Privacy Policy

Life Therapies Inc. (“Life Therapies”, “we” or “us”) is committed to respecting and protecting your privacy.

Accordingly, this policy (“Privacy Policy”) outlines general privacy and information practices with respect to the personal information and personal health information that we may collect when delivering services to you and when we otherwise interact with you.

This Privacy Policy also outlines:

  • How we will collect, use and disclose your personal information and personal health information;
  • How we store, retain and protect your personal information or personal health information;
  • How you can access records containing your personal information; and
  • How you can request correction of your personal information or personal health information.

A. What Is Personal Information?

Personal information is information about an identifiable person.

Personal health information is a subset of personal information, and refers to identifiable information about an individual which relates to, among other things, the following:

  • Physical or mental health of the individual, including family health history;
  • Provision of health care to the individual, including the identification of a person as a provider of health care to the individual;
  • Payments or eligibility for health care in respect of the individual;
  • The individual’s health number; or
  • Identification of an individual’s substitute decision-maker.

For the remainder of this Privacy Policy, “Personal Information” will be used generally to refer to both personal information and personal health information (as defined above).

B. Life Therapies Inc.

Life Therapies is a multi-disciplinary group practice in Ottawa, Ontario, offering physiotherapy and osteopathy health services to the public. As such, Life Therapies is governed by the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3 and acts as a health information custodian for any Personal Information that is collected, used and/or disclosed from our clients.

Our work at Life Therapies is supported by a dedicated team. Therefore, there may be circumstances in which individuals employed by us (e.g. administrative staff) may collect, use, access and/or disclose your Personal Information. In such cases, since the Personal Information is used to deliver health services to you, these individuals act as our agents – i.e. under our strict instruction, and in accordance with applicable laws and this Privacy Policy.

C. Personal Information We Collect

We collect, use and disclose Personal Information to provide health care (i.e. physiotherapy and osteopathy) services to our clients. To that end, the Personal Information we may collect from you includes the following:

  • Your first and last name, birthdate, address, and other contact information (i.e. phone numbers, fax numbers, email addresses);
  • Your health history, including your age, family history, physical condition and function, social situation, and employment information;
  • Names and contact information of your emergency contacts;
  • Your payment information (e.g. credit or debit card information) and/or any third-party payor information.

D. How We Collect, Use and Disclose Personal Information

As required by applicable law, we will typically obtain your consent before, or when, collecting, using, transferring or disclosing your Personal Information.

There are different ways you can give your consent for the collection, use and disclosure of your Personal Information under this Privacy Policy. This includes:

  • Express consent – for example, verbally or electronically through our consent form, which describes the intended uses and disclosures of your Personal Information; or
  • Implied consent – for example, when you provide information necessary for a service you have requested, or, in some circumstances, where we have given you notice about our intention to take a specific action with respect to your Personal Information and you have not withdrawn your consent for the identified purpose.

By accessing, using, and completing forms that we provide to you (either physically or electronically), using our services, and/or otherwise interacting with us, you are consenting to the collection, use, transfer and disclosure of your Personal Information by us (or by others handling your Personal Information on our behalf) in accordance with the terms and purposes set out in this Privacy Policy, as they may be amended from time to time.

Please note that it would be rare for us to collect or disclose your Personal Information without your express consent. However, there are circumstances in which your Personal Information may be collected, used and/or disclosed without your consent. Examples include:

  • In circumstances where a third-party payor (e.g. an insurance company to whom you have claimed reimbursement for our services) requests information from us about the details of the service(s) we provided to you;
  • In an emergency, in which case you would be notified about the collection, use or disclosure of your Personal Information in writing as soon as possible; or
  • Where it is impractical to obtain consent, but we otherwise have reason to believe that you would have provided your consent if asked (e.g. a family member passing a message on to us on your behalf and we have no reason to believe that the message is not genuine).

E. Why We Collect Personal Information

i. Purpose(s) of Collection of Personal Information

We will collect your Personal Information directly from you, unless you have provided your express consent for us to collect your Personal Information from a third-party source (e.g. your family physician or a previous health service provider).

We collect the Personal Information listed in Section C above for the following purposes (as appropriate):

  • To provide you with physiotherapy and/or osteopathy care (as appropriate and requested by you);
  • To comply with our professional recordkeeping and quality control obligations;
  • To invoice, collect and process payments for services rendered to you.

Outside of these purposes, for members of the public who contact us, our primary purpose for collecting their Personal Information (e.g. name and phone numbers) is to respond to their inquiries and provide them with information about the services we offer.

ii. Method of Collection of Personal Information

In our practice, we collect, access and store all client records (including intake and consent forms, correspondence, charting notes, reports, invoices, etc.) through a secure practice management platform called Jane.

For our physiotherapy services, we also use a secure home exercise program called Wibbi to deliver exercise programming to clients.

Jane and Wibbi are third-party service providers which are built to comply with applicable privacy laws.

For more information about the set up and delivery of these systems, please consult the following:

System Link to Information About Service Provider Link to Privacy Policy
Jane “About” page: https://jane.app/about https://jane.app/legal/privacy-notice
Wibbi “About” page: https://wibbi.com/about/ https://wibbi.com/privacy-policy/

 

F. Disclosure of Personal Information and Limits of Confidentiality

We will not disclose your Personal Information to third parties without your informed consent.

