I, Meggan Levson, Speech-Language Pathologist is committed to protecting the privacy of all personal information that is collected to enable me to provide quality speech and language care to you and your child. In order to achieve this, it is my policy to collect, use and disclose personal information responsibly, limit the information I collect to what I need and to make my policies available to you. This document describes my privacy policies.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to personal characteristics (e.g., gender, age, home address or phone number, ethnic background, family status), health (e.g., health history, health conditions, health services received) or activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
WHO I AM
Meggan Levson, Speech-Language Pathologist includes at the time of writing one speech-language pathologist. To assist me in providing services, I may use consultants that, in the course of their duties have limited access to personal information I hold, such as: book keepers and accountants, website managers, and lawyers. I restrict their access to any personal information I hold as much as is reasonably possible. I also have their assurance that they follow appropriate privacy principles.
PRIMARY PURPOSES FOR COLLECTING PERSONAL INFORMATION
My primary purpose for collecting personal information is to provide speech and language services. For example, I collect information about you and your child’s health history that will be relevant to communication disorders and assist me in offering effective intervention options. A second primary purpose is to obtain a baseline of your child’s communication skills to track changes over time. It would be rare for me to collect such information without your express consent, but this might occur in an emergency (e.g., the client is unconscious) or where I believe you would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from you and I have no reason to believe that the message is not genuine).
ABOUT CONTRACT STAFF, VOLUNTEERS AND STUDENTS:
For people who are contracted to do work for me (e.g., book keeper), my primary purpose for collecting personal contact information is to ensure I can get in touch with them for employment purposes to better serve my clients. It is rare for me to collect such information without prior consent, but this might happen in the case of a health emergency (e.g., an infectious disease outbreak) or to investigate a possible breach of law (e.g., a theft in the office). I also collect information in order to do performance appraisals, provide feedback to students’ instructors or write references if requested.
RELATED AND SECONDARY PURPOSES FOR COLLECTING PERSONAL INFORMATION
Meggan Levson, Speech-Language Pathologist also collects, uses and discloses information for purposes related to or secondary to my primary purposes. The most common examples are as follows:
- To secure payment for goods or services
- To advise clients of the need for follow-up services
- To advise clients and others of special events or opportunities (e.g., a seminar, new service)
- To allow me to meet my regulatory obligations. The College of Audiologists and Speech-Language Pathologists may inspect my records and interview my staff as part of their regulatory activities in the public interest. Various government agencies (e.g., Canada Customs and Revenue Agency, Privacy Commissioner, Human Rights Commission, etc.) have authority to review my files and interview my staff as part of their mandates. External regulators have their own strict privacy obligations. In these circumstances, I may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to me.
- To provide information to third party payers (e.g., private insurance, Assistive Devices Programs) when they pay for the goods and services you receive from me. I will obtain your consent to disclose your personal information in these instances except in instances where there is legislative authority to collect, use or disclose the information.
- To answer any questions you may have about the service you received once it is concluded. The College of Audiologists and Speech-Language Pathologists requires that I keep records for at least 10 years past your child’s 18th birthday.
If you choose not to be part of some of these related or secondary purposes, please let me know so that I may take the appropriate measures where possible.
SHARING PERSONAL INFORMATION
I will not share you or your child’s personal health information without the informed consent of your child’s legal guardian or your child if your child is capable to provide his/her own consent. Informed consent can be either verbal or written. Common situations where I may request to share personal information include:
- With other speech-language providers such as the Provincial Preschool Speech and Language Program (e.g., TykeTALK), school board Speech-Language Pathologists, CCAC Speech-Language Pathologists, private Speech-Language Pathologists
- Medical practitioners (e.g., pediatrician, family physician, CCAC)
- Students or volunteers who are gaining experience at my practice
- Private Health Insurance Carriers who request confirmation of services provided
- Invoicing 3rd party payees for services rendered (e.g., charitable organizations that have provided funding for therapy)
PROTECTING PERSONAL INFORMATION
I understand the importance of protecting personal information. For that reason, I have taken the following steps:
- Paper information is either under supervision or secured in a locked or restricted area
- Electronic hardware is either under supervision or secured in a locked or restricted area. My computer is password protected.
- Paper information is sealed and transmitted by reputable companies.
- Special care is taken to ensure privacy when transmitting electronic information. Where I am unsure of the security of the electronic transfer of information, identifying information is removed.
- External consultants must enter into privacy agreements with me.
Should a breach in privacy occur, I would notify the affected persons as soon as possible.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
The College of Audiologists and Speech-Language Pathologists of Ontario requires that I retain my client records for, in the case of a child, 10 years past the child’s 18th birthday. I destroy my files within three months of that time. These files include your contact information. Contact information for members of the public is kept for 3 years unless requested to do so earlier.
I destroy paper files containing personal information by shredding. I destroy electronic information by deleting it and, when the hardware is discarded, I 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 I hold about you or your child. Often all you have to do is ask. I will need to confirm your identify, if I do not know you, before providing you with this access. I reserve the right to charge a nominal fee for such requests.
If I cannot give you access, I will tell you within 30 days if at all possible and tell you the reason, as best I can, as to why I 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 my professional opinions. I may ask you to provide documentation that my files are wrong. Where I agree I made a mistake, I will make the correction and notify anyone to whom I sent this information. If I do not agree that I have made a mistake, I will still agree to include in my file a brief statement from you on the point and I will forward that statement to anyone else who received the earlier information.
DO YOU HAVE A QUESTION OR A CONCERN?
Please speak to myself, Meggan Levson, Speech-Language Pathologist at:
938 Colborne Street
I will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about my privacy practices, you may make it in writing to myself. I will acknowledge receipt of your complaint, ensure that it is investigated promptly, and that you are provided with a formal decision and reasons in writing.
If you have a concern about the professionalism or competence of my services, I ask that you discuss these concerns with me. However, if I cannot satisfy your concerns, you are entitled to complain to my regulatory body:
College of Audiologists and Speech-Language Pathologists of Ontario
160 Bloor Street East, Suite 1125
Telephone: (416) 975-5347 or 1-800-993-9459
Facsimile: (416) 975-8394
This policy is made under the federal Personal Information Protection and Electronic Documents Act and the Ontario Personal Health Information Protection Act. These are complex Acts and there are some additional exceptions to the privacy principles that are too detailed to set out here. Also, there are some rare exceptions to the commitments set out above.
The Information and Privacy Commissioner of Ontario is responsible for making sure that privacy law is followed in Ontario. For more information about your privacy rights, or if you are not able to resolve a problem directly with me and wish to make a complaint, contact:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
For more general inquiries, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Office of the Privacy Commissioner can be reached at:
112 Kent Street
Telephone: (613) 995-8210 or 1-800-282-1376
Facsimile: (613) 947-6850
TTY: (613) 992-9190