Privacy and Accessibility

Providing goods, services or facilities to people with disabilities

Accessible Customer Service Policy

Source Centre for Health & Wellness is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code respecting non-discrimination.

Source Centre for Health & Wellness understands that obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its accessibility standards do not substitute or limit its obligations under the Ontario Human Rights Code or obligations to people with disabilities under any other law.

Source Centre for Health & Wellness is committed to complying with both the Ontario Human Rights Code and the AODA.

Source Centre for Health & Wellness is committed to excellence in serving all customers including people with disabilities.

Our accessible customer service policies are consistent with the principles of independence, dignity, integration and equality of opportunity for people with disabilities.

Assistive devices

People with disabilities may use their personal assistive devices when accessing our goods, services or facilities.

In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access our goods, services or facilities.

We will ensure that our staff is trained and familiar with various assistive devices on site or provided by us that may be used by customers with disabilities while accessing our goods, services or facilities.

Communication

We will communicate with people with disabilities in ways that take into account their disability. This may include the following:

  • Over email
  • In writing
  • By telephone
  • In person
  • By any other communication technology as required

We will work with the person with a disability to determine what method of communication works for them.

Service animals

We welcome people with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public.

When we cannot easily identify that an animal is a service animal, our staff may ask a person to provide documentation (template, letter or form) from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability.

A service animal can be easily identified through visual indicators, such as when it wears a harness or a vest, or when it helps the person perform certain tasks.

A regulated health professional is defined as a member of one of the following colleges:

  • College of Audiologists and Speech-Language Pathologists of Ontario
  • College of Chiropractors of Ontario
  • College of Nurses of Ontario
  • College of Occupational Therapists of Ontario
  • College of Optometrists of Ontario
  • College of Physicians and Surgeons of Ontario
  • College of Physiotherapists of Ontario
  • College of Psychologists of Ontario
  • College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario

If service animals are prohibited by another law, we will do the following to ensure people with disabilities can access our goods, services or facilities:

  • explain why the animal is excluded
  • discuss with the customer another way of providing goods, services or facilities

Support persons

A person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.

Treatment fees will not be charged for support persons.

In certain cases, Source Centre for Health & Wellness might require a person with a disability to be accompanied by a support person for the health or safety reasons of:

  • the person with a disability
  • others on the premises

Before making a decision, Source Centre for Health & Wellness will:

  • consult with the person with a disability to understand their needs
  • consider health or safety reasons based on available evidence
  • determine if there is no other reasonable way to protect the health or safety of the person or others on the premises

If Source Centre for Health & Wellness determines that a support person is required, we will waive the treatment fee for the support person.

Notice of temporary disruption

In the event of a planned or unexpected disruption to services or facilities for customers with disabilities, Source Centre for Health & Wellness will notify customers promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.

Services/Facilities include:

  • Chiropractic
  • Acupuncture
  • Registered Massage Therapy
  • Workshops

The notice will be made publicly available in the following ways:

Training

  • Source Centre for Health & Wellness will provide accessible customer service training to:
  • all employees and volunteers
  • anyone involved in developing our policies
  • anyone who provides goods, services or facilities to customers on our behalf.

Staff will be trained on accessible customer service within 90 days after being hired.

Training will include:

  • purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard
  • Source Centre’s policies related to the customer service standard
  • how to interact and communicate with people with various types of disabilities
  • how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person
  • how to use the equipment or devices available on-site or otherwise that may help with providing goods, services or facilities to people with disabilities.
  • What to do if a person with a disability is having difficulty in accessing Source Centre’s goods, services or facilities

Staff will also be trained when changes are made to our accessible customer service policies.

Feedback process

Source Centre for Health & Wellness welcomes feedback on how we provide accessible customer service. Customer feedback will help us identify barriers and respond to concerns.

Customers will be notified of how to provide feedback in the following ways:

Customers who wish to provide feedback on the way Source Centre for Health & Wellness provides goods, services or facilities to people with disabilities can provide feedback in the following way(s):

All feedback, including complaints, will be handled in the following manner:

  1. Feedback will be forwarded to the accessibility director (AD)
  2. AD will work with employees, volunteers, and service providers to identify any accessibility issues, develop solutions and timelines for any policy changes, training, implementation
  3. AD will notify the original customer of the solution and timeline

Customers can expect to hear back in 30 days.

Source Centre for Health & Wellness will make sure our feedback process is accessible to people with disabilities by providing or arranging for accessible formats and communication supports, on request.

Notice of availability of documents

Source Centre for Health & Wellness will notify the public that documents related to accessible customer service, are available upon request by posting a notice in the following location(s)/way(s):

Source Centre for Health & Wellness will provide this document in an accessible format or with communication support, on request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner and, at no additional cost.

