Privacy

We will protect the privacy of all the information you give us.

The information you or your child gives us about your child and your family is important to our work at the Boomerang Health. It is important to the assessment and treatment of your child, so that we can provide him or her with the best care possible.

We promise to make sure that all of your child’s personal health information is kept private. This page explains why we collect information about you, your child and your family, and how we use it. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We strive to be open and transparent regarding how we handle personal information. This document describes our privacy policies.

What is personal health information?

Personal health information is information about an identifiable individual. Personal health information includes information that relates to: an individual’s personal characteristics (e.g., name, age, gender, address), health (e.g., developmental and medical history, assessment and treatment history); or, activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). This information may include records of your child’s visits to Boomerang Health and the care that he or she received during those visits.

We collect personal health information about a client from the client, his/her parents and/or from the person responsible for making decisions for the client.

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How We Collect, Use and Disclose Personal Health Information: Boomerang Health’s Privacy Policy

We collect, use and disclose personal health information so that we can care for you or your child. We also collect information for our records, as the law requires us to. Boomerang Health’s obligations in regards to personal health information are outlined in Ontario’s health information privacy legislation, the Personal Health Information Protection Act, 2004 (PHIPA). In the course of carrying out client care and administrative functions, Boomerang Health collects, retains, uses, discloses, and ultimately disposes of confidential personal information and personal health information relating to its clients and its staff, within its custody and control.

Primary Purposes:

A. Collecting, Using and Disclosing Information About Clients

We collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide assessment and treatment services. For example, we collect information about a client’s developmental history, including their family history, medical history, and current functioning in order to help us assess what their language, motor, social, emotional, behavioural or physical needs are, to advise them of their options and then to provide the care they choose to have. A second primary purpose is to obtain a baseline of developmental/health information so that in providing ongoing services we can identify changes that occur over time. It would be rare for us to collect such information without express consent from the client or from the caregiver who is legally responsible for a client, but this might occur in an emergency (e.g., the client is unconscious) or where we 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 we have no reason to believe that the message is not genuine).

Each time a client visits Boomerang Health, we collect information about the client. For example, we collect the results of any assessments and document the progress of treatment. Within Boomerang, we give the client’s information to only those people who need it for their work. We work as a multidisciplinary team; we may consult with allied health practitioners on the team in the event that we feel such consultation would be valuable for your child’s care. We also give your information only to those who have a right to it by law. Sometimes we collect, use and disclose personal health information about a client from other sources (for example, schools, a referring doctor) if we have the client’s and/or legal caregiver’s consent or if the law permits.

These are the people who may see your /your child’s information:

• The client;
• The parent(s)of a child client/ the person responsible for making decisions for a child client
• Professionals/practitioners with whom your child works;
• Professionals/practitioners both inside and outside of Boomerang Health, with your consent;
• Students, interns, and others training at Boomerang Health;
• Other people, if the child and/or parents agree, or when the law requires or permits it. See limits of confidentiality for further information about when the law requires sharing of personal health information without expressed consent.

Limits of Privacy: Confidentiality

There are four situations when health care practitioners are obligated, either legally or ethically to share information:

• When there is concern a child is being harmed or is at risk of being harmed. This may include actual or suspected physical, emotional, or sexual abuse, neglect, or a pattern of failure to follow through on necessary treatment. The health care practitioner is required to contact the Children’s Aid Society (CAS).
• When Boomerang Health staff and/or documentation are “subject to subpoena” by the court (that is, when they are requested by a judge for a legal proceeding in family or criminal court).
• If someone presents an imminent danger to him or herself, or to others (e.g., if a child or parent is considered suicidal or homicidal).
• If it is reported that a member of another regulated health profession has been sexually inappropriate with a member of your family. In this case, a report will be made to the professional’s college. The client’s name will not be reported without expressed consent.

B. Collecting, Using and Disclosing Information About Members of the General Public

For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might 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. We do not disclose information about members of the general public to third parties.

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.g., to respond to your email message, to register for a course, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.

C. Collecting, Using and Disclosing Information About Contract Staff, Volunteers and Students

For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts). 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 a health emergency, or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect, use and disclose information about their work related performance and provide a report as authorized by them.

