The Therapy Path is committed to protecting the privacy of all personal information that is collected to enable us to provide quality speech, language and hearing care to you.  In order to achieve this, it is our policy to collect, use and disclose personal information responsibly, 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 (e.g., gender, age, home address or phone number, ethnic background, family status), health (e.g., health history, health conditions, health services received) or activities and views (e.g. opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

Who We Are

The Therapy Path includes at the time of writing two speech-language pathologists. To assist us in providing services, we use consultants that may, in the course of their duties, have limited access to personal information we hold, such as: computer consultants, office security and maintenance, bookkeepers and accountants, 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.

primary purposes for personal collecting information

About Patient/Clients

Our primary purpose for collecting personal information is to provide speech language and hearing services. For example, we collect information about a your health history that will be relevant to communication disorders and assist us in offering effective intervention options.  A second primary purpose is to obtain a baseline of your communication skills or hearing to track how that changes over time.  It would be rare for us to collect such information without your express consent, but this might occur in an emergency (e.g., the patient/client is unconscious) or where we believe you would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from you and we have no reason to believe that the message is not genuine).

About Members of the General Public

Our primary purpose for collecting contact information about members of the public is to make them aware of speech, language and hearing 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.

On our website we only collect the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message).  Any information inadvertently collected will only be used to help you navigate our website (e.g., a website “cookie”).

About Contract Staff, Volunteers and Students

For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal contact information is to ensure we can get in touch with them for employment purposes to better serve our patient/clients.   It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., an infectious disease outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in our office). We also collect information in order to do performance appraisals, provide feedback to students’ instructors or write references if requested.  

Related and Secondary Purposes for collecting personal information

The Therapy Path also collects, uses and discloses information for purposes related to or secondary to our primary purposes. The most common examples are as follows:

q       To secure payment for goods or services.

q       To advise patient/clients of the need for follow-up services.

q       To advise patient/clients and others of special events or opportunities (e.g., a seminar, a new service, a new hearing aid or other product).

q       To evaluate our services and the performance of our staff. This may involve external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) to do audits and continuing quality improvement reviews of our services, including reviewing patient/client files and interviewing our staff.

q       To allow us to meet our regulatory obligations. The College of Audiologists and Speech-Language Pathologists may inspect our records and interview our staff as a part of their regulatory activities in the public interest. Various government agencies (e.g., Canada Customs and Revenue Agency, Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. External regulators have their own strict privacy obligations.  In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.

q       To provide information to third party payers (e.g., OHIP, WSIB, private insurance, Assistive Devices Program) when they pay for the goods and services 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.

q       To answer any questions you may have about the service you received once it is concluded.  The College of Audiologists and Speech-Language Pathologists requires that we keep records for at least 10 years following your last intervention or in the case of a child, 10 years past the child’s 18^th birthday.

q       To allow us to provide required information to a prospective purchaser if this practice or its assets are to be sold, in order to conduct a “due diligence” review of our accounting and service files. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided 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:

q       Paper information is either under supervision or secured in a locked or restricted area.

q       Electronic hardware is either under supervision or secured in a locked or restricted area. Our computers are password protected. Our office phones are cord phones and our cell phones are digital as these signals are more difficult to intercept.

q       Paper information is sealed and transmitted by reputable companies.

q       Special care is taken to ensure privacy when transmitting electronic information.  Where we are unsure of the security of the electronic transfer of information, identifying information is removed.

q       Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.

q       External consultants and agencies with access to personal information must enter into privacy agreements with us.

Retention and Destruction of Personal Information

The College of Audiologists and Speech-Language Pathologists of Ontario requires that we retain our patient/client records for 10 years past the last visit or in the case of a child, for 10 years past the child’s 18^th birthday.  We destroy our files within three months of that time.  These files include your contact information. Contact information for members of the public is kept for 3 years unless requested to do so earlier.

We destroy paper files containing personal information by shredding or burning. 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 tell you the reason, as best we can, as to why we 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 our professional opinions. We may ask you to provide documentation that our files are wrong. Where 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 a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.

Do You Have a Question or a concern?

Our partners, John Stark or Cindy Wilson, Speech-Language Pathologists can be reached at:

7Balsam St. South | Timmins, ON | P4N 2C7      PHONE (705) 267-2270

They will attempt to answer any questions or concerns you might have.