The Vault Wellness Center Privacy Policy

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PIPEDA- Personal Information Protection and Electronic Documents Act
PIPEDA requires private sector organizations across Canada to obtain consent when they collect, use or disclose personal information in the course of commercial activity.

Personal information can only used for the purposes for which it was collected. If an organization is going to use it for another purpose, they must obtain consent again.

Personal information must be protected by appropriate safeguards.
What is personal information?
Personal information includes any factual or subjective information recorded or not, about an identifiable individual. This includes information in any form such as:

• An individual’s characteristics (e.g. age, name, gender, home address, contact information);

• An individual’s personal health information ( conditions, medications, lifestyle, health services received);

• An individual’s opinions, comments, intentions, activities.

Personal information is different from business information (e.g. business address, telephone number). This is not protected by privacy legislation.
Written Statement of Policy
The Vault Wellness Center holds the privacy of personal information with high regard.
Who We Are
We are a small clinic located in Tara, Ontario that offers Registered Massage Therapy to the communities of grey-bruce and surrounding area.
We Collect Personal Health Information: Primary Purposes
Like all medical professionals, we collect, use and disclose personal health information in order to serve our clients. The primary purpose for collecting personal health information is to provide safe and effective massage therapy treatment. For example; we collect information about a clients health history, medical conditions, including family history, physical conditions, function and social situation 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 purpose is to obtain a baseline of health and social information so that in providing ongoing health care services, we can identify changes that are occurring over time.
We Collect Personal Information: Related and Secondary Purposes
Like most organizations, we also collect, use and disclose personal information for purposes related to or secondary to our primary purposes. The most common examples are:

• To invoice for good or services or to collect unpaid accounts.

• To advise clients of appointments

• To advise clients of special events ( seminars, new services or products) that we have available

• Registered Massage Therapists are regulated by the College of Massage Therapists of Ontario. The CMTO may inspect our records and interview us as part of their regulatory activities acting in the public’s interests. As professionals, we report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. 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. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commissioner) have the authority to review our files and interview us as 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.

• With your written permission, information may be shared with an insurance company, lawyer or other health-care practitioner. As the information may be different, it will be addressed on a case-by-case basis.

• Clients or individuals we deal with may have questions about our goods or services after they have been received. We retain our client information for a mandatory minimum of 10 years after the last contact to enable us to respond to those questions and provide these services.
Booking Online
When you book an appointment online, we collect personal information necessary to provide you with the service you have requested.
Protecting Personal Information
We understand the importance of protecting personal information. The following steps have been taken:

• Paper information is either under supervision or secured in a locked area.

• Our computers/Ipads/Phones are password protected.

• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.

• External consultants and agencies, with access to your personal information, must enter into privacy agreements with us.

• Electronic information is transmitted either through a direct line or has identifiers removed or is encrypted.

• Staff is trained to collect, use and disclose personal information only as necessary to fulfill their duties with our clinic policies.

• We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when hardware is discarded, we ensure that the hard drive is physically destroyed.
You Can Look at Your Information
With only a few exceptions, you have the right to see what personal information we hold about you. We can help you identify what records we might have about you. We will also try to understand any information that 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 deserve 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 days if at all possible and tell you the reason, as best we can, 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 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 files a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information
Questions??
Our staff would be happy to answer any questions you may have about your personal information. If you would like more information about our policies, or would like to see exactly what personal information we have about you in our records, or wish to register a complaint, please contact:

Lynn Gunson/Owner
39 Yonge St, Tara ON N0H 2N0
Phone 519-934-1517 or 226-668-1974
Email: lynngunson@gmail.com

If you have a concern about the professionalism or competence of our therapists and the services offered or the mental or physical capacity of any of our regulated health professionals we would ask you to discuss those concerns with us personally. However, if we cannot satisfy your concerns , you are entitled to complain to our regulatory body:

College of Massage Therapists of Ontario
1867 Yonge St, Suite 810
Toronto, On M4S 1Y5
Canada
Phone: 416-489-2626
Toll- Free In Ontario: 1-800-465-1933
Fax: 416-489-2625

Email: cmto@cmto.com or professionalconduct@cmto.com

You can also contact the Privacy Commissioner of Canada for assistance between the hours of 8:30 a.m. to 4:30 pm EST, at

Privacy Commissioner of Canada for assistance
Toll-free: 1-800-282-1376
Phone: (819)994-5444
Fax: (819)994-5424
TTY: (819)994-6591

Or by mail at:
30 Victoria Street
Gatineau, Quebec
K1A 1H3

Or at this website:
http://www.priv.gc.ca

You can also contact our Provincial or Territorial Privacy Commissioner's office for more information:

Provincial or Territorial Privacy Commissioner's office
2 Bloor St East,
Suite 1400
Toronto, ON
M4W 1A8
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