1 / What is personal information?

Personal information pertains to details about an identifiable person, encompassing aspects such as their personal attributes (e.g., gender, age, income, residential address, contact number, ethnicity, and family situation), their health information (including health history, conditions, and medical services received), as well as their personal beliefs and opinions (e.g., religious beliefs, political stances, expressed opinions, or evaluations of the individual). This definition distinguishes personal information from business-related data (e.g., an individual's work address and phone number), which falls outside the scope of privacy legislation protection.

2 / What is personal health information?

In Ontario, the Personal Health Information Protection Act (PHIPA) governs personal health information. PHIPA offers a comprehensive definition of personal health information, which includes:

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• Information relating to an identifiable individual, including data that can be amalgamated with other information to identify the individual.

• Information in oral or recorded form, extending to questions asked (even if the answers are not recorded), and it pertains to the individual's:

  • Physical or mental condition, encompassing family health history.

  • Healthcare details, encompassing maintenance, preventative measures, and palliative care.

  • Providers of healthcare services.

  • Payment for healthcare services, including health card numbers.

  • Substitute decision-makers.

  • Non-healthcare information (e.g., home contact information) integrated with other personal health information.

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RevivoSync Therapeutic Clinic adheres to PHIPA guidelines for the collection, retention, destruction when appropriate, and disclosure of all personal health information. For further details, please refer to our brochure titled "Your Health Information and Your Privacy in Our Office."

3 / Primary Purposes of Information Collection

Like all massage therapy/wellness clinics we collect, use and disclose personal information in order to serve our patients.

For our patients, the primary purpose for collecting personal information is to provide registered massage therapy and related (acupuncture, chiropractic, naturopathy) services. For example, we collect information about a patient's health history, including their family history, physical condition and function and social situation in order to help us assess what their health needs are, to advise them of their options and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that are occurring over time. It would be rare for us to collect such information without the patient's express consent, but this might occur in an emergency (e.g. the clients 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 from our client and we have no reason to believe that the message is not genuine).

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For members of the general public, our primary purposes for collecting personal information to provide notice of special events (e.g. promotion) or to make them aware of massage therapy and related 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, phone 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.

4 / Secondary Purposes of Information Collection

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 patients for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.

• To advise patients that their products or services 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 patients and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new product, change of location/contact information) that we have available.

• Occasional communications from the patients (e.g. newsletter, holiday/birthday cards)

• Our clinic reviews patients 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 patient files and interviewing our staff.

• Registered Massage Therapists, Registered Acupuncturists, Registered Traditional Chinese Medicine Practitioners, Naturopathy Doctors and Chiropractors are regulated by their respective provincial Colleges (regulatory bodies) 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 will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious 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, 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 patients is paid for by third parties (e.g. extended health/auto insurers). 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 patient's entitlement to this funding.

• Patients 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 patients information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory Colleges also require us to retain our patient records).

• If RevivoSync Therapeutic Clinic or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

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, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

5 / Information Protection

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

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• 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 at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.

• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.

• Electronic information is transmitted either through a direct line or is anonymized or encrypted.

• Staff is trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.

• External consultants and agencies with access to personal information must enter into privacy agreements with us.

Please note that as e-mail is not a secure medium we do not as a policy initiate transmission of any personal or personal health information or identify a patient/client in an email unless specifically requested to do so by him/her. We only use email for general communications. If you choose to send us an email containing any personal or personal health information, it is implied that you have consented to providing us with this information in this manner. If you have concerns about your information being intercepted by an unauthorized party, you should consider contacting us by phone or another secure method of communication.

6 / Information Retention and Destruction

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 patient files for about 10 years from the date of last entry (or 10 years past the age of 18 if the client was under 18 at the time of the last entry. Our patients 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 right away. We keep any personal information relating to our general correspondence with people who are not our patients, newsletters, seminars and marketing activities for about 2 years after the newsletter ceases publication, 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. Alternatively, we may send some or the entire client file to our client.

7 / Your Choices

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. We reserve the right to charge a nominal fee for such requests.

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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.

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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 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.

8 / Use of Third-Party Platforms

At RevivoSync Therapeutic Clinic, we utilize trusted third-party platforms to store, use, share, and disclose information. We want to assure you that these platforms are compliant with the highest security standards and regulations, ensuring the utmost protection of your data. Specifically, we utilize Wix.com and Janeapp.com for various aspects of our operations.

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Wix.com: Our website and online presence are hosted and managed through Wix.com. Wix.com is committed to meeting Payment Card Industry (PCI) requirements, which are designed to safeguard your personal information. They also adhere to the relevant regulations of the Personal Information Protection and Electronic Documents Act (PIPHEA). Read more about Wix.com privacy policy.

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Janeapp.com: Our appointment scheduling and patient management services are facilitated through Janeapp.com. Janeapp.com also adheres to the stringent PCI requirements and operates in accordance with PIPHEA regulations to ensure the security and privacy of your personal and health information.

We want you to have peace of mind regarding the protection of your data while using our services. If you have any questions or concerns about the privacy practices of these platforms, please do not hesitate to contact us. Your trust is of utmost importance to us, and we are committed to ensuring the secure handling of your information. Read more about Janeapp.com privacy policy.

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Please note that while we partner with these platforms to enhance the delivery of our services, you should also review their respective Privacy Policies for more detailed information on how they handle data.

9 / Contact Us

For any inquiries or concerns regarding this Privacy Policy, please contact us at revivosync@gmail.com.

By using our website and services, you consent to this policy, which adheres to best practices as recommended by Wix. Thank you for choosing RevivoSync Therapeutic Clinic for your wellness needs.

Please note that while this Privacy Policy is based on Wix's recommendations, it is advisable to consult with legal professionals to ensure full compliance with specific legal and regulatory requirements.

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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. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory bodies:

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COLLEGE OF MASSAGE THERAPISTS OF ONTARIO
1867 Yonge St. Suite 810, Toronto, ON M4S 1Y5
www.cmto.com

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COLLEGE OF TRADITIONAL CHINESE MEDICINE PRACTITIONERS AND ACUPUNTURISTS OF ONTARIO

55 Commerce Valley Drive West, Suite 705, Thornhill, ON L3T 7V9

https://www.ctcmpao.on.ca

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COLLEGE OF CHIROPRACTORS OF ONTARIO
130 Bloor St W. Suite 902, Toronto, ON M5S 1N5
http://www.cco.on.ca

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This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. Specific policies pertaining to personal health information are made under the Personal Health Information Protection Act.

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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 Privacy Commissioner can be reached at:

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112 KENT STREET | OTTAWA, ONTARIO | K1A 1H3
PHONE (613) 995-8210 | TOLL-FREE 1-800-282-1376 | FAX (613) 947-6850 | TTY (613) 992-9190 http://www.privcom.gc.ca

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Inquiries pertaining to personal health information in Ontario can be directed to:

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Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, ON, M4W 1A8
Phone: 416-326-3333 or 1-800-387-0073
Fax: 416-325-9195

http://www.ipc.on.ca