Ottawa Carleton Hearing Aid Dispensary, Cornwall Audiology Clinic and Hawkesbury Audiology Service is committed to protecting the privacy of all personal information that is collected. This information enables us to provide quality personalized audiological services. We are committed to collecting, using and disclosing personal information responsibly and to limit the information we collect to what we need for the efficient provision of diagnostic as well as therapeutic services. We also try to be open and transparent with respect to the policies that govern how we handle all personal information. This document describes our privacy policies.
What is personal information?
Personal information is information about an identifiable individual. Personal information includes information that relates to personal characteristics (gender, age, home address, telephone number, family status), health (health history, health conditions, health services received) and activities and views such as opinions expressed by an individual or an opinion or evaluation of an individual. Personal information is distinct from business information that may include an individual's business address and telephone number. Business information is not protected by privacy legislation.
Who are we?
Ottawa Carleton Hearing Aid Dispensary, Cornwall Audiology Clinic and Hawkesbury Audiology Service is a series of three distinct companies that offer a wide range of clinical audiological services to the residents of Eastern Ontario. These services include diagnostic audiological testing as well as the dispensing of hearing aids and other assistive listening devices. To assist us in providing services we use consultants such as: computer consultants, office security maintenance, accountants, university and/or summer students, leasing companies, cleaners and lawyers who may in the course of their duties have limited access to personal information we hold. 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.
Primary Purposes for Collecting Personal Information
Our primary purpose for collecting personal information is to provide professional audiological care to our clients including the provision of amplifying devices. By way of example, we collect information about your health history that will be relevant to your aural rehabilitation status and that assists us in offering effective intervention options. Another primary purpose is to obtain a baseline of your rehabilitation status and to track changes over time. It would be rare for us to collect such information without your express consent but this may occur in an emergency and when it is impractical to obtain consent e.g. a family member sending a message from you and we have no reason to believe that the message is not genuine.
Other Members of the General Public
Our primary purpose for collecting contact information about members of the public is to make them aware of rehabilitation services in general or our services in particular. We try to obtain consent before using any personal contact information, but where this is not possible, we will, upon request, immediately remove the information from our distribution list.
Information collected from our web site (www.ottawahearing.com and www.cornwallaudiology.com ), will be personal information that you provide and used only for the purpose for which you gave it to us e.g. to respond to your email message.
Regarding Contract Staff, Volunteers and Students
A primary purpose for collecting personal contact information from individuals who are contracted to complete work for us is to ensure that we can get in touch with them for employment purposes to better serve our clients. It is rare for us to collect such information with no 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 e.g. if theft were to occur in our office. We also collect information in order to complete performance appraisals, provide feedback to students' instructors or write references, if requested.
Related and Secondary Purposes for Collecting Personal Information
Ottawa Carleton Hearing Aid Dispensary, Cornwall Audiology Clinic and Hawkesbury Audiology Service also collects, uses and discloses information for purposes related to our secondary or primary purposes. The most common examples are as follows:
- To secure payment for goods and services.
- To advise clients of the need for follow-up services.
- To advise clients and others of special events or opportunities.
- To evaluate our services and the performance of our staff.
- To allow us to meet our regulatory obligations. The College of Audiologists and Speech Language Pathologists of Ontario may inspect our records and interview our staff as part of their regulatory activities in the public interest. Certain government agencies e.g. Canada Customs and Revenue Agency, Privacy Commissioner, Human Rights Commission, have the authority to review our files and interview our staff as part of their mandates.
- To provide information to third-party payers e.g. auto insurance, disability insurance, WSIB, Assistive Devices Program, when they pay for the goods and services that you receive from us such as hearing aids and batteries. We will obtain your consent to disclose your personal information in these instances except in instances where there is legislative authority to collect, use or disclose the information.
- To answer any questions you may have about the service you received once it is concluded. The College of Audiologists and Speech Language Pathologists of Ontario requires that we keep records for at least 10 years following your last intervention or in the case of a child, 10 years past the child's 18th birthday.
- To allow us to provide required information to a prospective purchaser if this practice's assets were to be sold, in order to conduct a due diligence review of our accounting and service files. All the rest of the purchasers who have already agreed to buy the organization's business assets would be provided with access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
If you choose not to be part of some of these related or secondary purposes, please let us know so that we may take the appropriate measures where possible.
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 log or restricted area.
- Electronic hardware is either under supervision or secured in a locked or restricted area. Our computers are password-protected. Our cell phones are digital as the signal is more difficult to intercept. Paper information is sealed and transmitted by reputable companies. All documents containing personal information are labeled "Confidential" and disseminated to restricted individuals for whom you have provided consent to release or transmit information.
- Special care is taken to ensure privacy when transmitting electronic information. Transmissions are encrypted and where we are unsure about the security of the electronic transfer of information, identifying information is removed.
- External consultants and agencies with access to personal information must enter into privacy agreements with us.
Retention and Destruction of Personal Information
As stated previously The College of Audiologists and Speech Language Pathologists requires that we retain our client records for 10 years past a client's last visit or in the case of a child for 10 years past the child's 18th birthday. We destroy your files within three months of that time; these files include your contact information. Contact directories will be updated when practical upon request. Contact information for members of the public is kept for three years unless requests are made to destroy it sooner. 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.
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 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 we cannot give you access, we will tell you within 30 days if at all possible and the reason, as best we can, as to why we cannot grant 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 our professional opinions. We may ask you to provide documentation that our files are incorrect. If 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 the statement from you and will forward that statement to anyone else who received the earlier information.
Do You Have a Question or Concern?
Our information officer is:
Robert Schultz M.A. Reg. CASLPO
Registered Clinical Audiologist
Tel: 613. 567.4847 Fax: 613.567.9401
And can be reached at:
225 Metcalfe St., Suite 414
He will attempt to answer any questions or concerns that you may 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 one 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 body:
College of Audiologists and Speech Language Pathologists of Ontario
3080 Yonge St. Street East, Suite 5060, Toronto, Ontario M4N 3N1
Telephone: 416-975-5347 / 1-800-993-9549 Fax: 416-975-8394