SHORE Centre is committed to safeguarding the personal information entrusted to us by our clients, program participants, volunteers, staff, and donors. We manage your personal information in accordance with Ontario’s Personal Health Information Protection Act and other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information.
This policy applies to SHORE Centre and to any person providing services on our behalf. A copy of this policy is provided to anyone on request and is posted to our website.
What is personal information?
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, gender, health history, an identifying number (health card, insurance information), financial information, educational history, etc.
What personal information do we collect?
We collect only the personal information that we need for the purposes of providing services to our clients, program participants, volunteers, staff, and donors, including personal information needed to:
• deliver client healthcare, services and programming
• provide services and programming with community partners
• submit referrals on behalf of clients
• communicate with donors and volunteers
• employ and manage staff and volunteers
We normally collect client, program participant, volunteer, staff, or donor personal information directly from them. We may collect your information from other persons with your consent or as required or authorized by law.
There are some exceptional circumstances when we cannot maintain strict confidentiality because of ethical or legal requirements, such as:
• When records are required by law (eg. Courts)
• When a SHORE Centre employee or volunteer suspects child abuse or neglect.
• When there is a need to intervene to prevent serious harm to yourself or someone else.
• When we are required according to Canada’s Legal Age of Consent to Sexual Activity laws.
We inform our clients, program participants, volunteers, staff, or donors, before or at the time of collecting personal information, and of the purposes for which we are collecting the information.
Consent
We ask for written consent to collect, use or disclose your personal information, except in specific circumstances where collection, use or disclosure without consent is authorized through “circle of care” or required by law. When accessing healthcare services at SHORE Centre you authorize the collection of your personal and medical information as it relates to the healthcare services you are seeking. Additionally, you authorize SHORE Centre and its associated healthcare professionals to communicate with other healthcare practitioners as it relates directly to your care and is beneficial to your treatment (eg. family doctor, referring doctor, nurse practitioner, hospital, walk-in clinic, laboratory, diagnostic imaging clinic, pharmacist, etc…). I also understand that my personal and medical information is confidential and will only be disclosed to third parties with my permission.
We assume your consent to continue to use and, where applicable, disclose personal information that we have already collected, for the purpose for which the information was collected.
A client, program participant, volunteer, staff, or donor may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain services if we do not have the necessary personal information.
How do we use and disclose personal information?
We use your personal information only for the purpose for which the information was collected, except as authorized or required by law.
We do not publish the names of our clients, program participants, volunteers, or donors without their written consent.
We may disclose non-identifying information on our clients, program participants, volunteers, staff, and donors. This information includes the combining of multiple client stories into a client example story and demographic information.
If we wish to use or disclose your personal information for any new purpose, we will ask for your consent.
How do we safeguard personal information?
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.
We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
We retain personal information only as long as is reasonable to fulfil the purposes for which the information was collected. Employee and donor records are kept indefinitely.
Access to records containing personal information
Individuals have a right to access their own personal information in a record that is in the custody or under the control of SHORE Centre subject to some exceptions. If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record. You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. In addition, you may request a correction of an error or omission in your personal information.
You may make a request for access to your personal information by writing to the Executive Director or Board President. You must provide sufficient information in your request to allow us to identify the information you are seeking. We will respond to your request within 45 calendar days.
SHORE Centre does not directly share information about your visit with other healthcare providers, however blood work and ultrasounds you have done may, prescriptions you fill, or hospital visits you have may be included as part of your Electronic Health Record (EHR).
If you have received healthcare services at SHORE Centre and are worried about another health care professional having access to that information please visit the E-Health Ontario website to learn more managing your EHR to limit other healthcare provider access to your information.
You can also contact E-Health Ontario at anytime by calling 1-866-250-1554 or servicedesk@ehealthontario.on.ca:
• If you don’t want to share information with any or all of your health care providers
• To receive copies of your information
• To request a correction to your information
• For any privacy and security questions or requests
Virtual Care
In response to COVID-19 and public health recommendations and guidelines, SHORE Centre is limiting in-person appointments at this time. Where possible, all appointments and communication will be conducted remotely using email, Zoom, Jane or Doxy.
Personal health information shared by video and email communication may be less secure due to risks associated with third-party data collection and internet security.
You are responsible for reviewing the privacy information available on the websites for Zoom, Jane, Doxy.me as well as the privacy information for your email and Internet Service providers (eg. Rogers, Bell, Microsoft, Google, Yahoo, etc…)
We require that you provide your consent to continue with using a potentially insecure form of communication for your appointment(s).
Email Communication
The following is SHORE Centre’s Uses of Email Communication Policy. All clients of SHORE Centre will be asked to review and agree to this policy when they become a client.
Uses of Email Communication
Email communication will not be used to communicate individual medical information in any capacity. Email communication SHORE Centre is restricted to the following uses:
● Scheduling appointments (including rebooking and cancellation)
● Providing directions (to clinic location and other facilities)
● Providing practice policies & protocols (e.g. privacy policy, referrals, etc.)
● Providing general educational and health promotion electronic documents, resources, and links
Email communication with SHORE Centre is not to be used for emergency or urgent medical concerns. If you are experiencing a medical emergency contact 911 or visit your nearest emergency department.
Risks of Using Electronic Communication
SHORE Centre cannot guarantee the security and confidentiality of electronic communications. Please consider the following risks of using email communication:
● Despite reasonable efforts to protect the privacy and security of electronic communication, it is not possible to completely secure the information
● Employers and online services may have a legal right to inspect and keep electronic communications that pass through their system
● Electronic communications can introduce malware into a computer system and potentially damage or disrupt the computer, networks, and security settings
● Electronic communications can be forwarded, intercepted, circulated, stored, or even changed without the knowledge or permission of the physician or the patient
● Even after the sender and recipient have deleted copies of electronic communications, back-up copies may exist on a computer system
● Electronic communications may be disclosed in accordance with a duty to report or a court order
● Electronic communication can be misdirected, resulting in increased risk of being received by unintended and unknown recipients
● Electronic communication can be easier to falsify than handwritten or signed hard copies. It is not feasible to verify the true identity of the sender, or to ensure that only the recipient can read the message once it has been sent
Email Communication Protocols & Practices:
● Emails will only be checked during clinic office hours
● Emails will be triaged and answered according to internal clinic prioritization
● While we will strive to return all email queries within 48 hours, we cannot guarantee this time frame
● It is the responsibility of the patient to follow up on all email communications
● No medical information or advice will be given or disclosed via email
● Do not submit any attachments to an email unless specifically directed to do so as part of your communication with SHORE Centre
● Email communication with SHORE Centre must be limited to the aforementioned uses
Instructions for Email Communication:
● Reasonably limit or avoid using an employer’s, school’s, or other third party’s computer
● Inform SHORE Centre within 5 business days of any changes in the your email address
● Include an appropriate and descriptive message subject line
● Include your full name in the body of the message
● Keep your email short and concise – if you require assistance with a more complex matter, please call or visit SHORE Centre
● Do not include any attachments unless requested by your health care provider
● Refrain from using offensive language or using online communication for frivolous or commercial purposes
Questions and complaints
If you have a question or concern about any collection, use or disclosure of personal information by SHORE Centre, or about a request for access to your own personal information, please contact the Executive Director or Board President.
If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Ontario.