Privacy of Personal Information Policy
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1. PURPOSE:

The purpose of this policy is to ensure the protection of personal data and to comply with applicable data protection regulations.

1. SCOPE:

This policy applies to all employees, contractors, and third-party service providers who handle personal data on behalf of the BodyLab Recovery Science.
At BodyLab Recovery Science, BodyLab prioritize the privacy of our client’s personal information. Our commitment is to collect, use, and disclose personal data responsibly and only as necessary to deliver our goods and services. BodyLab strives to be transparent about how BodyLab manages personal information. This document outlines our privacy policies.

1. DEFINITIONS:

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their 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. 


BodyLab Recovery Science includes, at the time of writing, one chiropractor, two physiotherapists, three massage therapists and one support member. BodyLab use several consultants and agencies that may, in the course of their duties, have limited access to personal information BodyLab hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, BodyLab’s managers, cleaners and lawyers. BodyLab restrict their access to any personal information BodyLab hold as much as is reasonably possible. BodyLab also have their assurance that they follow appropriate privacy principles. 

1. PROCEDURES: 

4.1 Collecting Client Personal Information 
As healthcare practitioners, BodyLab collect, use, and disclose personal information to serve our clients effectively. The primary purpose of collecting personal information is to provide chiropractic treatments, physiotherapy, or massage therapy. Additionally, BodyLab gather baseline health and social information to monitor changes over time and enhance ongoing health services. While rare, BodyLab may collect such information without explicit consent in emergencies or when it is impractical to obtain consent but believe in a professional capacity the client would consent if asked.


BodyLab collects, uses, and discloses personal information for several purposes:

1. Billing and Payments: To invoice clients for goods or services not paid for at the time of service, process credit card payments, or collect unpaid accounts.
2. Client Notifications: To inform clients that their product or service needs review and to notify them and others about special events or opportunities available at our clinic.
3. Quality Assurance: To review client and other files to ensure high-quality services, including staff performance assessments. External consultants may conduct audits and quality improvement reviews, which can involve reviewing client files and interviewing staff.








4. Regulatory Compliance: Our practitioners are regulated by their respective colleges, which may inspect records and interview staff as part of their regulatory activities. BodyLab also report serious misconduct, incompetence, or incapacity of practitioners and illegal behavior to the appropriate authorities. External regulators have their own privacy obligations, and such reports may include personal information to support concerns.
5. Third-Party Payments: Some goods and services are paid for by third parties, who may require certain information to demonstrate client entitlement to funding, often with client consent or legislative authority.
6. Client Inquiries and Ongoing Services: Clients may have questions about goods or services post-receipt. BodyLab provide ongoing services over months or years, for which previous records are essential. BodyLab retain client information for at least ten years after the last contact to respond to inquiries and provide these services, as required by our regulatory college.
7. Business Transactions: If BodyLab Recovery Science or its assets are to be sold, the purchaser would conduct a "due diligence" review of records to ensure business viability. This review may involve some examination of accounting and service files. The purchaser must provide a written promise to keep all personal information confidential and can only access personal information for due diligence purposes.
8. 
   
   4.2 Members of the General Public
   For members of the public, our primary purposes for collecting personal information are to inform them of special events and make them aware of our multidisciplinary services or our clinic specifically. On our BodyLab site, BodyLab only collect personal information that client provides, except for cookies, which are used solely to aid navigation and not for monitoring purposes.
   4.3 Contract Staff, Volunteers, and Students
   For individuals contracted to work with us, our primary purpose for collecting personal information is for future contact and necessary work-related communication. This may include home addresses and telephone numbers. In rare cases, BodyLab might collect information without prior consent during health emergencies or to investigate potential legal breaches. If contract staff, volunteers, or students request a reference or evaluation, BodyLab will collect information regarding their work performance and provide the report as authorized.
   
   
   4.4 PROTECTING PERSONAL INFORMATION 
   BodyLab understands the importance of protecting personal information and have implemented the following measures:
9. 1. Physical Security:
10. Paper information is either supervised or secured in a locked or restricted area.
11. Electronic hardware is either supervised or secured in a locked or an always restricted area.
12. 1. Digital Security:
13. • Password protection is implemented on all computers.
    • All cell phones are digital, making their signals more difficult to intercept.
    • Electronic information is transmitted either through direct lines or is anonymized or encrypted.
14. 1. Information Transmission:
15. • Paper information is transmitted using sealed, addressed envelopes or boxes by reputable companies.
16. 1. Training:
    2. • BodyLab employees and contractors are trained to collect, use, and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
       • They must also adhere to the privacy policies set out by their specific overseeing body or college. 
       • Third-Party Agreements:
       • External consultants and agencies with access to personal information must enter into privacy agreements with us.
    3. 
       
