Personal information includes information that relates to:

- An individual’s personal characteristics (gender, age, home address or telephone number, ethnic background, family status, etc);
- Health (e.g., health history, health conditions, health services received by them);
- Activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual).
-Under PHIPA, as your health care provider I am considered your Health Information Custodian (HIC), so please reach out to me with any PHI concerns or complaints.

Like all professionals, I collect, use and disclose personal information in order to serve my clients. The primary purpose for collecting personal information is to provide treatment. For example, I collect information about a client’s health history, including their family history, physical condition, function and social situation in order to help me assess what their health needs are, to advise them of their options and then to provide the health care they choose to have.

Like most organizations, I also collect, use and disclose information for purposes secondary to my primary purposes. The most common examples of my related and secondary purposes are as follows:

To invoice clients for goods or services that was not paid for at the time, to process credit card payments or to collect unpaid accounts.

I review clients and other files for the purpose of ensuring that I provide high quality services. In addition, external consultants (e.g., auditors, practice consultants) may on my behalf do audits and continuing quality improvement reviews of my Clinic, including reviewing client files.

Registered Massage Therapists are regulated by the College of Massage Therapists of Ontario (CMTO). The CMTO may inspect my records as a part of their regulatory activities in the public interest. Also, my 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 my clients, or other individuals, to support the concern (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review my files as a part of their mandates. In these circumstances, I may consult with professionals (e.g., Lawyers, Accountants) who will investigate the matter and report back to me.

Clients or other individuals I deal with may have questions about my goods or services after they have been received. I retain my client information for a mandatory minimum of ten years after the last contact to enable me to respond to those questions and provide these services.

I understand the importance of protecting personal information. For that reason, I have taken the following steps:

-Paper information is either under supervision or secured in restricted area.
-Electronic hardware is either under supervision or secure in a restricted area at all times. Your PHI is stored and protected through Jane Scheduling Software, a Canadian company that stores your PHI in Canadian servers.
-Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
-Electronic information is transmitted either through a direct line or has identifiers removed or is encrypted.
-External consultants and agencies with access to personal information must enter into privacy agreements with me.

I need to retain personal information for some time to ensure that I can answer any question the client may have about the services provided and for my own accountability to external regulatory bodies. I keep my clients files for 10 years according to my College regulations. I destroy paper files containing personal information by shredding. I destroy electronic information by deleting it and, when the hardware is discarded, I ensure that the hard drive is physically destroyed.

With only a few exceptions, you have the right to see what personal information I hold about you.

I can help you identify what records I might have about you. I will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). I will need to confirm your identity, if I do not know you, before providing you with this access. I reserve the right to charge a nominal fee for such requests.

If there is a problem I may ask you to put your request in writing. If I cannot give you access, I will tell you within 30 days if at all possible and tell you the reason, as best I can, as to why I 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 I may have formed. I may ask you to provide documentation that my files are wrong. Where I agree that I made a mistake, I will make the correction and notify anyone to whom I have sent this information. If I do not agree that I have made a mistake, I will still agree to include in my file a brief statement from you on the point and I will forward that statement to anyone else who received the earlier information.

To make a complaint about the mishandling of your Personal Health Information (PHI) in Ontario, you must first address your concerns with the healthcare organization that holds your records. If the issue is not resolved, you can then file a formal complaint with the Information and Privacy Commissioner of Ontario (IPC).