PRIVACY POLICY AND PROCEDURE

Administration

Privacy Policy and Procedure

A-02

经批准

梅兰妮·马努拉，导演

January 1, 2019.

February 1, 2019

February 1, 2020

1

1.01

The purpose of this policy is to affirm Creative Therapy Associates’ commitment to managing information responsibly to support quality service delivery. All team members understand the importance of protecting personal information and exercising due diligence when collecting, using and disclosing such information. In addition, transparency in information management practices is considered an integral aspect of this policy.

1.02

Creative Therapy Associates provides Speech-Language Pathology and Occupational Therapy services to clients of all ages throughout Northwestern Ontario. These services are often provided on behalf of community agencies including the Children’s Centre of Thunder Bay, George Jeffrey Children’s Centre, Thunder Bay Catholic District School Board, Dilico Anishinabek Family Care, North West Local Health Integration Network, Veteran’s Affairs, Workplace Safety Insurance Board and Options Northwest. Our Speech-Language Pathologists are registered members of the College of Audiologists and Speech-Language Pathologists of Ontario and our Occupational Therapists are registered members of the College of Occupational Therapists of Ontario. As such, they are subject to the legal requirements of these colleges according to the provision of the Regulated Health Professions Act.

1.03

Our therapists are supported by administrative team members, which also have access to the personal information we hold. We restrict as much as is reasonably possible their access to such personal information.

1.04

We are also involved with a number of individuals and agencies that may in the course of their duties have limited access to the personal information we hold. These may include lawyers, accountants, bookkeepers, computer consultants and students. We restrict as much as is reasonably possible their access to such personal information and have their assurance that they will follow appropriate privacy practices.

1.05

Our primary purpose for collecting, using and disclosing personal information is to serve our clients and provide the best care as it relates to Speech-Language Pathology and Occupational Therapy Services.

1.06

We also collect, use and disclose personal information for purposes related to or secondary to our primary purpose. These would include:

1.07

除少数例外情况外，客户有权查看我们持有的关于他们的个人信息，并可提出查阅申请。我们可以提供记录识别信息，并对任何不清楚的信息进行解释说明；但如果客户身份不明，则在授予查阅权限前，我们应先确认客户身份。CTA保留对此类申请收取少量费用的权利。

1.08

如果客户认为信息有误，他们有权要求更正。这仅适用于事实信息，不适用于团队成员可能形成的任何专业意见。CTA管理层可能会要求客户提供文件证明记录有误。如果双方一致认为CTA犯了错误，隐私官将进行更正，并通知所有收到过该信息的人员。如果双方不同意CTA犯了错误，客户就此问题提交的简要声明将被添加到文件中，并转发给所有之前收到过该信息的人员。

1.09

The Privacy Officer, Melanie Maunula, can be reached at (807) 626-4268 to address any questions or concerns. If a client wishes to make a formal complaint about CTA privacy practices, it can be made in writing and directed to the Privacy Officer identified above. The receipt of the complaint will be acknowledged, the issue will be investigated promptly and the client will be provided with a formal decision and reasons in writing.

1.10

The client must also be advised of their right to file a complaint with the Information Privacy Commissioner. If the client indicates interest in doing so or has additional questions, the client can be directed to:

1.11

本政策和程序声明将为所有团队成员在服务提供和相关运营过程中收集、使用和披露个人信息时制定指导方针。

2.01

The owners of Creative Therapy Associates are committed to protecting the personal information of clients and exercising due diligence when collecting, using and disclosing such information in the context of service delivery and related operation.

2.02

All team members have an important role in promoting and supporting the implementation of this policy and related procedures.

2.03

All team members are responsible for ensuring that personal information is protected and is only used for the purposes for which it was collected and is not disclosed without proper authorization. All team members will be required to sign a confidentiality agreement to that effect on an annual basis.

2.04

All regulated health professionals managing information in the context of service delivery are required to be compliant with the guidelines provided by their regulatory college.

2.05

Any team members that handle personal information contrary to this policy may be subject to disciplinary measures up to and including dismissal or termination of contracted services.

2.06

The Privacy Officer, Melanie Maunula, is accountable for the implementation of this policy and the related procedures. As such, any issues or questions regarding this policy or related procedures should be directed accordingly.

3.01

本政策和程序声明适用于所有团队成员，包括所有者、董事、员工、分包商和学生。

4.01

The Privacy Officer, Melanie Maunula, is responsible for:

4.02

所有团队成员均有责任：保持个人档案的更新，并确保其文件符合监管机构的要求；熟悉并遵守与服务提供相关的所有个人信息的收集、使用和披露的政策及相关程序；向客户解释此政策及相关程序，并在适当情况下将其转介给隐私官 Melanie Maunula；在披露与服务提供相关的个人信息之前，获得适当的同意和授权；对密码保密并限制对个人信息的访问；立即向隐私官 Melanie Maunula 报告任何隐私泄露事件，以便其进行调查并在认为适当时进行报告；在离职或终止雇佣关系时，放弃对任何个人信息的持有或访问权限；

5.01

Personal information is any information about an identifiable individual and may include race, ethnic origin, colour, age, marital status, family status, religion, education, medical history, criminal record, employment history, financial status, address, telephone number, and any numerical identification, such as Social Insurance Number. Personal information also includes information that may relate to the work performance of the individual, any allegations, investigations or findings of wrongdoing, misconduct or discipline. Personal information does not include job title, business contact information or job description.

