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1. Openness and transparency
1.1 We value client privacy and act to ensure that it is protected.
1.2 This policy was written to capture our current practices and to respond to federal and provincial requirements for the protection of personal information
1.3 This policy describes how this office collects, protects and discloses the personal information of clients and the rights of clients with respect to their personal information. 1.4 We are available to answer any client questions regarding our privacy practices.
2.1 The physician is ultimately accountable for the protection of the health records in his/her possession.
2.2 Client information is sensitive by nature. Employees and all others in this office who assist with or provide care (including students and locums) are required to be aware of and adhere to the protections described in this policy for the appropriate use and disclosure of personal information.
2.3 All persons in this office who have access to personal information must adhere to the following information management practices.
2.4 This office employs strict privacy protections to ensure that We protect the confidentiality of any personal information we access in the course of providing client care.
- We collect, use and disclose personal information only for the purposes of providing care and treatment or the administration of that care, or for other purposes expressly consented to by the client.
- We adhere to the privacy and security policies and procedures of this office. -We educate and train staff on the importance of protecting personal information.
Collection, Use and Disclosure of Personal Information
3. Collection of personal information
3.1 We collect the following personal information -Identification/Contact information, including name -date of birth -Billing information, including -Provincial/territorial Health insurance plan (health card) number private medical insurance details -Health information, which may include medical history -presenting symptoms
3.2 Limits on collection We will only collect the information that is required to provide care, administrate the care that is provided, and communicate with clients. We will not collect any other information, or allow information to be used for other purposes, without the client's express consent - except where authorized to do so by law. These limits on collection ensure that we do not collect unnecessary information.
4. Use of personal information
4.1 Personal information collected from clients is used by this office for the purposes of-Identification and contact
- Emergency contact
- Provision and continuity of care
- Historical record
- Health promotion and prevention
- Administrate the care that is provided.
- Prioritization of appointment scheduling
- Billing provincial health plan
- Professional requirements
- Risk or error management, i.e., medical-legal advice (C.M.P.A.)
- Quality assurance (peer review)
- Research studies and trials
5. Disclosure of personal information
5.1 Implied consent (Disclosures to other providers)
5.1.1 Unless otherwise indicated, you can assume that clients have consented to the use of their information for the purposes of providing them with care, including sharing the information with other health providers involved in their care. By virtue of seeking care from us, the client's consent is implied for the provision of that care.
5.2 Without consent (Disclosures mandated or authorized by law)
5.2.1 The essence of privacy is the following regarding PRIVATE or PERSONAL INFORMATION of our CLIENTS, We NEVER disclose information unless you give us written permission, EXCEPT A FEW CASES ARE LEGALLY FORCED TO DISCLOSE INFORMATION to the APPROPRIATE AUTHORITIES:
18.104.22.168 ABUSE: Suspected abuse of a child (or a dependant elderly , etc)
22.214.171.124 HOMICIDE: Suspected or reference to killing, or harming others.
126.96.36.199 SUICIDE: Suspected or reference to killing, or harming others.
5.3 Express Consent (Disclosures to all other third parties)
5.3.1 The client's express consent (oral or written) is required before we will disclose personal information to third parties for any purpose other than to provide care or unless authorized to do so by law.
5.3.2 Examples of situations that involve disclosures to third parties include (but are not limited to) -third party medical examinations
-provision of charts or chart summaries to insurance companies
5.3.3 Disclosure Log Before a disclosure is made to a third party, a notation shall be made in the file that the client has provided express consent, or a signed client consent form is appended to the file.
5.4 Withdrawal of consent
5.4.1 clients have the option to withdraw consent to have their information shared with other health providers at any time.
5.4.2 clients also have the option to withdraw consent to have their information shared with third parties.
5.4.3 If a client chooses to withdraw their consent, the physician will discuss any significant consequences that might result with respect to their care and treatment (e.g., possible negative impact on the care provided).
6. Security measures
6.1 Safeguards are in place to protect the security of client information.
6.2 These safeguards include a combination of physical, technological (for offices where computers are in use) and administrative security measures.
6.2.1 We use the following physical safeguards limited access to office monitored alarm system deadbolt entry lock (or key card/key pad entry system limited access to records need to know basis locked file cabinets office layout/features front desk privacy screens soundproofing and/or white noise to ensure confidentiality
6.2.2 We use the following technological safeguards Protected computer access for client health information
- user authentication
- system protections
- firewall software
- virus scanning software
Protected external electronic communications - Internet
- separate internet access (stand alone, not connected to operating system)
- encrypted email for any external communication of client health information
- secure electronic record disposal
- safely dispose of computer hard drives
- destroy all other removable media (diskettes, CD-R, DVD)
Wireless and mobile communication devices (e.g., laptops, PDAs, etc) are especially vulnerable to loss, theft and unauthorized access.
- We take extra precautions when using these devices for client health information.
