Your Privacy at ASP

Understand your privacy across the Alzheimer Society Peel.

An older couple sitting with a counsellor.

Your Privacy

Contents:

  1. Our Privacy Notice
  • Protecting your privacy
  • Implied Consent
  • Express Consent
  • People who can make decisions for you
  • Accessing your Records
  • Correcting your Records
  • Client Recording
  • Privacy Inquiries
  1. A Guide to the Collection, Use and Sharing of Your Personal Health Information.
    • Our Practices
    • Your Choices
    • Limits of Confidentiality
    • Your Rights
    • Your Health Record
    • For more information or complaints

 

OUR PRIVACY NOTICE

The Alzheimer Society Peel respects the privacy and dignity of anyone utilizing its services, and does not divulge confidential information without consent, except when required by professional or legal obligations.

The Alzheimer Society Peel follows all applicable regulations as per the Personal Health Information Protection Act (PHIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA).

The Alzheimer Society Peel only grants access to information to individuals accessing their own electronic records and to third parties who supply proper documentation.

The Alzheimer Society Peel may release its electronic records to a third party without documentation under extraordinary circumstances such as threats of suicide and/or harm to other individuals.

Except where required by law, the Alzheimer Society Peel only releases its electronic records in the form of a summary prepared by staff. An inspection of actual electronic records may occur in the presence of staff. The Alzheimer Society Peel shall not release actual records or their copies to anyone unless required by law.

A record holder is a person whose information forms the primary source for the electronic record. Record holders include all clients who use Adult Day Services, Nora’s House, the Bathing program, counselling services, participants in the education programs, and volunteers.

For more information on your privacy  and ASP please  review our privacy notice brochure (pdf).

 

PROTECTING YOUR PRIVACY

  • All staff members and volunteers sign a pledge of confidentiality upon starting employment.
  • Staff members do not discuss an individual unless such discussion forms part of the planning of service for the individual. Information about an individual should be discussed only among those staff members who are taking part in providing service to that individual.
  • Confidential records for individuals are placed under lock and key or safeguarded electronically.
  • The Alzheimer Society Peel does not release any information to any third-party individual or organization unless the following procedures have been followed and documentation provided or under extraordinary circumstances.
  • Staff members and volunteers do not communicate to any third-party individual or organization outside the Alzheimer Society Peel any identifying information about individuals associated with the Alzheimer Society Peel, except where consent has been obtained explicitly for this purpose.

 

IMPLIED CONSENT TO USE AND GIVE OUT YOUR INFORMATION IN ORDER TO PROVIDE YOU WITH HEALTH CARE 

  • When you seek health care from us, we assume that we have your permission to collect, use and share your personal health information among your health care providers who provide or assist in providing health care to you. We may also give your personal health information to your other health care providers outside of this office so they can provide you with ongoing health care and follow-up. 
  • Health care providers who do not provide or assist you with health care are generally not allowed to see your health information. 
  • You should let us know if you do not want us to use, share or give out some or all of your personal health information to people who provide you with health care.

 

EXPRESS CONSENT TO GIVE OUT YOUR INFORMATION TO OTHER PEOPLE 

  • Sometimes we are not allowed to assume we have your permission to give personal health information about you to others. For example, except where the law allows otherwise, we must ask your permission to give your personal health information to: 

(a) people who do not provide you with health care, like your insurance company or your employer; or 

(b) to a health care professional for reasons other than providing you with health care. 

  • People outside the health system who receive your personal health information can only use it or give it out for the reasons that they received it or as allowed or required by law. 
  • You may have other family or friends to whom you would like us to give more detailed information about your health, like how your treatment is working or what kind of care you will need at home. You can let us know if we can discuss your health with family and friends. Let us know if you would like us to give more detailed information about your health to someone.


 

PEOPLE WHO CAN MAKE DECISIONS FOR YOU 

  • We will presume that you are able to make your own decisions about your personal health information. If we determine that you cannot, another person, usually a family member, will be asked to make decisions for you. The law tells us who to turn to first on a list of “substitute decision-makers”. For example, if you have a substitute decision-maker for treatment, that person will make decisions about your health information that is related to that treatment. Since a substitute decision-maker needs information about a person’s health to make these kinds of decisions, our office can give them that kind of information. Your substitute decision-maker can also ask us to see your records and our staff will give him or her information about your health. 
  • We will ask for your consent, or your substitute decision-maker’s consent, before giving your personal health information to your other family members. You may also decide in advance who should act as your substitute decision-maker when you are no longer capable to make these decisions.

