Ross Rehabilitation is committed to the protection of the personal information of all its clients.
Ross Rehabilitation’s information practices adhere to the Personal Information Protection and Electronic Documents Act, 2004 (PIPEDA) and to the Personal Health Information Protection Act, 2004 (PHIPA).
Ross Rehabilitation’s information practices also comply with the COTO (College of Occupational Therapists of Ontario) Standards for Record Keeping (2016), COTO Standards for Consent (2017) and COTO Standards for Occupational Therapy Assessments (2013).
Ross Rehabilitation’s information practices are designed to protect personal information that we collect and to ensure that any use of this information is subject to consent. Ross Rehabilitation has designated a contact person (Maria Ross) who is accountable for compliance.
Before personal information is collected, Ross Rehabilitation will identify the purposes for which it is being collected. Primarily, personal health information is used to deliver client care, provide independent assessments for third party payers (e.g., legal representatives, insurers, WSIB), for administration, teaching, statistical and research purposes. Information will not be used or disclosed for purposes other than those for which it was collected, except with the client’s consent.
The client’s knowledge and consent will be obtained for collection, use and disclosure of personal information. Implied consent may be relied upon for provision of client care. The client’s express consent (verbal or written) will be obtained to disclose personal health information to a non-custodian (e.g., legal representative, insurer) or to another custodian for non-treatment purposes (e.g., research, marketing). Exceptions include using personal information for health care planning and delivery, risk management and education. Substituted consent may be obtained where the client is not capable of understanding the information issue or appreciating its reasonably foreseeable consequences. Clients may withdraw their consent at any time, subject to legal or contractual restrictions and reasonable notice.
Ross Rehabilitation ensures that personal information is as accurate, complete and as up to date as possible. Clients can request access to their record and request corrections of factual errors in their record as appropriate. There may be exceptions to granting a client’s request to access their record (e.g., if providing the information presents a risk of serious harm to the treatment or recovery of the client or of serious bodily harm to another person, ifaccess would reveal the identity of a confidential source of information).
Ross Rehabilitation has adopted safeguards to ensure that personal information is protected from theft, loss, unauthorized use, disclosure, copying, modification or disposal. In the event of a privacy breach, RRVS will notify affected clients. Protection may include restricting access (e.g., locked cabinets or offices), limiting access to RRVS staff, use of passwords, encryption and audits, etc. Ross Rehabilitation staff and agents are required to sign a confidentiality agreement as a condition of employment.
Clients will be able to initiate complaints concerning compliance with this policy at Ross Rehabilitation. Clients may contact Maria Ross to initiate a complaint. Ross Rehabilitation will investigate all complaints. If a complaint is justified, Ross Rehabilitation will take appropriate measures, including, if necessary, amending their policies and practices.