       4.5 RETENTION AND DESTRUCTION OF PERSONAL INFORMATION 
       BodyLab retain personal information for a specific period to address any questions client may have about the services provided and to meet our accountability requirements to external regulatory bodies. However, to protect client privacy, BodyLab avoid retaining personal information longer than necessary.
    4. 1. Client Files:
    5. BodyLab retain client files for ten years after the last visit.
    6. 4.5.2     Client and Contact Directories:
    7. • These directories are more challenging to systematically destroy, but BodyLab remove such information when it appears BodyLab will no longer need to contact a client. 
       • Upon request, BodyLab will promptly remove client contact information.
    8. 4.5.3     General Correspondence and Marketing:
    9. • BodyLab retain personal information related to general correspondence, newsletters, seminars, and marketing activities for six months after the publication ends or the event concludes.
    10. 1. Destruction of Personal Information:
    11. • Paper Files: Destroyed by shredding.
        • Electronic Information: Deleted, and when the hardware is discarded, the hard drive is physically destroyed.
    12. Alternatively, BodyLab may send some or all the client file to the client.​
        
        4.6 RETAINING INFORMATION 
        With only a few exceptions, clients have the right to see what personal information BodyLab hold about them. Often, a client can ask for this request at their convenience. BodyLab can help clients identify what records BodyLab might have about them. BodyLab will also try to help clients understand any information or technical language they may not understand. BodyLab will need to confirm a client's identity through government issued identification, if they are not familiar with our practitioners, before providing access. BodyLab reserve the right to charge a nominal fee for such requests. If there is a problem, BodyLab may ask the client to put their request in writing. If BodyLab cannot provide access, BodyLab will inform the client within 30 days, if possible, and explain the reason for the denial.
        If a client believes there is a mistake in the information, they have the right to request a correction. This applies to information and not to any professional opinions BodyLab may have formed. BodyLab may ask the client to provide documentation that our files are incorrect. If BodyLab agree that a mistake was made, BodyLab will correct it and notify anyone who received the incorrect information. If BodyLab do not agree that there is a mistake, BodyLab will still include a brief statement from the client in our file on the matter and forward that statement to anyone who received the original information
        
        
    13. REFERENCES:
    14. Ontario Chiropractic Association
        Tel: 416-860-0070 | Toll-free: 1-877-327-2273
        [email protected]  | Fax: 416-860-0857
        70 University Ave. Ste. 201 Toronto, ON M5J 2M4 
        
        
        College of Massage Therapists of Ontario
        Tel: 416-489-2626 | Toll- free: 1-800-465-1933
        [email protected] |Fax: 416-489-2625
        1867 Yonge Street, Suite 810 Toronto, ON M4S 1Y5
        
        
        College of Physiotherapists of Ontario
        Tel: 416-591-3828 ext. 201 |Toll-free: 1-800-583-5885
        [email protected] |Fax: 416-591-3834
        375 University Ave, Suite 800 Toronto, ON M5G 2J5
        
        
        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.
        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. 
        The Information and Privacy Commissioner can be reached at: 
        30 Victoria St. | Gatineau, Quebec | K1A 1H3 
        PHONE 819-994-5444| TOLL-FREE 1-800-282-1376 | TTY 819-994-6591 
        https://www.priv.gc.ca/en/contact-the-opc
        
        
        
    15. REVISION AND REVIEW:
    16. 
        This policy will be reviewed annually by the Information Officer and revised as necessary.
        Our Information Officer, Dr. Sarah Hopkins, can be reached at:
         52 George St. | St. Catharines, ON |L2R 5N6
         PHONE (905)-228-3130
        
        
        She will attempt to answer any questions or concerns client might have.
        If client wish to make a formal complaint about our privacy practices, client may make it in writing to our Information Officer. She will acknowledge receipt of client complaint, ensure that it is investigated promptly, and that client are provided with a formal decision and reasons in writing.
        If client have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff, BodyLab will ask client to discuss those concerns with us. However, if BodyLab cannot satisfy client concerns, a client is entitled to complain to our regulatory bodies. 
        
        
        Policy Approved by:         Dr. Sarah Hopkins
        Date of Approval:     May 29th, 2024
        Review Date:         May 29th, 2024