PRIVACY POLICY

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

To advise clients that their product or service should be reviewed

To advise clients and others of special events or opportunities that we have available.

Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff.  

Massage Therapists are regulated by the College of Massage Therapists of Ontario who may inspect our records and interview 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. External regulators have their own strict privacy obligations.  Sometimes these reports include personal information about our clients, or other individuals, to support our 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.

The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., OHIP, WSIB, private insurance).  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 client entitlement to this funding.

Clients or other individuals we deal with may have questions about our goods and 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 client 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 College also requires us to retain our client records).

If ‘Your Wellness Journey’ 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).

Protecting Personal Information:

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

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. 

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

Retention and Destruction of Personal Information:

We need to retain personal information for some time to ensure that we can answer any questions you might have about our 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 client files for ten years.  Our client 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.

You can look at your Information:

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

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 made a mistake, we will still agree to include our file in a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.