Modifications to this or other policies

Any policies of Source Centre for Health & Wellness that do not respect and promote the principles of dignity, independence, integration and equal opportunity for people with disabilities will be modified or removed.

Published: November 20, 2017

Source Centre for Health & Wellness Privacy Policy

General

Privacy of personal information is an important principle to Source Centre for Health and Wellness. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.

Who We Are

Our organization, Source Centre for Health & Wellness includes at the time of writing Chiropractors, and Massage Therapists, and support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, cleaners and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

What Is Personal Information?

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

Collection of Personal Information: Primary Purposes

Personal Information About Clients

Like all health practitioners we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide care for our clients. For example, we may collect information about a client’s health history, including their family history, physical condition and function and social situation in order to help us assess what their health needs are, to advise them of their options and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that are occurring over time. It would be rare for us to collect such information without the client’s express consent, but this might occur in an emergency (e.g., the client is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our client and we have no reason to believe that the message is not genuine).

Personal Information About Members of the General Public

For members of the general public, our primary purpose for collecting personal information is to provide notice of special events (e.g., a seminar, health talk or open house) or to make them aware of our services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.

On our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.

Personal Information About Contract Staff, Volunteers and Students

For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., an infectious disease outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If contract staff volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.

Collection of Personal Information: Related and Secondary Purposes

Personal Information About Clients

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 goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
  • To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new product) 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. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our Clinic, including reviewing client files and interviewing our staff.

Most of our practitioners are regulated by Colleges in Ontario, such as the College of Chiropractors of Ontario, who may inspect our records and interview our 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. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the 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. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.

The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., OHIP, WSIB, private insurance, Assistive Devices Program). 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 or 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 seven years after the last contact to enable us to respond to those questions and provide these services Our regulatory Colleges also require us to retain our client records.

If Source Centre for Health & Wellness 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 agree 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 directing 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).

You Can Look At Your Information

With only a few exceptions, you have the right to see what personal information we hold about you. 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 this 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 and signed. 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 have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.

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.
  • Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
  • Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
  • External consultants and agencies with access to personal information must enter into privacy agreements with us.

Disclosure and Release of Personal Information

In addition to the measures taken to protect your personal information listed above, we have a policy regarding the disclosure and release of personal information. In general, we will not disclose or release any personal information to a third party. There are however, specific circumstances where we may be required to do so by law and will act in accordance with the legislation that governs. Also, with only a few exceptions, you are entitled to a copy of your file and the information we maintain about you. To obtain a copy of some or all of the personal information that we have on record about you, we require a formal written request, signed by you. Upon receipt and confirmation of such a request, we will either mail the documents to the address specified by you, or arrange a time to release the information to you in person. We reserve the right to charge a nominal fee for such requests.

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.

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 the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information longer than necessary in order to protect your privacy.

We keep our client files for at least seven 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. We keep any personal information relating to our general correspondence (i.e., with people who are not clients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar of marketing activity is over.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or all of the client file to our client.

Do You Have A Question?

Our primary information Officer, Dr. Leo Quan can be reached at:

202 – 326 Adelaide Street West

Toronto, ON M5V 1R3

Phone (416) 923-4325

He will attempt to answer any questions or concerns you might have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory bodies:

College of Chiropractors of Ontario

130 Bloor Street West,#902

Toronto, ON M5S 1N5

College of Naturopaths of Ontario

163 Queen Street East, 4th Floor

Toronto, ON M5A 1S1

College of Massage Therapists of Ontario

1867 Yonge Street, Suite 810

Toronto, Ontario M4S 1Y5

Traditional Council of the College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario

163 Queen Street East, 4th Floor

Toronto, ON M5A 1S1

Council of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario

163 Queen Street East, 4th Floor

Toronto, ON M5A 1S1

This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Health Information Protection Act (PHIPA).

These are complex Acts and provide additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.

For inquiries about the Personal Information Protection and Electronic Documents Act, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Privacy Commissioner can be reached at:

112 Kent Street

Ottawa, Ontario K1A 1H3

Phone: (613) 947-1698

Toll-free: 1-800-282-1376

Fax: (613) 947-6850

TTY: (613)992-9190

www.privcom.gc.ca

For inquiries about the Personal Health Information Protection Act, the Information and Privacy Commissioner/Ontario protects the privacy of individuals with respect to their personal health information held by health information custodians. The Information and Privacy Commissioner can be reached at:

2 Bloor Street East, Suite 1400

Toronto, Ontario

Canada M4W 1A8

416-326-3333

1-800-387-0073

Fax : 416-325-9195

TTY (Teletypewriter) : 416-325-7539

Website : www.ipc.on.ca