilitation/vocational assessment and consulting services to individuals disabled as a result of illness or injury and/or third party payers such as WSIB, employers, private insurance companies or lawyers.
Purposes for Which NHA Collects and Uses Personal Information
Like all rehabilitation service providers, we collect, use and disclose personal information in order to serve you.
The primary purpose for collecting personal information is to provide rehabilitation/vocational assessment and consultation services to:
identify your needs
set goals
identify options, assistance and costs related to rehabilitation/vocational goals
identify appropriate resources or service providers to assist you
share related information with your service providers, insurer and/or representative
meet professional, legal and regulatory requirements.
We limit the collection, use and disclosure of personal information to only what is necessary for the identified purposes for which our services are retained and for our own internal quality control. Information may be obtained directly from you during interview/assessment, through review of hospital and other medical records, consultations with your health care providers, contact with your employer(s) and/or educator(s), contact with your insurance adjuster and/or lawyer. NHA collects personal information by fair and lawful means only.
In providing you with rehabilitation assistance, we use and/or liaise with a number of individual health care providers, equipment suppliers, consultants and agencies that may, in the course of their duties, have limited access to your personal information we hold. We require these service providers to comply with current privacy legislation and communicate with them to convey same.
Disclosure of Personal Information
We disclose personal information we hold as outlined in this Privacy Policy and otherwise as needed with the appropriate consent or authorization from you or your representative and only for the limited purposes and time frame identified prior to use.
Personal information is obtained from/disclosed to an insurance company or lawyer paying for your assessment and/or rehabilitation services and to the providers of the rehabilitation services. Personal information may be disclosed without your consent or knowledge when we are legally required to do so - e.g. to comply with a subpoena or court order relating to the production of records, or when there is an emergency that threatens your life, health or security, etc.
Some goods or services provided by NHA to clients are paid for by third parties (e.g. WSIB, private insurance companies, lawyers, etc.) Other NHA services are provided directly to and paid for by third parties. These third party payers often have client consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement.
Consent
Your verbal and/or written consent is obtained prior to the collection, use or disclosure of any personal information about you we collect, except where required by law, or where it is impossible or impractical for legal, medical or security reasons. Personal information that has been collected shall not be used for a new purpose until we identify the new purpose to you and your consent has been obtained.
You may choose to withdraw or refuse your consent at any time by calling or speaking with your NHA consultant, his/her supervisor or our Privacy Officer. You should be aware that if you decide to withdraw or refuse consent, our ability to provide you with the requested service may be diminished, suspended or terminated.
Protecting Personal Information
We understand the importance of protecting personal information. NHA uses appropriate security safeguards to ensure that all personal information is protected against unauthorized access, disclosure, copying, use or modification. NHA staff are trained to collect, use and disclose personal information only as necessary to fulfill their assigned duties and in accordance with our privacy policy.
Retention and Destruction of Personal Information
We are required to retain your personal information in accordance with any legislation that may apply, to fulfill the purposes for which the information was collected and for our own accountability to external professional regulatory bodies.
Files containing personal information are destroyed with appropriate care once the purpose for which the personal information was gathered has been fulfilled, to prevent unauthorized persons from accessing that information.
Access to Personal Information on File at NHA
With only a few exceptions, you have the right to know what personal information we hold on file. 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 access to your file. We reserve the right to charge a nominal fee for such requests.
We may ask you to put your request in writing to our Privacy Officer (contact information outlined below). 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 provide you access.
You have the right to question and request correction of any inaccurate or incorrect information on our file. 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 an error, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we made an error, 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.
NHA Privacy Officers
NHA has appointed Privacy Officers who are responsible for NHA’s privacy policy and related practices. To address any questions or concerns you might have, our privacy officers can be reached at:
| By Mail: | Nancy Haston
& Associates Inc.
2 Bloor Street West
Suite 900
Toronto, ON
M4W 3E2
| By Phone:
Toll Free:
By Fax: | 416-927-1614
1-800-465-1614
416-927-8677 |
| By E-mail: | rehab@nancyhaston.com | Website: | www.nancyhaston.com |
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy Officer(s). She 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, within 30 days if possible.
The Information and Privacy Commissioner of Canada oversees the administration of privacy legislation in the private sector. General questions relating to privacy legislation or other issues of concern may be directed to the Privacy Commissioner at:
04/2004
edited 07/2005
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