Privacy Policy:

Privacy of personal information is an important principle and we are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also try to be open and transparent as to how we handle personal information.

Limestone Health Consultants Inc Privacy Policy:

Privacy of personal information is an important principle to Limestone Health Consultants Inc. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also try to be open and transparent as to how we handle personal information. This document outlines our privacy policy.

 

What is Personal Information?

Personal information is information about an identifiable individual. Personal information includes that which relates to their personal characteristics (e.g., age, income, home address, phone number, work information, family status, and ethnic background), their health (e.g., health history, health conditions, health services received) or their activities or views (e.g., religion, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information, which is not protected by privacy legislation.

 

Who We Are:

Limestone Health Consultants Inc. includes at the time of writing 3 salaried staff and 8 contract consultants who in the course of their business on behalf of our company have access to personal information in order to provide rehabilitation services to our customers and clients. These include: an administrative manager, physiotherapist, counsellor, rehabilitation worker, 2 psychologists, and 5 occupational therapists. We restrict their access to any personal information to that which is reasonable and necessary for their role within our company. In addition, lawyers, accountants, office maintenance have limited access to personal information we hold as much as reasonably possible. We, at Limestone Health Consultants, also have their assurances that they follow appropriate privacy principles.

 

We Collect Personal Information: Primary Purposes:

Like all rehabilitation companies, Limestone Health Consultants Inc. collects, uses and discloses personal information related to rehabilitation services in order to serve our clients.

 

Clients:

For our clients, the primary purpose for collecting personal information about an individual is to provide rehabilitation services for that person. For example, we might collect information related to a person's health history, including their physical and mental condition, function, and social situation to help us assess what their rehabilitation needs are, to recommend their rehabilitation options and then to provide those services that they approve. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing rehabilitation services we can identify changes 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 a client and we have no reason to believe that the message is not genuine).

 

Members of the General Public and Customers:

For members of the general public and customers, our primary purposes for collecting personal information are to provide notice of special events, such as a seminar or conference, or to make them aware of services in our company. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers, home telephone numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.

On our web site we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to email, to register for a course, to subscribe to our newsletter). Cookies are only used to help you navigate our web site and are not used to monitor you.

 

Contract Staff and Students:

For the people who are contracted to do work for us (e.g. contract staff), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., new work assignments) and for necessary work ? related communication (e.g. sending paycheques). The type of information we might collect could include: home addresses, telephone numbers, pager numbers, email addresses, and fax numbers. It is rare for us to collect such information without prior consent, however, it might occur in the case of a health emergency (e.g., SARS) or to investigate a possible breach of law (e.g. theft from our office). If contract staff or students wish a letter of reference or an evaluation, we will collect information about their work ? related performance and provide a report as authorized by them.

 

We Collect Personal Information: Related and Secondary Purposes:

Like many organizations we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of this 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 service should be reviewed (e.g., to ensure the service is still relevant to their needs);
• Our company reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g., lawyers, auditors, accountants, private consultants, and voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our company and its services. This may include reviewing client files and interviewing some of our staff and contract consultants;
• Our professional staff are regulated by their respective colleges or councils who may inspect 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. Also, our organization believes it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals to support the concern (e.g., improper services). Also, 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 a 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 services/goods provided by this organization to clients is paid for by third parties (e.g., 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;
• Clients or other individuals we deal with may have questions about our goods or services after they have been received. We also provide 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 10 years after the last contact to enable us to respond to those questions and provide our services. (our regulatory Colleges(Physiotherapy, Psychology. Occupational Therapy, and Counselling) also require us to retain records); and
• If Limestone Health Consultants Inc. or its assets were to be sold, the purchaser would want to conduct a ?due diligence? review of our records to ensure that it is a viable operation 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 reputable purchasers who have already agreed to buy the organization's business or it's assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events, by paying your services in advance). We do not, however, have much choice about some of the related or secondary purposes (e.g., external regulation)

 

Protecting Personal Information:

We understand the importance of protecting personal information. For that reason, we have undertaken the following steps to protect your information:

• 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 a reputable company.
• 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 fulfil their duties and 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 a period of time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulators. 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 years. Our client and contact directories are much more difficult to systematically destroy, so we may remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence (e.g., with people who are not clients) newsletters, seminars, and marketing information for about 6 months after the newsletter ceases publication or a seminar or marketing activity is over.

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. Alternatively, we may send some or all of the client file to our client.

 

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 ask that you put your request in writing to facilitate the process. 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 this access. We reserve the right to charge a nominal fee for such requests.

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 feel 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 that 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, Sherrey Larmour ? Trode, can be reached at:

• 541 Days Rd, Kingston, ON, K7M 3R8
• Phone: (613) 389 ?2350
• Fax: (613) 389 ? 5354
• Email: limeston@kos.net
•  

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 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 your concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:

• College of Occupational Therapists of Ontario
• College of Physiotherapists of Ontario
• College of Psychology of Ontario
• Council of Rehabilitation Counsellors of Ontario

This policy is made under the Personal Information Protection and Electronic Documents Act. This is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to outline in this document. There are some rare exceptions to the commitments set out in this document.

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 the privacy disputes. The Information and Privacy Commissioner can be reached at:

• 112 Kent Street, Ottawa, On, K1A 1H3
• Phone: (613) 995 ? 8210
• Toll Free: 1 ? 800 ? 282 ? 1376
• Fax: (613) 947 ? 6850
• TTY: (613) 992 ? 9190
• www.privcom.gc.ca