The TRAC Program is committed to
protecting the privacy of all personal information that is
collected to enable us to provide quality rehabilitation services.
In order to achieve this, it is our policy to collect, use
and disclose personal information responsibly, to limit the
information we collect to what we need and to make our policies
available to you. 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 [example: gender, age,
home address, telephone number, family status], health [example:
health history, health conditions, health services received],
and activities and views [example: opinions expressed by an
individual, an opinion or evaluation of an individual]. Personal
information is distinct from business information which may
include an individual’s business address and telephone
number, which is not protected by privacy legislation.
Who are we?
The TRAC Program is a multidisciplinary
rehabilitation program that offers a range of clinical services.
It is an incorporation that utilizes internal and external
service providers for clinical coordination/case management,
speech language pathology, occupational therapy, social work,
physiotherapy, psychological and behavior therapy services
and vocational rehabilitation. To assist us in providing services
we use consultants who may in the course of their duties have
limited access to personal information we hold such as: computer
consultants, office security maintenance, accountants, university
and/or summer students, leasing companies, cleaners and lawyers.
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. Summer students,
university students and volunteers are required to sign a
contract of confidentiality so as to protect the privacy of
the clients of this company.
Primary Purposes for Collecting Personal Information
Our primary purpose for collecting personal information is
to rehabilitation services. For example, we collect information
about your health history that will be relevant to your rehabilitation
status and that assists us in offering effective intervention
options. A primary purpose is also 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 [example: 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.
About Contract Staff, Volunteers and Students
For people who are contracted to complete work for us, a
primary purpose for collecting personal contact information
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 [example: an infectious
disease outbreak] or to investigate a possible breach [example:
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
The TRAC Program also collects,
uses and discloses information for purposes related to our
secondary or primary purposes. The most common examples are
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
To evaluate our services and the performance of our
To allow us to meet our regulatory obligations. The
respective colleges that govern the conduct of our service
providers may inspect our records and interview our
staff as part of their regulatory activities in the
public interest. Certain government agencies [example:
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 [example:
auto insurance, disability insurance, WSIB, Assistive
Devices Program] when they pay for the goods and services
that you receive from us. 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. Many professional
colleges in Ontario require that health care professionals
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 program’s assets
were to be sold, in order to conduct a “due diligence”
review of our accounting and service files. 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
Staff is trained to collect, use and disclose personal
information only as necessary to fulfill their duties
External consultants and agencies with access to
personal information must enter into privacy agreements
with us. A copy of this agreement is available upon
Retention and Destruction of Personal Information
Most colleges governing regulated health practitioners in
Ontario require that we retain our client records for a minimum
of 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 [example: information
deleted] 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
Do You Have a Question or Concern?
Our information officer is:
Christine A. McCool, M.H.Sc., Reg. CASLPO
Registered Speech Language Pathologist
110-161 Greenbank Road
Ottawa, ON K2H 5V6
She 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. She 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.