Planned Parenthood of Toronto (PPT) is committed to protecting the privacy of our clients, members, donors and the general public and to meeting the requirements of the Ontario Personal Health Information Protection Act and Canada's Personal Information Protection and Electronic Documents Act.
This policy acts as an addendum to PPT's Client Confidentiality and Disclosure Policy that, along with a confidentiality agreement, is signed by all staff and volunteers of PPT.
For the purposes of this policy:
"Personal information" includes any information, recorded or not, that could identify an individual including name, age, weight, height, contact information, identification numbers/certificates, records, race and ethnic origin, religious affiliation and education. Personal information does not include the name, job title, business address or office telephone number of an employee or an organization.
"Health information" includes any identifiable personal information, recorded or not, that relates to the physical or mental health of an individual including medical history, family medical history and health number.
"Clients" refer to any individual who accesses services through PPT programs including The House Community Health Centre, Woman2Woman at the Bay Centre for Birth Control and the Teen Sex Information Program.
"Members" refer to any individual who meets membership eligibility requirements and has paid annual membership fees in full.
"Donors" refer to individuals, organizations and/or corporations that have contributed a monetary gift to PPT and are eligible to receive a charitable tax receipt.
"General Public" refers to any individual, group or institution that may provide PPT will some form of personal information but does not fall into the category of a client, member or donor.
INFORMATION COLLECTED BY PPT
PPT and its programs may collect some or all of the following personal and/or health information from clients, members and donors.
- Name, address, e-mail address, telephone number
- Date of birth
- Health Card number
- Emergency contact
- Spiritual or religious affiliation
- Racial, ethnic, cultural background
- Immigration status
- Living situation
- Medical history and records
The personal and health information of clients is updated and confirmed for accuracy every time a client visits The House Community Health Centre.
Donors and Members
- Name, address, e-mail address, telephone number, fax number
- Credit card number, expiry date and authorizing signature (if applicable)
PPT does not trace phone calls or use Call Display services.
USE OF INFORMATION
PPT uses the personal and health information of clients, members and donors for the following purposes:
- To collect and use personal and health information for the purposes of providing clients with medical and/or social services offered by PPT, its programs and appropriate agents.
- To collect and use personal information for the purposes of corresponding via mail, email or telephone about PPT activities including fundraising initiatives, special events, organizational development initiatives and the annual general meeting. Members are provided with ongoing opportunities to opt in or out of receiving such correspondence.
- To collect and use personal information for the purposes of corresponding via mail, email or telephone about PPT fundraising initiatives including direct mail, special events, in-kind donations, planned giving (opt in/out option provided) and to provide charitable tax receipts. Donors are provided with ongoing opportunities to opt in or out of receiving such correspondence.
- To seek permission for public recognition of contributions.
DISCLOSURE AND NON-DISCLOSURE OF INFORMATION
PPT discloses personal and health information in the following circumstances:
- For purposes of coordinating and/or transferring care among PPT agents and other health care custodians.
- To comply with other authoritative bodies where ethical and/or legal obligations require.
- PPT does not disclose, sell, trade or share the personal information of our members.
- PPT does not sell, trade, share or disclose the personal information of our donors.
In addition to the categories mentioned above, information may be disclosed to some third-party contractors for PPT business purposes only. This includes financial audits, insurance and administrative purposes as necessary and appropriate. In these cases, PPT collects the privacy statements of the third-party contractors and makes these available to clients, members and donors upon request.
PPT may otherwise disclose personal and health information as necessary to meet legal, regulatory and security requirements as permitted or required by law. This includes the following situations:
- If you indicate that you or another person may be a danger to yourself or others;
- In the case of apparent, suspected or potential child abuse;
- If you report sexual abuse by a Regulated Health Care Professional;
- When the court issues a summons for records or testimony;
- If you receive a positive test result for a reportable communicable disease. For a complete list and explanation of reportable communicable diseases, please ask a staff member.
ONLINE INFORMATION COLLECTION
PPT currently operates and manages three web sites: www.ppt.on.ca, www.spiderbytes.ca and www.teachtoronto.ca. PPT does not track Internet provider addresses and does not disclose, sell, trade or share any personal information about visitors to our sites.
