Your Privacy and the Law
National Home Doctor Service (NHDS) is committed to ensuring that the privacy of your personal information is respected and maintained at all times. We are bound by the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Ontario Personal Health Information Protection Act, 2004.
What personal information do we collect?
The ‘personal information’ we collect includes your name, date of birth, address/es, contact details, health card number, healthcare identifiers and health fund details. Medical information may include medical history and any care you may need. Doctors need information about your past and present health in order to provide you with high-quality care.
NHDS follows the guidelines of the CMA’s Health Information Privacy Code and Code of Ethics, as well as the CPSO’s Confidentiality of Personal Health Information Policy for the management of health information. These policies incorporate federal and provincial privacy legislation, which requires that your personal information is kept private and secure.
Why do we collect, use, hold and share your personal information?
NHDS will need to collect your personal information to provide healthcare services to you. Our main purpose for collecting, using, holding and sharing your personal information is to manage your health. We also use it for directly related business activities, such as financial claims and payments, practice audits, and business processes (e.g. staff training).
We may also collect your personal information for the purpose of telling you about our services or products that might better service your healthcare or lifestyle requirements or other opportunities in which you may be interested. You may opt out of receiving marketing communications from us at any time by following opt out instructions provided in such marketing communications.
Why and when your consent is necessary
When you register, or on your initial booking with NHDS, you provide consent for staff and doctors to access and use your personal information so they can provide you with the best possible healthcare. Only staff that needs to see your personal information will have access to it. If we need to use your information for anything else, we will seek additional consent from you to do so.
How do we collect your personal information?
NHDS will collect your personal information:
- When you register with our service i.e. pre-registration
- When you make your first booking or attempt at booking with our service
- During the course of providing medical services, we may collect further personal information
- We may also collect your personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media.
In some circumstances, personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:
- your guardian or responsible person
- other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services your health fund, or the Ministry of Health.
Your medical records
NHDS takes steps to ensure that your medical records:
- are accurate, complete, well-organised and legible
- are up-to-date
- contain enough information to allow another doctor to care for you
If you are uncertain why information is being requested, please ask our Privacy Officer. If you wish to remain anonymous while accessing healthcare services, please speak to one of our staff.
Disclosing your personal information
Subject to the particular restrictions on sensitive information (see below) we may disclose your personal information to:
- any person you request or consent to receiving the information
- in the case of a minor, to the parent with parental responsibility
- to any other authorised representative such as a legal guardian or Power of Attorney
- your treating doctor or regular general practitioner
- anyone we are required or authorised by law to disclose the personal information
- Provincial health insurance program or other health insurance companies where it is necessary for you to obtain Provincial health insurance payments or other health insurance rebates, or
- our contractors assisting us to facilitate the provision of healthcare services or other services to you;
- anyone included in a transfer of all or part of our assets or businesses
- there is an overriding public health and safety interest in the release of the information.
In the above cases, only information necessary to meet the requirements will be provided. Your health information will not ordinarily be sent overseas unless:
- you are informed and provide consent for this to occur, and
- the overseas country receiving the information has privacy laws that are very similar to the Canadian Privacy Principles.
Sensitive information will only be used for the purposes for which it was provided or for a purpose directly related to such purpose, unless you agree otherwise or the use or disclosure of the sensitive information is required or authorised by law.
By providing your personal information, you are consenting to provisions outlined previously and to the collection, use and disclosure provisions described.
NHDS requires that organizations to which it discloses your personal information have in place reasonable safeguards for protecting personal information. These organizations are only permitted to use the information for services or functions for which they have been engaged.
Providing your information to Family Doctors and others
NHDS respect your right to decide how your personal information is used or shared. Personal information that identifies you will be sent to you, your family doctor or family with your consent, unless there are exceptional circumstances. Gaining your consent is the guiding principle used by NHDS in using and sharing your information.
Using health information for quality improvement and research
NHDS may use your health information to assist in improving the quality of care we give to all our patients, by reviewing the treatments used in the service.
Your information held by NHDS may be used in research projects to improve healthcare in the community; however, this information will not include data that can identify you.
The information used for research, including the publication of research results, will not be in a form that would allow you to be identified, unless the research serves an important public interest. In such cases, identifiable medical records can be used for medical research without your consent under guidelines issued by the Canadian Government. Before providing such identified information, NHDS will discuss with you the information that she or he is obliged to disclose.
How can you access your health information?
Sharing information is important for good communication between NHDS and yourself. You can request access to your medical record and any other information NHDS records about you. You may also ask our staff about any aspect of your healthcare, including information contained in your record.
In the case of minors or individuals who are not capable of making this request, a parent with parental responsibility or legal guardian can request access to the medical records and any other information NHDS records of the relevant child or person.
If you or an authorized representative (such as a parent or legal guardian) requests access to your medical record, NHDS will need to take reasonable steps to confirm the identity of the person making the request. For authorized representatives, such as parents or legal guardians, NHDS will also take reasonable steps to confirm the identity of the patient and confirm the requester is an authorized representative by means such as confirmation from both parents, court orders indicating parental responsibility, or other legal documents demonstrating legal guardianship.
When reviewing requests for access, NHDS will need to consider if there may be a risk of physical or mental harm to you or any other person that may result from disclosure of your health information. NHDS may need to remove any information that will affect the privacy of other individuals. Depending on what is involved, you may be asked to contribute to the cost of providing the information.
Dealing with us anonymously
You have the right to deal with us anonymously or under a pseudonym unless it is impracticable for us to do so or unless we are required or authorised by law to only deal with identified individuals.
How do we protect your personal information?
Canadian privacy legislation applies to all personal health information recorded in electronic and paper records. All records must be kept secure to protect against unauthorized access. NHDS complies with these requirements to protect your information. Unauthorized use of confidential information is grounds for litigation in Canada. NHDS does not tolerate any misuse of confidential information.
We reserve the right to change this policy at any time.
Resolving concerns regarding the privacy of your health information
If you have any concerns regarding the privacy of your personal health information or the accuracy of the information held by NHDS, you should discuss these with our Privacy Officer. Inaccurate information can be corrected or your concerns noted in your record. For legal reasons, the original notes will be retained.
If you wish to contact us about your personal information or make a complaint about possible breaches of privacy, you should direct enquiries to:
National Home Doctor Service
505 Consumers Rd, Suite 901, Willowdale ON M2J 4V8
Ph : 416 631 3000
The Privacy Officer will endeavour to deal with your enquiry or complaint as soon as is reasonably practicable.
To find out more about federal privacy laws, please contact the Office of the Privacy Commissioner at 1-800-282-1376 or visit their website: www.privcom.gc.ca