Public Written Statement
This document explains how we, the clinicians and staff at everwell Integrated Health Professionals, protect your personal health information. This pertains to any identifying information about you, including your mental and physical health. Everyone at everwell Integrated Health Professionals is committed to maintaining client privacy and confidentiality to the best of their abilities. Each member of the team adheres to everwell confidentiality and information safeguarding policies which meet the requirements of the Personal Health Information Protection Act (PHIPA) in Ontario. PHIPA outlines rules for how we can collect, use, modify, disclose and dispose of your personal health information.
Contact Person
If you have any questions about our privacy and confidentiality practices please contact Arijana Palme, administrator at everwell Integrated Health Professionals, ph. 905-527-6337, arijana@everwellcounselling.ca .
Personal Health Information
What personal health information do we collect?
We collect the following personal health information;
Identification and contact information (name, email address, phone number, address, date of birth, emergency contact information, etc.)
Billing information (private insurance if applicable, optional credit card information, etc.)
Health information (relevant mental and physical health history, symptoms, diagnosis, goals etc.)
Why do we collect this?
We collect your personal health information to identify you, to ensure that we are delivering the best services possible to you and to communicate with you. We only collect information that is required to fulfill those purposes. We do not collect any other information, or allow information to be used for other purposes, without your consent, except where required to do so by law.
Consent
We only collect, use, modify, disclose and dispose of your personal health information with your consent. We obtain your consent in the first appointment by providing you with a form that outlines what personal health information we collect, how we use it and to whom we disclose it. Your therapist will go over this form with you, answer any questions and then have you sign it once you feel fully informed of, and satisfied with, the details.
If we need to collect, use, modify, disclose and dispose of your personal health information in a way other than what is originally described, we will seek your consent unless we are required by law to do otherwise.
When and to whom do we disclose personal health information?
Any personal health information that is collected by a clinician or staff of everwell Integrated Health Professionals is kept within their strict access as per our Access to Information and Safeguards Policy. All staff and clinicians have access to your identifying information only, and only your specific clinician has access to your chart notes and detailed personal health information. Clinicians never use identifying information when consulting with the other clinicians on the team. The administrative staff at everwell have greater access to personal health information but the process for accessing and logging their activity in client files is governed by the laws of PHIPA, and is further explained in our Access to Information and Safeguards Policy which can be found here.
Disclosure to other health care providers:
In the rare instance when an external referral is required, the disclosure of your personal health information will include a discussion with your everwell clinician ahead of time. This ensures you remain informed of what information is being disclosed and allows you to make informed decisions about your care. We also disclose your personal health information to your private insurance company for billing purposes.
Disclosures authorized by law:
There are limited situations where we are legally required to disclose your personal health information without your consent. These situations include (but are not limited to) situations where the clinician has a duty to report abuse or neglect of children, elder adults and/or adults with developmental disabilities; if you pose a threat to your own life or someone else’s; if there is a medical emergency; if the clinician is ordered by a court of law; or if you disclose that another registered healthcare worker has sexually abused you or someone else.
Disclosures to all other parties:
We will obtain your consent before disclosing your personal health information to third parties for any purpose not specified in the notice unless we are authorized to do so by law. We will obtain your express consent if we collect, use or disclose your personal health information for any fundraising activities, research or marketing, or if the disclosure is to public media.
Withdrawal of consent:
At any time, you can withdraw your consent for the collection, use or disclosure of your personal health information for any purpose, except where the collection, use or disclosure is required by law or by established standards of professional practice. To withdraw your consent, you must do so in writing and provide the written withdrawal to your everwell clinician. Prior to withdrawing consent, we encourage you to discuss the matter with your everwell clinician first so they can explain the possible consequences of withdrawing consent.
Client Rights
How can records be accessed?
You have the right to access any records containing your own personal health information in a timely manner. You may request a copy of your records. If you wish to view an original record, one of our staff must be present to maintain the integrity of the record. Please note that in some circumstances, there may be a fee for accessing your records.
Requests for access to your records can be made in writing and sent to Arijana Palme, contact person (see above). You do not have the right to access any other person’s personal health information unless you have their express consent to do so or if you have been designated as a substitute decision maker for the individual that the information is about.
Are there limitations on access?
In rare circumstances you may be denied access to your records, for example if providing access would create a significant risk to you or to another person.
What if the records are not accurate?
We make every effort to ensure that all of your information is recorded accurately. If an inaccuracy is identified, you can request that the information be corrected, and a note will be made to reflect this on your file. Please note that correction of your personal health information is limited to factual information and does not apply to a health care provider’s professional opinion or observation.
Everwell Safeguards
How do we secure your personal information?
Safeguards are in place to protect your personal health information. These safeguards include a combination of physical, technical and administrative security measures that are appropriate to the sensitivity of the information. These safeguards are aimed at protecting your personal health information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. If there is a breach of your personal health information that creates a risk of significant harm to you, you will be notified.
How do we communicate with you?
We protect personal health information regardless of the format. Specific procedures and safeguards are in place for ensuring that communications by phone and email remain secure. This includes authentication procedures and a secure file transfer platform.
How long do we keep your personal health information?
We retain your records for a minimum period of 10 years from the date of your final appointment, or as otherwise required by law and professional regulations.
How do we dispose of your personal health information when it is no longer required?
When the 10 years have lapsed, your personal health information is destroyed in an irreversible and secure manner.
Questions, Comments or Complaints?
If you have any questions, comments or would like to file a complaint regarding our office’s compliance with this statement of practice or with PHIPA, please first contact us directly to discuss your concerns.
You may also choose to make a complaint to the Information and Privacy Commissioner of Ontario.
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario
M4W 1A8
1-800-387-0073
www.ipc.on.ca/
info@ipc.on.ca
Please do not send personal health information to us or to the Information and Privacy Commissioner by email because it is not a secure form of communication.