PRIVACY POLICY

Privacy of personal information is an important principle to Sutherland-Chan School & Teaching Clinic. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also wish to be open and transparent as to how we handle personal information. This document describes our privacy policy.

WHAT IS PERSONAL INFORMATION?

Personal information is information about an identifiable individual. Personal information includes information that relates to an individual’s personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status) and the individual’s health (e.g. health history, health conditions, health services received). An individual’s business information (e.g. an individual’s business address and telephone number) is not personal information.

WHO WE ARE

Our organization, Sutherland-Chan School & Teaching Clinic, includes the management team, coordinators, support staff, faculty, and clinic receptionists. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information held by us. These include, without limitation, lawyers, computer consultants, bookkeepers and accountants, temporary workers to cover holidays, and credit card companies. We restrict their access to any personal information we hold as much as is reasonably possible and they are required to maintain confidentiality in accordance with this Privacy Policy.

WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES

About Student and Specialty Clinic Clients

Similar to other massage therapy schools, we collect, use and disclose personal information for the following primary purposes. The first primary purpose is to provide massage treatment. For example, we collect personal information about a client’s health history, including the client’s family history, physical status and conditions in order to help us assess what the client’s massage therapy needs are, to advise the client of the options, and then to provide the health care the client chooses to receive. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services, including advice and referrals, we can be equipped to identify changes that occur over time. Another primary purpose is to facilitate the education of our students. Please note that it would be very rare for us to collect such personal information without the client’s consent, but this might occur in an emergency (e.g. the client is unconscious). Occasionally, we collect personal information about you from other sources if we have obtained your consent to do so or if the law permits.

About Potential Members of Our Community

In the case of people who contact us for information (e.g. potential applicants, course registrants, information session attendees, etc.), our primary purposes for collecting personal information are to distribute notice of special events (e.g. clinic information or upcoming specialty clinics, information sessions, upcoming workshops, courses, or seminars) or to make them aware of massage therapy services in general or our clinic in particular. We will upon request immediately remove any personal information from our distribution list.

On our website we only collect the personal information you provide and only use that personal information for the purpose you gave it to us (e.g. to respond to your email message, to register you for a course, to process your application to the program, to forward to you information about special events) unless otherwise specified.

About Contract Staff, Volunteer and Co-op Students

In the case of people who are contracted to do work for us (e.g. temporary workers), our primary purpose for collecting personal information is to enable us to contact them in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending out pay cheques, 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, use or disclose such personal information without prior consent, but it might happen in the case of a health emergency (e.g. a public health concern) or to investigate a possible breach of law (e.g. if a theft were to occur in the school or clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about performance and prepare a report which will be disclosed only with the consent of the individual.

About Students Enrolled in the Diploma Program

We collect and use personal information about students during the course of their studies. This personal information includes addresses, phone numbers, health history, and other such personal information as is relevant directly or indirectly to the educational process.

This personal information is held in confidence in accordance with this Privacy Policy and is used only as dictated by the needs of the student’s studies at the school.

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.

Examples of our related and secondary purposes are as follows:

• To process credit card payments or to collect unpaid accounts.
• To advise clients and others of special events or opportunities (e.g. seminars, information sessions, prerequisite courses, new specialty clinics, development of a new service) that we have available.
• To review client and other files for the purpose of facilitating our provision of 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 conduct audits and continuing quality improvement reviews of our Clinic, including reviewing client files and interviewing our staff.
• To comply with regulatory requirements imposed by external organizations. In particular, Ontario massage therapy schools are regulated by the College of Massage Therapists of Ontario which may inspect our records and interview our staff as a part of its regulatory activities in the public interest. Also, our organization believes that it should report information suggesting 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. Also, like all organizations, we are subject to the ability of various government agencies (e.g. Canada Revenue Agency and the Information and Privacy Commissioner) to review our files and interview our staff as a part of their mandates. We may consult with professionals (e.g. lawyers, accountants) who may assist us regarding such matters.
• If the Sutherland-Chan School & Teaching Clinic or its assets were to be transferred, to facilitate such a transaction.
• To compile statistics and to conduct research (in compliance with privacy legislation).

PROTECTING PERSONAL INFORMATION

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

• Personal information recorded on paper is either under supervision or secured in a locked or restricted area.
• Electronic hardware is either physically secured in a locked or restricted area at all times and/or password protected.
• Personal information recorded on paper is transmitted externally through sealed, addressed envelopes or boxes and by reputable companies.
• Electronic personal information is transmitted either through a direct line or is anonymized or encrypted.
• Our staff is trained to collect, use and disclose personal information only as necessary to fulfill their respective duties and in accordance with this Privacy Policy.
• External consultants which need to access personal information held by us must enter into privacy agreements with us.

RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

We need to retain personal information for some time to enable us to answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, it is our policy and practice not to keep personal information for an unreasonably long period of time.

We retain our client files for ten years. Our client and contact directories are difficult to destroy systematically, so we remove personal information from those directories as and when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information immediately. We normally keep any personal information relating to our general correspondence (i.e. with people who are not clients), newsletters, seminars and marketing activities for approximately six months after the subject matter of the correspondence has been dealt with, 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, the hard drive is physically destroyed. Alternatively and where appropriate, we may send some or the entire client file to our client.

YOU CAN REQUEST ACCESS TO YOUR PERSONAL INFORMATION

You have the right to request access to personal information we hold about you. We will need to confirm your identity before providing you with this access. We reserve the right to charge a reasonable fee for such requests.

Access requests must be in writing. We will respond to your request in writing and, if we cannot give you access, we will tell you the reason. We may also need to review your file so that the personal information you are able to access pertains solely to you (e.g. a client file might contain information pertaining to a student therapist, etc.).

If you believe that the personal information we hold about you is incorrect, you have the right to ask for it to be corrected. We may ask you to provide to us documentation that our files are incorrect.

WITHHOLDING OR WITHDRAWING CONSENT

Subject to some legal exceptions, you may withhold or withdraw your consent regarding some of the above uses or disclosures by contacting our Information Officer.

DO YOU HAVE A QUESTION OR COMPLAINT?

Our Information Officer can be reached at:

Information Officer, 330 Dupont Street, Suite 400, Toronto, ON M5R 1V9

PHONE: (416) 924-1107 ext.16

and will attempt to answer any questions you might have.

This Policy has been prepared in the context of, and is subject to, Canada’s Personal Information Protection and Electronic Documents Act and Ontario’s Personal Health Information Protection Act, 2004, each of which are complex statutes which provide frameworks within which this Policy operates.

If you wish to make an access request or a formal complaint about our privacy practices, you may make it in writing to our Information Officer at the above address. Our Information Officer will acknowledge receipt of your complaint and send you a written response.

If you are not satisfied with our response regarding personal information, the Information and Privacy Commissioner of Canada can be reached at:

112 Kent Street

Ottawa, Ontario KIA 1H3

Phone: (613) 995-8210 Toll-Free: 1-800-282-1376 FAX: (613) 947-6850 TDD/TTY: (613) 992-9190

www.privcom.gc.ca

If you are not satisfied with our response regarding personal health information, the Office of the Information and Privacy Commissioner of Ontario can be reached at:

2 Bloor Street East, Suite 1400

Toronto, Ontario M4W 1A8

Phone: (416) 326-3333 Toll-Free: 1-800-387-0073 FAX: (416) 325-9195 TDD/TTY: (416) 325-7539 www.ipc.on.ca

CHANGES TO THIS PRIVACY POLICY

Sutherland-Chan School & Teaching Clinic reviews all of its policies and procedures and we may change this Privacy Policy from time to time.