 

ACCESSING YOUR RECORDS

  • You have a right to see your personal health information and to get a copy of it by asking us for it, or by writing to us. Some exceptions may apply. For example, when the information relates to law enforcement, legal proceedings or another individual, you may not get to see the record. 
  • We must respond to your request as soon as possible and within 30 days. There may be a delay if we have to ask others about the records or it will take time to find the record. You have the right to be notified of such delays. If you require the record urgently, we must consider responding as soon as possible

 

CORRECTING YOUR RECORDS

  • Once you have seen your record of personal health information, if you believe it is inaccurate or incomplete, you may write to us and ask for a correction. 
  • We must reply to your request within 30 days, or later if it is reasonable to do so. You are entitled to be told how long it will take to get back to you if it is longer than 30 days. 
  • We may not correct a record that was created by someone else and we do not know enough about the record to change it or where, for example, the opinions or observations in the record were made in good faith. You are entitled to be told the reasons for not making a correction and of your right to have a statement of disagreement attached to your records. You can also ask to have this statement made available to those who see the record. 
  • Where we correct a record, it must be done carefully so that the full corrected record remains visible or by ensuring that the corrected version is readily available.

 

CLIENT RECORDING

ASP has established strict guidelines for photo, audio and video recording by clients and visitors in order to protect the safety and privacy of clients, visitors and other stakeholders, the confidentiality of client information, and to safeguard ASP’s reputation. Consistent with the guidelines of this policy, ASP generally permits photo, audio or video recording by clients and visitors which has the express consent of all persons who may be recorded and is not otherwise prohibited by the policy.

ASP strictly prohibits: 

  • Any form of covert recording by a client or visitor is expressly prohibited. 
  • Any form of surveillance by a client or visitor is prohibited without prior approval by ASP Leadership.

ASP strictly prohibits photo, audio, or video recording by clients and visitors in the following areas and/ or during the listed programs or services, whether in person, or virtual:

  • Day to Day operations of our Adult Day Services, at all sites and daily activities.
  • All Support Groups
  • All Public Education Sessions
  • During general tours, arriving, departing, or entering any sites and offices
  • Any location, setting, program or service at the discretion of CEO/ designate

Any exceptions shall require the approval and authorization of the CEO, Privacy Officer, and/or designate.

The following procedure applies for clients requesting to record:

  • Recording by a client or visitor is only permitted after the client or visitor obtains the express consent of all persons who may be reasonably expected to be recorded, including any ASP personnel, other clients, or visitors.
  • No recording shall be made where a person who may be reasonably expected to be recorded cannot provide consent or refuses to provide consent.
  • A person who is requested to provide consent for a client or visitor recording may decline to provide consent without providing a reason for declining. Where practicable, a person declining consent for recording may elect to remove themselves from being recorded at their discretion in order for the recording to otherwise proceed. 
  • ASP personnel who may be requested to provide consent for recording by a client or visitor may decline to provide consent in circumstances where, at ASP’s sole discretion, the recording is deemed to conflict with their professional responsibilities, or the safe delivery of care to a client.
  • Any authorized recording of an ASP client that reasonably renders the client personally identifiable as a client of ASP is considered personal health information under the Personal Health Information Protection Act, 2004. Clients or visitors who record an ASP client are solely responsible for their custody and control of the resulting recording.
  • A person who is suspected of having recorded without authorization may be asked by ASP to produce a copy of the recording for ASP’s review. At ASP’s sole discretion, ASP may request that the person securely and irrevocably erase or otherwise destroy any recording already obtained by that person regardless of where or how the recording may have been obtained or retained.
  •  A person who is found to be or have been recording in breach of this policy will be informed of the policy prohibiting unauthorized recording and will be asked to cease the recording activity immediately.

You may request to review the full policy by contacting our Privacy Officer.

