The Summit Centre for Preschool Children with Autism
Privacy Policy
Sept. 20, 2007
Privacy of personal information is an important principle to Summit Centre. 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. Our practices related to how we handle personal information are governed, in addition to our concern for your privacy, by two pieces of legislation – the federal Personal Information Protection and Electronic Documents Act (PIPEDA), and provincially by the Personal Health Information Protection Act (PHIPA), 2004. This document describes our privacy policies.
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); health (e.g., health history, health conditions, health services received by them); or, activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is different from business information (e.g., an individual’s business address and telephone number). This is not protected by privacy legislation.
Who We Are
Our organization, Summit Centre, includes at the time of this writing a Board of Directors, a Clinical Director, an Executive Director, Senior Therapists, a Program Secretary, and Behaviour Therapists. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include maintenance staff, bookkeeping staff, psychological consultants, speech language pathologists, and computer consultants. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy and confidentiality principles.
We Collect Personal Information: Primary Purposes
About clients
Our “clients” are both the children we serve and their families or legal guardians. As all of the enrolled children in our centre are under 6 years of age, a substitute decision-maker, such as the custodial parent or legal guardian may give or refuse consent.
Like all intensive behavioural treatment centres, 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 intensive behavioural services. Examples of the type of personal information we collect for those purposes include the following: health history, health conditions, assessment results, diagnoses, information collected in the course of providing treatment, data collected during assessment and treatment, communication history with the centre, opinions expressed by the client, letters written to the centre by clients, and views, evaluations, or opinions by the centre about the client.
About Members of the General Public
For members of the general public, our primary purpose for collecting personal information is to put prospective clients on our contact list and to notify them of events at the centre. Examples of the type of personal information we collect for those purposes include the following: name, contact information, gender and age of child. We ask for verbal consent to collect this information when someone calls in, this consent can be altered by calling and requesting that we remove any personal information from our contact list.
About Contract Staff, Volunteers, and Students
For people who are contracted to do work for us (e.g., temporary workers) our primary purposes for collecting personal information is to contact them for necessary work-related communication and for the safety of our clients. Examples of the type of personal information we collect for those purposes include the following: name, home contact information, and police clearance. If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.
We Collect Personal Information: 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:
θTo invoice clients for services, additional information that is collected for this purpose are the notices of assessment for parents
θTo advise clients and others of special events and opportunities that we have available. We collect home contact information for this purpose.
θThe cost of some services provided by the Summit Centre to clients is paid for by third parties (e.g., Autism Program- South West Region, Thames Valley Children’s Centre). These third party payers often have your consent to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding. Examples of information shared with Autism Program, TVCC are: children’s Summit Centre programs are evaluated at regular review meetings, and their monthly hours are reported to Autism Program, TVCC.
θOur organization, or its professional staff, is regulated by the College of Psychologists of Ontario (COPO) who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we are obligated to report any incident of concern about a child’s physical or emotional well being (e.g. to the Children’s Aid Society or other appropriate legal authorities e.g. local or provincial police). Also, like all organizations, various government agencies (e.g. 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) who will investigate the matter and report back to us regarding our reporting rights and obligations.
θClients or other individuals we deal with may have questions about our services after they have been received. We also provide periodic consultations for many of our clients over a period of months or years for which previous records are helpful. We retain our client information for at least ten years following the date at which a client turns 18, to enable us to respond to those questions. We destroy our information ten years after the individual turns 18, at the first opportunity in order to reduce the risk of accidental or inadvertent disclosure (our regulatory College requires us to retain our clients’ records for that period of time).
You can choose not to be part of some of these related or secondary purposes (e.g., by declining additional services or by paying a full user fee). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation) regardless of your choice.
Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following measures:
θPaper information is either under supervision or secured in a locked or restricted area.
θWhen parents ask us to disclose information about their enrolled child to a third party such as a school or doctor, written consent will always be the first method used instead of implied consent.
θIf there is a disclosure of personal health information outside The Summit Centre without consent, we will inform you of the uses and disclosure that were done. We will make a note of the uses and disclosure and will keep a note with those files/records.
