Nutrition Pathway, Cheryl Corry, RD
Privacy of personal information is an important principle to Nutrition Pathway. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services I provide. I also try to be open and transparent as to how I handle personal information. This document describes my privacy policies.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). 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 I AM
Nutrition Pathway is owned and operated by sole proprietor, Cheryl Corry, Registered Dietitian. I operate separately from Proactive Health, where I am located. I interact with a clinic management software company and merchant account provider that may, in the course of their duties, have limited access to personal information I hold. I restrict their access to any personal information I hold as much as reasonably possible. I also have their assurance that they follow appropriate privacy principles.
I COLLECT PERSONAL INFORMATION:PRIMARY PURPOSES
Like all Registered Dietitians, I collect, use and disclose personal information in order to serve my clients. For my clients or when I assess a client for someone else (i.e. referring physician), the primary purpose for collecting personal information about you is to provide you with dietetic services. I collect information about your health and diet history, your physical condition and function, and your social situation, in order to help me assess what your needs are, to advise you of your options and then to provide the health care you choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services I can identify changes that are occurring over time. It would be rare for me 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 I 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 I have no reason to believe that the message is not genuine).
I COLLECT PERSONAL INFORMATION:RELATED AND SECONDARY PURPOSES
Like most organizations, I also collect, use and disclose information for purposes related to my primary and secondary purposes, for example:
To obtain payment for services or goods provided to an individual.
To promote my services, new services, special events and opportunities (e.g., a seminar or conference) that I offer. I can only do this with express consent from my client prior to collecting or handling personal health information for this purpose.
Registered Dietitians are regulated by the College of Dietitians of Ontario who may inspect my records as part of their regulatory activities in the public interest. In addition, as a professional, I will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or my own. Also, I believe that I 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 a 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 my files as a part of their mandates. In these circumstances, I may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to me.
The cost of some services provided by the organization to clients is paid for by third parties (e.g., health insurance companies). These third-party payers often have your consent or legislative authority to direct me to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
Clients or other individuals I deal with may have questions about my services after they have been received. I also provide ongoing services for many of my clients over a period of months or years for which previous records are helpful. I retain my client information for a minimum of ten years after the last contact to enable me to respond to these questions and provide these services (my regulatory College also requires us to retain our client records).
You can choose not to be part of some of these related or secondary purposes (e.g., by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g. external regulation).
PROTECTING PERSONAL INFORMATION
I understand the importance of protecting personal information. For that reason, I have taken the following steps:
I use a web-based clinic management software program for booking, billing and charting that is password protected.
Electronic health records are stored on secure Canadian servers.
Web-based counselling is conducted using a HIPAA-compliant platform in a private office space.
Paper information may be scanned, attached to the client’s electronic health record and then shredded.
Paper information is transmitted through sealed, addressed envelopes via a reputable delivery service.
Electronic information i.e. faxes, are transmitted through an encrypted, secure online service.
Client intake forms are linked to a secure, online website.
External consultants and agencies with access to personal information must enter into privacy agreements with me.
E-mail is not a secure or confidential form of communication. Messages sent across the internet can be intercepted and/or read. For this reason, clients wishing to communicate via e-mail must sign a consent form which will be included in their medical record.
TELEPHONE AND/OR WEB-BASED COUNSELLING
Telephone and/or web-based counselling are not secure or confidential forms of communication. There is a risk for potential breach of confidentiality as communication via telephone or internet can be intercepted. For this reason, clients wishing to communicate by telephone or by web-supported platforms, must sign a consent form which will be included in their medical record.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
I need to retain personal information for some time to ensure that I can answer any questions you might have about the services provided and for my own accountability to
external regulatory bodies. However, I do not want to keep personal information too long in order to protect your privacy. I keep my client files for about ten years. I destroy paper files containing personal information by shredding. I destroy electronic information by deleting it.
YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information I hold about you. Often all you have to do is ask. I can help you identify what records I might have about you. I will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). I will need to confirm your identity, if I do not know you, before providing you with this access. I reserve the right to charge a nominal fee for such requests.
If there is a problem I may ask you to put your request in writing. If I cannot give you access, I will tell you within 30 days if at all possible and tell you the reason, as best I can, as to why I 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 I may have formed. I may ask you to provide documentation that my files are wrong. Where we agree that I made a mistake, I will make the correction and notify anyone to whom we sent this information. If we do not agree that I have made a mistake, I will still agree to include in your 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?
Cheryl Corry can be reached at:
323 Kerr St., Suite 209, Oakville, Ontario, L6K 3B6
I will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about my privacy practices, you may make it in writing to Cheryl Corry. 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.
If you have a concern about the professionalism or competence of my services or my mental or physical capacity, I would ask you to discuss those concerns with me.
However, if I cannot satisfy your concerns, you are entitled to complain to my regulatory body:
College of Dietitians of Ontario
5775 Yonge Street, Suite 1810, Box 30
Toronto, Ontario, M2M 4J1
This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA). That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
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 privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street, Ottawa ON, K1A 1H3