Privacy of personal information is an important principle to Dr. Pamela Schmitz Dr. Linda Sujo, Associates in Optometry. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.
WHAT IS PERSONAL INFORMATION? Personal information is information dbout dn identifiqble individual. Personal information includes information that relates to their personal characteristics (e.., Gender, age, home address or phone number, family status, their health (e.., Health history, health conditions, health services received by them) or their activities and views (e.., opinions expressed by an individual, an opinion or evaluation of an individual. Personal information is to be contrasted with business information (e.., an individuals business address and telephone number, which is not protected by privacy legislation.
who we ARE Our organization, Dr. Pamela Schmitz and Dr. Linda Sujo, Associates in Optometry, includes at the time of writing four optometrists and 9 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. These include computer consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, cleaners and lawyers. 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 PERSONAL INFORMATION: PRIMARY Purposes
About Patients Like all Optometrists, we collect, use and disclose personal information in order to assess, treat and service our patients. For our patients, the primary purpose for collecting personal information is to provide Optometric treatment. For example, we collect information about a patients health history, including their family history, 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 secondary primary purpose is to obtain a baseline of ocular health 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 patients express consent, but this might occur in an emergency (e.. the client is unconscious) or where we believe the patient would consent if asked and it is impractical to obtain consent (e.., a family member passing a message on from our patient and we have no reason to believe that the message is not genuine).
About Members of the General Public For members of the general public, our primary purposes for collecting personal information are to make them aware of Optometric services in general or our office in particular. For example, we may collect home addresses, fax 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 website 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.., to respond to your email message or to subscribe to our quarterly newsletter. Cookies are only used to help you navigate our website and are not used to monitor .
About Contract Staff, Volunteers and Students For people who are contracted to do work for Us (e.., cooperative students), our primary purpose for collecting personal information is to ensure we can contact them in the future. (e.., for possible parttime employment or new assignments). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of health emergency (e.., a SARS outbreak) or to investigate a possible breach of law (e.., if a theft were to occur in the office). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a repl ort as authorized by them.
WE COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY Purposes 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 patients for goods and services that were not paid for at the time, to process credit card payments or to collect unpaid accounts
The cost of some goodsservices provided by our office to our patients is paid for by third parties (e.. OHIP, private insurance, Assisted Devices Program. These thirdparty payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate patient entitlement to this funding.
Optometrists are regulated by the College of Optometrists 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. Also, our organization believes that 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 patients, or other individuals, to support their concern (e.., improper services). Also, like all organizations, various government agencies (e.., 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.., lawyers, accountants) who will investigate the matter and report back to us.
To advise patients of their next annual oculovisual assessment by way of our newsletter.
Patients or other individuals we deal with may have questions about our goods or 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 after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our patient records).
Our office uses a security camera to safeguard our staff and patients, the premises and its records. The images are stored for a period of 24 hours before being destroyed. The information is not for any other purpose.
If the practice of Dr. Schmitz Dr. Sujo, Associates in Optometry, were to be sold, the purchaser would want to conduct a due diligence” review of the practices 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 reputable purchasers who have already agreed to buy the organizations business or its assets would be provided accless to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
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 restricted area. Electronic hardware is either under supervision or secured in a restricted area.
In addition, passwords are used on computers.
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 dccountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
We keep our patient files for ten years. Our client and contract directories are much more difficult to systematically destroy, so we 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 (i.., with people who are not clients) newsletters, seminars and marketing activities for about six 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 the entire patient file to our patient.
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.., 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 there is a problem we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 business days if at all possible and tell you the redson, as best we con, 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, Maureen McConkey, can be reached at 905.666.4848, extension 114, to address any questions or concerns you might have.
If you wish to make a formal complaint about our privacy proctices, 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 decision and reasons in writing.
For more general inquires, 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 StreetOttawa, Ontario
Phone (613) 995.8210/TollFree 1.800.282.1376/Fax (613) 947.6850/TTY (613) 992.9190