However, there are certain limits to the confidentiality of your Personal Information, in which case disclosure of your Personal Information to a third party may be required and/or permitted by law. Namely, circumstances in which disclosure of your Personal Information may be required and/or permitted without your consent include:

  • Where there is suspicion that a child or children (i.e. a person 18 or younger) has been or is being neglected and/or sexually, psychologically, or physically abused;
  • Where a client is likely to harm themselves unless protective measures are taken;
  • Where a client presents a serious risk of harm/violence to others;
  • If a client reveals that they have been sexually abused by a health care provider (for example, a physiotherapist, psychologist, physician, social worker, etc.) who is governed by the Regulated Health Professions Act, 1991, S.O. 1991, c. 18 (in which case we are bound by law to report the name of the perpetrator to the health care provider’s governing body);
  • Where there are reasonable grounds to suspect abuse or neglect of residents living in long-term care facilities or retirement homes (including the misuse or misappropriation of money);
  • When required by Order, Search Warrant, or Urgent Demand to disclose information to police about a missing person;
  • When required to disclose information pursuant to a legal proceeding; or
  • When participating in a peer assisted review in the context of a professional regulator’s quality assurance program or responding to a professional regulator’s investigation.

In circumstances where we are required to disclose your Personal Information to comply with one of these obligations, whenever appropriate/practicable, we will endeavour to notify you before disclosing the information to the applicable party, or (if that is not possible) at a reasonable time after the disclosure is made.

G. Protection of Personal Information

i. Storage of Personal Information

As noted above in Section E(ii), your Personal Information will be stored in our practice management system, Jane and, where applicable, in Wibbi.

ii. Retention of Personal Information

Under applicable laws and standards, we are required to retain your Personal Information for at least:

  • Ten years following your last interaction with us; or
  • Ten years after the day you turn eighteen years old (i.e. if you were less than 18 years old at the time of your last interaction with us).

The retention of this information assists us in being able to respond to lawful requests for access to your Personal Information.

Following the expiry of the above retention term, your Personal Information will be deleted/destroyed via secure means.

iii. Safeguards for Personal Information

Protecting your Personal Information is important to us. For that reason, we take reasonable and appropriate actions to protect your Personal Information. These include:

  • Limiting collection of your Personal Information to only what is necessary to deliver our services to you;
  • Using reputable and secure third-party service providers to collect and store your Personal Information;
  • Restricting internal access to your Personal Information to only those who are involved in delivering service to you.

H. Your Privacy Rights

i. Right to Withdraw Consent to Collection, Use and Disclosure of Personal Information

You have the right to withdraw your consent to the collection, use and disclosure of your Personal Information at any time. However, please be advised that if you withdraw your consent, this may impact your ability to access our services.

Further, the effect of your withdrawal of consent is not retroactive – i.e. any Personal Information that was collected, used or disclosed prior to the withdrawal will continue to be handled in accordance with applicable privacy laws and the terms of this Privacy Policy.

ii. Right of Access to Personal Information

Subject to applicable exceptions, you have the right to access a record of your Personal Information and to request copies of same.

Please note that we may require that your request be made in writing, after which we will endeavour to provide our response within 30 days.

In circumstances where we can grant access to the record, please note that we will need to confirm your identity prior to releasing the record to you.

In some cases, the record in question may contain Personal Information belonging to or that identifies another individual. In these circumstances, we may need to obtain consent from the other individual before the record can be released to you. Alternatively, that individual’s information may need to be severed from the record before we can grant you access.

Please be advised that we reserve the right to charge a nominal fee for access requests. This fee is intended to recover a fraction of the cost(s) associated with (as applicable):

  • Retrieving your file from storage;
  • Reviewing the file to determine whether access may be granted; and/or
  • Separating out your Personal Information from the Personal Information of other affected individuals.

iii. Right to Correction of Personal Information

If you believe that our records contain an error in relation to your Personal Information, you have the right to request that the error be corrected.

This right applies only to the correction of factual information and does not permit you to request that changes be made to any professional opinions or observations contained in the record.

When considering a request to correct your Personal Information, we may ask you to provide documentation to support the correction. After reviewing the documentation:

  • Where we agree that a correction needs to be made, we will make the correction and notify anyone to whom we have sent your Personal Information about the correction.
  • If we do not agree that a correction needs to be made, you can provide us with a notice of your disagreement that we will include in the record. We will also forward the notice of disagreement to anyone to whom we have sent your Personal Information.

I. Privacy Inquiries

We will endeavour to respond in a timely manner to your questions, concerns and/or complaints about the protection of your Personal Information and/or about this Privacy Policy.

If you would like more detailed information about this Privacy Policy, would like to access or ask for a correction of your Personal Information, would like to communicate any concerns/complaints about our privacy policies and procedures, or any concerns/complaints about the way your privacy is being handled, please do not hesitate to contact us through our Privacy Officer:

Tamara Bond-Vlad
205-307C Richmond Rd.
Ottawa, ON K1Z 6X3
(613) 422-8939
info@LifeTherapies.ca

Please note that if we are unable to resolve your privacy questions and/or concerns, you have the right to contact or launch a written complaint with the Office of the Information and Privacy Commissioner of Ontario (“OIPC”). The OIPC is the provincial regulator which oversees Ontario’s access and privacy laws, including the Personal Health Information and Protection Act, 2004, S.O. 2004, c. 3, Sched. A. The OIPC can be contacted through the following information:

Office of the Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
Tel: 416-326-3333 or 1-800-387-0073
Email: info@ipc.on.ca
For information about filing a complaint, please visit the OIPC’s Privacy Complaints Process.

J. Changes to This Privacy Policy

We may update/revise this Privacy Policy from time to time. We will circulate the amended Privacy Policy and review changes with you at your request.

If we make any material changes to this Privacy Policy, we will notify you and obtain your consent (if required by applicable law) before the changes take effect. Material changes will only apply to your Personal Information collected after the amended Privacy Policy takes effect.