Currently, PPT does not collect identifiable personal or health information through our web sites. Most of our web-based transactions are filtered through third-party secured sites or by downloadable documents that can be mailed, faxed or emailed to PPT. PPT includes hypertext links to the privacy policies of the third-party secured sites. However, PPT may from time to time or in the future collect personal information in the following ways and purposes:
- Information surveys and feedback forms
- Responding to "Contact Us" enquiries
- Ordering and/or purchasing PPT resource materials, publications
- Membership applications
- Volunteer applications
- Making donations
The collection and use of personal information for these purposes is covered under the "Use of Personal Information" section in this statement.
Other non-identifiable and statistical information is collected by our web sites through a log file generated by our site hosts and may be shared with funders and other health care custodians as required.
PPT uses sessional ID cookies. A cookie is a piece of data stored on the user's computer tied to information about the user. Usage of a cookie is not linked to any identifying personal information and once users close the browser, the cookie terminates.
MSN Chat and E-mail
Some information, such as an email address, is collected and used by PPT staff when responding to service and information requests through PPT's Email a Question and MSN Chat services. In these cases, personal information is collected and used for the purposes outlined in this statement.
Emails and Chat logs are saved for liability and statistical purposes. PPT does not disclose personal information collected online unless it is required to do so by law. Only authorized staff have access to saved emails and chat logs.
Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be expressed or implied . Consent may also be given by an authorized representative such as a legal guardian or power of attorney. For clients of PPT programs, an expressed consent form is used. For donors and members, PPT will assume that, by providing personal information with your donation and/or completed membership form, you consent to our collection, use and disclosure of such information for the purposes identified in this policy. However, PPT will also provide opportunities for donors and members to opt in or out of such information collection, use and disclosure. As well, for purposes of donor recognition (ie. annual report, PPT web site) PPT will seek explicit consent via telephone, mail or Internet.
You may withdraw your consent to our collection, use and disclosure of personal information at any time by doing so in writing, however, PPT may no longer be able to provide certain clinical services if you choose to do so.
PPT uses the following security measures to protect your information against loss, theft, unauthorized access and disclosure without consent:
- All client information is stored in professionally appropriate, lockable cabinets.
- The cabinets are kept locked during non-operational hours.
- The cabinets containing active client information are located behind a staffed reception desk that is located away from the clinic waiting area.
- Client information stored electronically is password protected.
- Client information that is not legislatively required is promptly shredded.
- Medical charts are kept in a secured location for 10 years after your last visit and/or 10 years after your 18th birthday if greater than the last visit date.
- Charts are disposed of in accordance to the protocols set by the College of Physicians and Surgeons of Ontario.
- Charts that are shredded are done so by a contracted health Records Management disposal firm.
Only authorized employees of PPT who require access to your personal information in order to fulfill their job requirements will have access to your personal information. As well, all employees and volunteers of PPT sign a confidentiality agreement. Client medical records are stored and disposed of according to the protocols set by the College of Physicians and Surgeons of Ontario.
ACCESS, CORRECTION, COMPLAINTS AND CONTACTING ORGANIZATION
PPT may establish and maintain a file of your personal and/or health information for the purposes described in this statement. If you wish to request access to or make a correction of your personal information in our custody or control, you may submit your request in writing to the following:
Planned Parenthood of Toronto
36B Prince Arthur Ave.,
Toronto, ON M5R 1A9
Tel: 416.961.0113 ext. 223
If you believe that your privacy rights are not being respected, suspect your personal information has been improperly collected, used or disclosed, run into any difficulties obtaining access to your personal information or generally believe that PPT is not following the provisions of PIPEDA or the Ontario Personal Health Information Protection Act, you are entitled to file a complaint. The Office of the Privacy Commissioner of Canada recommends that you first try to settle the matter directly with the organization you are filing a complaint against. PPT does have a privacy complaints procedure. You can find out about the procedure and file a complaint by contacting the Privacy Officer of PPT at the address provided above. If you are not satisfied with PPT's response to your complaint you may contact the Office of the Information and Privacy Commissioner/Ontario or the Office of the Privacy Commissioner of Canada at the following addresses:
The Office of the Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
The Office of the Privacy Commissioner of Canada
112 Kent Street
Ottawa, ON K1A 1H3
This privacy statement may be revised from time to time. If PPT intends to use or disclose personal information for purposes not outlined in this statement, we will make reasonable efforts to notify affected individuals in advance if necessary.
Policy approved by PPT Board of Directors: May 7, 2005.