6.2.3 We use the following administrative safeguards
188.8.131.52 Limits on third party access
- Any other persons having access to client information or to these premises (e.g., cleaners, security staff, landlords) shall, through contractual or other means, provide a comparable level of protection.
184.108.40.206 Staff signed confidentiality agreements
- We also ensure that all staff have signed confidentiality agreements or clauses as part of (or appended to) their employment contract.
- This confidentiality agreement or clause extends beyond the term of employment.
7. Communications policy
7.1 We are sensitive to the privacy of personal information and this is reflected in how we communicate with our clients, others involved in their care and all third parties.
7.2 We protect personal information regardless of the format.
7.3 We use specific procedures to communicate personal information by
- Client preference with regards to phone messages will be taken into consideration
- Unless authorized, we only leave our name and phone number on message for clients
- Our fax machine is located in a secure or supervised area (restricted public access)
- we use of pre-programmed numbers to ensure fax received by proper recipient
- any confidential information sent over public or external networks is encrypted
- firewall and virus scanning software is in place to mitigate against unauthorized modification, loss, access or disclosure
7.3.4 Post/Courier- sealed envelope - marked confidential
8. Record retention
8.1 Physicians retain client records as required by law and professional regulations (please refer to your College guidelines).
8.2 The Canadian Medical Protective Association (C.M.P.A.) advises members to retain their medical records for at least 16 years from the date of last entry or, in the case of minors, 16 years from the time the client would have reached the age of majority (age 18 or 19 in all jurisdictions).
8.3 Physicians use secure offsite record storage (locked, fireproof, etc) if required
8.4Some colleges advise physicians that claims may arise beyond the stipulated regulatory period, and therefore may want to keep their records longer, particularly if they are aware of a potential claim.
9. Procedures for secure disposal/destruction of personal information
9.1 When information is no longer required, it is destroyed according to set procedures that govern the storage and destruction of personal information (please refer to your College guidelines).
9.1.1 Physicians use the following methods to destroy/dispose of paper records According to provincial/territorial college regulations shredding
9.1.2 Physicians use the following methods to destroy/dispose of electronic records: Physicians seek expert advice on how to dispose of electronic records and hardware. At a minimum, Physicians ensure that all information is wiped clean where possible prior to disposal of electronic data storage devices (e.g., surplus computers, internal and external hard drives, diskettes, tapes, CD-ROMs, etc.) properly disposed of computer hard drive destroy all other electronic media storage (diskettes, CD-R, DVD)
9.2 Disposal log
- Before the secure disposal of a health record, physicians maintain a log with the client's name, the time period covered by the destroyed record, the method of destruction and the person responsible for supervising the destruction (if applicable).
10. Access to information
10.1 clients have the right to access their record in a timely manner.
10.2 If a client requests a copy of their records, one will be provided at a reasonable cost (please refer to your College guidelines for non-insured services).
10.3 Access shall only be provided upon approval of the physician.
10.4 If the client wishes to view the original record, one of our staff must be present to maintain the integrity of the record, and a reasonable fee may be charged for this access.
10.5 Clients can submit access requests in writing via email to our office firstname.lastname@example.org.
10.6 This office follows specific procedures to respond to access requests we acknowledge receipt of request we respond within a timely fashion 30 days
11. Limitations on access
11.1 In extremely limited circumstances the client may be denied access to their records, but only if providing access would create a risk to that client or to another person.
11.1.1 For example, when the information could reasonably be expected to seriously endanger the mental or physical health or safety of the individual making the request or another person.
11.1.2 Or if the disclosure would reveal personal information about another person who has not consented to the disclosure. In this case, we will do our best to separate out this information and disclose only what is appropriate.
12. Accuracy of information
12.1 We make every effort to ensure that all client information is recorded accurately.
12.2 If an inaccuracy is noted, the client can request changes in their own record, and this request is documented by an annotation in the record.
12.3 No notation shall be made without the approval or authorization of the physician.
13. Privacy Complaints
13.1 It is important to us that our privacy policies and practices address client concerns and respond to client needs.
13.2 A client who believes that this office has not responded to their access request or handled their personal information in a reasonable manner is encouraged to address their concerns first with their doctor.
13.2.1 Client complaints can be made - verbally - in writing
13.2.2 This office follows specific procedures for responding to client complaints - Our complaints process is readily accessible, transparent and simple to use - Clients are informed of relevant complaint mechanisms
13.3 clients who wish to pursue the matter further are advised to direct their complaints to -provincial/territorial college
Any medical professionals affiliated with assisting our company have sworn to fulfill, to the best of their ability and judgment, this covenant:
CLIENT'S MEDICAL CHART - CONFIDENTIALITY & PRIVACY
NOT GOVERNMENT ISSUED:
HONOUR & INTEGRITY:
REACHING A ROADBLOCK
REFUND POLICY: There are no refunds from ENABLE AIR.
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