 

PRIVACY INQUIRES

Any person may ask questions or challenge our compliance with this policy or with PHIPA by contacting our Privacy Officer:

 

The Privacy Officer

Alzheimer Society Peel

385 Brunel Road

Mississauga, ON

L4Z 1Z5

 

Alzheimer Society Peel will receive and respond to complaints or inquiries about its policies and practices related to the handling of personal health information. Clients who make inquiries or lodge complaints will be informed of other available complaint procedures via the Alzheimer Society Peel Complaints Policy.

Alzheimer Society Peel will investigate all complaints. If a complaint is found to be justified, appropriate measures will be taken to reach a resolution.

The Information and Privacy Commissioner of Ontario oversees compliance with privacy rules and PHIPA. Any individual can make an inquiry or complaint directly to the Information and Privacy Commissioner of Ontario by writing or calling:

 

2 Bloor St East, Suite 1400

Toronto Ontario M4W 1A8

Phone: 1 (800) 387-0073 or (416) 326-3333

Fax: (416) 325-9195

Email: www.ipc.on.ca

 

 

A Guide to the Collection, Use and Sharing of Your Personal Health Information.

 

OUR PRACTICES

We collect your personal health information directly from you, or from your substitute

decision maker. Occasionally we collect information about you from other sources, if you have given us permission to do so or if the law permits, for example, from other

health care providers involved in your care. 

 

We collect, use, and share your personal health information to:

• Provide health support and services based on your needs

• Deliver our programs

• Communicate with other healthcare  professionals involved in your care

• Seek your consent (or consent of a substitute decision maker) where needed

• Plan, administer and manage our internal operations

• Perform risk management, error management and quality improvement activities

• Gather statistics

• Complete research

• Carry out client surveys

• Follow legal and regulatory requirements

• Fulfill other purposes permitted or required by law

 

Our collection, use and disclosure (sharing) of your personal health information is done following the Personal Health Information Protection Act, 2004 (PHIPA).

 

 


 

YOUR CHOICES

You have a right to make choices and control how your health information at the Alzheimer Society is collected, used, and disclosed, with

some exceptions. 

 

For most health care purposes, your consent to use your health information is implied as a result of your consent to using our programs and services, unless you tell us otherwise. From time to time, we may communicate about your care with your other health care providers, including collecting, using and sharing your personal health information through electronic medical information systems (sometimes called electronic health records, eHealth records, electronic medical records, etc.), unless you tell us you do not want us to do so.

 

In some cases, we must have your permission to give your health information to people

who do not provide you with health care. We may also need consent to communicate with any family members or friends with whom you would like us to share information about your health (unless one or more of these individuals is your substitute decision-maker).

 

When we require and ask for your consent, you may choose to say no. If you say yes,

you may change your mind at any time. Once you say no, we will no longer share your

information unless you say so, unless the law permits or requires us to do so.

 

 

 

LIMITS OF CONFIDENTIALITY

There are times when we are required to share your personal health information

without your consent. For example, to use your information for billing (when applicable), risk management or error management, quality improvement purposes, or if you are at risk of harm to yourself or others. Your health care providers are also required by law to respond to a subpoena and/or search warrant.

 

 



 

YOUR RIGHTS

With limited exceptions, you have the right to access the health information we hold about you.

You have a right to ask for a correction to your record if you believe the information is

inaccurate or incomplete.

 

YOUR HEALTH RECORD

Your health record includes important information about your health including your

date of birth, health card number, contact information, health history, details of your

physical and mental health, record of your visits, the care and support you received

during those visits and information from other health care providers.

 

FOR MORE INFORMATION OR COMPLAINTS

 

If you would like to access your record, request a correction or know more about our

privacy practices, please contact our Privacy

Officer: Shelly Melnyk, s.melnyk@alzheimerpeel.com or 905 278-3667 x 357

 

If, after contacting us, you feel that your concerns have not been answered to your satisfaction, you have the right to complain to the Information and Privacy Commissioner of Ontario.  The Commissioner can be reached at: 

Information and Privacy Commissioner of Ontario 

2 Bloor Street East, Suite 1400 

Toronto, Ontario M4W 1A8 

Tel: 1-800-387-0073 | Fax: 416-325-9195 www.ipc.on.ca