Respecting the privacy of our clients’ personal information is an important part of the work we do at The Vitanova Foundation. To that end, we are committed to collecting, using, and disclosing such information only as prescribed by law, and in a manner that is both open and transparent.
Our list of Clients’ Rights includes the right “…to personal personal privacy, and to have information shared with staff treated as confidential, except as may be required by law, or for purposes that do not involve client-specific indicators.”
In recognition of that right, we have developed the following policies and practices.
- Practices to protect privacy and safeguard personal information
Obtaining the consent of a client:
When a client is admitted to our day-treatment program, the intake worker or the client’s primary counselor will request that the client sign consent forms that will allow the counselor to speak with people that are part of the client’s support circle. The client has the right to choose for whom he/she would like to give consent. It is the client’s right to refuse to provide consent that would allow his/her primary counsellor to share the client’s personal health information in some cases. Clients also have the right to revoke consent at any time. There may be times when a client is uncomfortable sharing all details to those that the client has given consent to the primary counselor to speak to. The client can choose to `lock` certain parts of his/her personal health information (e.g., require a counsellor not to disclose certain information to the client’s parents, etc.)
Preventing unauthorized access to all types of client information:
Vitanova uses closed servers and protected databases for storing client information. As well, all hard copies of client information are stored in double locked areas.
System to track clients’ withdrawal of consent:
In the event that a client revokes or rescinds his/her consent, his/her primary counselor will make a note in the client’s record, void the consent form, and inform all other staff.
Notifying clients in the case of unauthorized theft, loss, access to, use or disclosure of client information:
Clients will be notified either by mail or at their next appointment in the case of unauthorized theft, loss, access to, use or disclosure of client information.
Client Access to Client Files
Clients are able to access a copy of the documents in their files for purposes of review within thirty (30) days of the request, or sixty (60) days in the case of complex searches. Clients can request a correction of any information in their file or obtain a copy of the contents of their files However, clients must be aware that Vitanova is unable to release any third party information held in the file (i.e., information in one client’s file that may identify another client). Lastly, clients can request assistance in interpreting their files.
- Circumstances in which information may be disclosed
There are circumstances in which client information may be disclosed:
- For purposes of research, providing that client-specific indicators are deleted
- Quality improvement, providing client-specific indicators are deleted
- Routine management and professional supervision of staff
- Responding to a police request of information; there may be a time when police request personal information about a client. In the event that a warrant or subpoena is issued for a client’s records, Vitanova is legally bound to provide information to the police. Vitanova may seek legal advice on this matter if there is any uncertainty about the request.
- How to contact Vitanova’s privacy contact person
The initial contact person regarding all privacy matters is the Program Director who can be contacted at 905-850-3690, extension 231 or via email to the attention of the program director at email@example.com.
- Procedure for making a complaint regarding a breach of privacy
If anyone has a concern and/or wishes to make a complaint to us about our privacy practices, including any questions or concerns about the contents of his/her personal file, a request must be made in writing, addressed to the Privacy Officer (who is the Executive Director) and delivered by hand or via post, facsimile, or electronic mail (to firstname.lastname@example.org). Please ensure that the request is directed specifically to The Privacy Officer.
The Privacy Officer will acknowledge your concern/complaint in writing, and will ensure that it is thoroughly investigated. As well, you will be provided with a formal decision in writing, including the reason for the decision, in a timely fashion.
If you are dissatisfied with the decision you may appeal it to the Board of Directors of The Vitanova Foundation. Depending on the time between your appeal to the Board and its next meeting, your appeal may be expedited by the Executive Committee of the Board, or by the Chair of the Board alone.
If you are dissatisfied with the outcome of your appeal, you may seek further information, from the Privacy Commissioner of Canada, at 112 Kent Street, Ottawa K1A 1H3 (Toll free telephone: 1-800-282-1376; facsimile 1-613-947-6850).
Vitanova’s privacy policies and procedures—copies of which are available on request from the Executive Director or his/her delegate—comply with the federal government’s Personal Information Protection and Electronic Documents Act (PIPEDA).