5.02

Personal health information is information about an identifiable individual that relates to the physical or mental health of the individual, the provision of health care to the individual, the individual’s entitlement to payment for health care, the individual’s health card number, the identity of providers of health care to the individual or the identity of substitute decision-makers on behalf of the individual. This information can be in oral or recorded format.

5.03

Third party is an individual or organization other than the subject of the records or a representative of Creative Therapy Associates. Note that in certain circumstances; Creative Therapy Associates may be entitled to provide personal information to a third party acting as an agent of Creative Therapy Associates.

7.01

Personal information regarding clients may only be collected, used, disclosed and retained for the purposes identified by Creative Therapy Associates as necessary and only after such purposes have been disclosed to the client and their knowledgeable consent obtained.

7.02

All team members much ensure that no personal client information is disclosed without the client’s consent and that all information handling processes are compliant with recommended privacy practices.

7.03

All team members must employ the following safeguards and take reasonable steps to ensure:

Privacy Statement

February 1, 2020

我们致力于保护您的隐私，并确保您个人健康信息的保密性。我们收集的个人健康信息可能包括您的姓名、出生日期、健康史以及您接受的护理记录。我们收集、使用和披露个人健康信息的目的如下：为我们的客户提供言语语言病理学或职业治疗服务；收取服务费用；为学生授课并为我们的团队提供继续教育；开展质量改进和风险管理工作；履行我们对安大略省言语语言病理学家和听力学家学院以及安大略省职业治疗师学院的监管义务；以及法律允许的其他目的。

We will collect, use and disclose only as much personal health information as is needed to achieve these purposes. You can withhold or withdraw your consent to the collection, use or disclosure of your personal health information by contacting our privacy officer.

You have the right to seek access to your health records that we keep and to ask us to correct a record if you believe it is inaccurate or incomplete. Please contact our privacy officer for more information.

You also have the right to complain to the Information and Privacy Commissioner of Ontario at the address below if you have concerns about our privacy practices or how your personal health information has been handled.

安大略省信息与隐私专员公署，地址：2 Bloor Street East, Suite 1400, Toronto, Ontario M4W 1A8，电话：多伦多地区 (416/本地 905) (416) 326-3333，长途：1 (800) 387-0073（安大略省内），TDD/TTY：(416) 325-7539，传真：(416) 325-9195，网址：www.ipc.on.ca

Website 

May 18, 2017

Creative Therapy Associates ("us", "we", or "our") operates the http://www.creativetherapyassociates.ca website (the "Service").

个人信息可能包括您的姓名、电子邮件地址、年龄、家庭住址、电话号码、婚姻状况、收入、信用记录、医疗信息、教育背景、就业信息和社会登记号码。我们致力于为我们的客户、顾客、会员（以下简称“您”）提供卓越的服务。提供卓越的服务可能涉及收集、使用，有时甚至需要披露您的个人信息。保护您的个人信息是我们的首要任务之一。我们始终尊重您的隐私并保护所有个人信息，并且我们已进一步加强了对这一目标的承诺。这是为了继续为您提供卓越的服务，并遵守所有关于个人信息收集、使用和披露的法律法规。我们将告知您我们收集、使用和披露个人信息的原因和方式；在必要时征得您的同意；并根据适用法律处理个人信息。我们对隐私的承诺包括确保您个人信息的准确性、保密性和安全性，并允许您请求访问和更正您的个人信息。本页面将告知您我们在您使用我们的服务时收集、使用和披露个人信息的政策。除本隐私政策中所述情况外，我们不会将您的信息用于任何其他用途或与任何人分享。

Cookie 是包含少量数据的文件，其中可能包含一个匿名唯一标识符。网站会将 Cookie 发送到您的浏览器并存储在您计算机的硬盘上。我们使用 Cookie 来收集信息。您可以设置浏览器拒绝所有 Cookie 或在收到 Cookie 时发出提示。但是，如果您不接受 Cookie，则可能无法使用我们服务的某些功能。如果您未设置浏览器拒绝所有 Cookie 或在收到 Cookie 时发出提示，则视为您同意我们使用您的个人信息。

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

As set out above, and for clarity, we will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

Our Service does not address anyone under the age of 18 ("Minor").

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

If you have any questions about this Privacy Policy, please contact us.