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 clients for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
• To advise clients that their product or service should be reviewed (e.g., to ensure a product is still functioning properly and appropriate for their then current needs and to consider modifications or replacement).
• To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new product) that we have available.
• Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our Clinic, including reviewing client files and interviewing our staff.
• Occupational Therapists, Physiotherapists, Psychologists, Speech and Language Pathologists are regulated by the College of Occupational Therapists of Ontario (COTO), College of Physiotherapists of Ontario (CPO), College of Psychologists of Ontario (CPO), and College of Audiologists, Speech and Language Pathologists of Ontario (CASLPO), respectively, who may inspect our records and interview respective staff as a 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. 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., 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 our files and interview our staff as a 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.
• The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., OHIP, private insurance, charities). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
• Clients 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 child turns 18 OR 10 years after the last contact (for those 18 and older) to enable us to respond to those questions and provide these services (our 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 declining to receive notice of special events or opportunities). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

How we protect your information

We protect your information in these ways:

• We ask your permission before we collect, use, or show your/your child’s or your family’s information to anyone for any purpose other than our main activities, such as providing care.
• Client personal health information is entered into an electronic medical record (EMR). Boomerang Health has taken reasonable steps ensure these records are secure and protected from theft, loss and unauthorized use or disclosure, including copying, modification or disposal.
• We make sure that your information stays private. Only the people who need to see your child’s personal records are allowed to look at them. Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• We take steps to make sure no one steals or loses your information. We also work to make sure no one copies, changes, uses, shares or discards your information unless it’s allowed.
• Paper information is either under supervision or secured in a locked or restricted area.
• Electronic information is hosted on a secure server and is protected from unauthorized access, loss, theft or disclosure. See “EMR Safeguards” below.
• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers and telephone voicemail boxes.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either through a direct line or has identifiers removed or is encrypted.
• We take steps to make sure that everyone who performs services for us protects your privacy and only uses your personal health information for the purposes you have agreed to. External consultants and agencies with access to personal information must enter into privacy agreements with us.
• We keep your information correct and up-to-date. You can see the information we collect about you or your family. See “Seeing and correcting your personal health information” below.
• We keep your information only for as long as it is needed or required by law. See “Retention and Destruction of Personal Health Information” below.
• We will look into any concerns you may have about how we keep your information private. We have someone in charge of looking after the privacy of information. That person can give you more information about how Boomerang Health protects a client’s privacy.

EMR Safeguards

• Only authorized staff uses the EMR. No unauthorized person is able to access identifiable health information.
• Each authorized user is assigned a unique identity in the EMR.
• The information each authorized user can access is based on their role (e.g., a receptionist may have access only to patient identification and appointment information).
• The EMR is protected by password controls or data encryption.
• Any electronic signatures can be authenticated.
• Identifiable health information is always transmitted securely.
• Data is regularly backed up and the backed-up data is stored securely.
• Data is recoverable if the system goes down, and data recovery protocols are regularly tested.
• Patient records within the EMR are accessible and readable for at least 10 years after the last time the patient has been seen (or 10 years after a minor client turns 18), even if the technology changes.
• A process is in place to ensure the continuity of my practice if the EMR is inaccessible.
• Before any hardware containing EMR data is disposed of, all identifiable health information is scrambled or removed and can never be reconstructed.

Retention and Destruction of 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 accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.

We keep our client files (for those 18 and over) for ten years. For younger clients, we retain our files for 10 years after the client turns 18. We keep any personal information relating to our general correspondence (i.e., 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.

Seeing and correcting your personal health information

With only a few exceptions, a client and/or the caregiver legally responsible for a child client has the right to see what personal information we hold about the client. Often all you have to do is ask. We will also try to help you understand any information 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 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 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If a client believes that there is a mistake in the information, he or she/the caregiver legally responsible for a child client has 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. If you want to correct any of your own information, you can contact the our Privacy Officer by phone at 905-553-3155 by e-mail at info@boomeranghealth.com or by mail at:

Lara Pietrolungo
Privacy Officer, Boomerang Health
9401 Jane Street, Suite 211
Vaughan, Ontario L6A 4H7

You have the right to complain to the Information and Privacy Commissioner/Ontario if you think we have violated your rights.

The Commissioner can be reached by phone at 416-326-3948, by fax at 416-325-9195, by e-mail at commissioner@ipc.on.ca, through www.ipc.on.ca or by mail at:

Information and Privacy Commissioner/Ontario,
2 Bloor Street East,
Suite 1400,
Toronto, Ontario M4W 1A8

If you do not want us to use your information for certain purposes, such as contacting you about your satisfaction with services, please contact us. Give us your name/child’s full name and date of birth, and a home phone number so we can call you in case we need to check the information.

How to contact us

Our privacy contact person is Lara Pietrolungo. If you need more information or have a concern about privacy, please call Boomerang Health’s Privacy Officer at 905-553-3155 or email her at info@boomeranghealth.com.

You may also send a fax to 905-553-8120 or write to:

Lara Pietrolungo
Privacy Officer, Boomerang Health
9401 Jane Street, Suite 211
Vaughan, Ontario L6A 4H7