θPaper information is marked private and confidential and transmitted through sealed, addressed envelopes (or boxes) by reputable companies, or hand delivered by staff, or in a sealed envelope to be picked up by the person who asks for it.
θElectronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital as these signals are more difficult to intercept.
θElectronic information is transmitted either through a direct line or has identifiers removed. This transfer may be through email communication if we are given a request and consent of the person to whom the personal information relates (e.g., the client requests email communication). Faxes are sent with a cover sheet identifying the recipient with a privacy clause on it and at least one of the following safeguards: the fax number has been approved by the recipient, the recipient has advised that the fax machine is securely located and there is no basis to doubt the assurance, the incoming fax machine is securely located.
θStaff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy. Specific direction is given about the need to be sensitive in collecting or using personal information verbally where others might overhear, as well as removing unnecessary personal information from internal information when it is not needed. Staff are also trained to dispose of personal information properly (e.g., shredding this information rather than discarding it in the regular garbage or recycle box). Regularly (at least annually) we review and update our privacy and confidentiality policies with all staff.
θAll employees, volunteers, professional staff members, and students are required to comply with our Privacy Policy. Disciplinary action for breach of the privacy policy must be taken by the Clinical Director.
θExternal consultants and agencies with access to personal information must enter into privacy and confidentiality agreements with us.
θWe will notify you if any personal information in our custody is stolen, lost, or accessed by unauthorized persons. One exception is if we had received the information from another health care provider (custodian), we are required to obtain consent from that original custodian before advising you of the breach.
θAny employee, volunteer, professional staff member or student who becomes aware that personal health information has been lost, stolen, or accessed by an unauthorized person is also required to report that information to the Summit Centre Privacy Officer.
Retention and Destruction of Personal 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. We do not want to keep personal information too long, in order to protect your privacy.
As required by the College of Psychologists, we keep our client files for at least 10 years past the date at which the client would turn 18 years of age. Our client and contact directories are much more difficult to systematically destroy, so we remove such information 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 keep any personal information relating to our general correspondence with people who are not our clients but are on our contact list. These are individuals to whom we send correspondence about seminars or other related activities until the client would no longer be on our contact list.
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.
You Can Look at Your Information
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. 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.
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 may have documented or raw data from standardized psychological tests or assessments. We may ask you to provide documentation that our files are wrong. A custodian, if put in writing, may have an extension of 30 days to reply to a correction. Where we agree that we made a mistake, we will make the correction and, where appropriate, notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will agree to include in our file a brief statement from you on the point and, as appropriate, we will forward that statement to anyone else who received the earlier information.
Do You Have a Concern?
Our Privacy Officer, Janine Dunn, can be reached at:
940 Prince Road | Windsor, Ontario | N9C 2Z5
PHONE (519) 255-1195
She will attempt to address any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy Officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal written decision after it has been reviewed with the Program Committee and if necessary the legal advisors of The Summit Centre Board of Directors.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. If we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
The College of Psychologists of Ontario
110 Eglinton Avenue West, Suite 500
Toronto, Ontario M4R 1A3
Phone: (416) 961-8817 | (800) 489-8388 | Fax (416) 961-2635
For more general inquiries, the Information and 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.
Information and Privacy Commissioner of Canada
112 Kent Street
Ottawa, Ontario K1A 1H3
Phone: (613) 995-8210 | (800) 282-1376 | TTY (613) 922-9190 | Fax (613) 947-6850
The Ontario Personal Health Information Protection Act is enforced by the provincial Information and Privacy Commissioner. Contact information is below.
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Telephone: (416) 326-3333 or 1-800-387-0073
Facsimile: (416) 325-9195
TTY: (416) 325-7539
Website: www.ipc.on.ca
Email address: info@ipc.on.ca
Revision History
revised version approved by the Summit Centre Board of Directors, Sept. 20, 2007
revised March 8, 2006
revised version approved by the Summit Centre Board of Directors, March 17, 2005
passed by the Summit Centre Board of Directors, Sept. 16, 2004
Privacy Policy approved 07 09 20.doc
