Privacy Notice
This notice describes how personal health information (information) about you may be used, collected and shared and how you can get access to this information. Please review it carefully.
Our Legal Responsibility
As one of your care providers, we are legally required to protect the privacy of your information. We collect information about you directly from you or from the person acting on your behalf. The information that we collect may include, for example, your name, date of birth, address, health history, record of your visits and the support you received during those visits.
We also may collect information about you from other sources if we have obtained your consent to do so or if the law permits us to do so. We make sure that only those people who need to see your information are allowed to look at it. We protect your information through our administrative policies and by adopting appropriate safeguards and security measures.
Your information includes data that identifies you and reports about the care and services you receive at any of the sites of the Minto-Mapleton Family Health Team clinics and physicians’ offices. Your record is our property, but the information in your file belongs to you and you may request to view your information at any time.
This notice applies to information in all forms – verbal, written and electronic. It includes all information created by anyone in any of our offices. As a provider of health care services, we are committed to protecting the privacy, confidentiality and security of all information, regardless of whether it is in verbal, written or electronic form.
Use Of Personal Health Information
We collect, use and share information to:
Your Rights Regarding Your Personal Health Information (PHI)
You have a right to make choices and control how your information is collected, used, and shared, subject to some limits.
There is no magic age when you become able to make your own decisions about your information. You may make your own decisions if you are “capable”. Your physician or other care provider will decide if you are capable based on a test the law sets out. You may be capable of making some decisions and not others. If you are not capable – you will have a substitute decision-maker (often your parent(s) or guardian) who will make your information decisions for you. Who can act as a substitute decision-maker and what they have to do is also set out in law.
If you are under the age of 16, there are some additional rules to know. If you are capable to make your own information decisions, your parent(s) or guardian will also be allowed to make some decisions about your health record. But they won’t be able to make decisions about any records about treatment or counseling where we asked for your permission alone. We encourage you to share information with your family to have supports you need. And we also encourage you to ask your health care provider questions to find out more about privacy and your family.
We assume that when you come to have health care from us, you have given us your permission (your consent) to use your information, unless you tell us otherwise. We may also collect, use and share your information in order to talk with other health care providers about your care unless you tell us you do not want us to do so.
You have the right to ask that we not share some or all of your information with one or more of our team members or ask us not to share your information with one or more of your external health care providers (such as a specialist). This is known as asking for a “lockbox”.
There are other cases where we are not allowed to assume we have your permission to share information. We may need permission to communicate with any family members or friends with whom you would like us to share information about your health (unless someone is your substitute decision-maker). For example, we will also need your permission to give your information to your school or your boss or to an insurance company. If you have questions, we can explain this to you.
When we require and ask for your permission, you may choose to say no. If you say yes, you may change your mind at any time. Once you say no, we will no longer share your information unless you say so. Your choice to say no may be subject to some limits.
BUT there are cases where we may collect, use or share your information without your permission, as permitted or required by law. For example, we do not require your permission to use your information for billing, risk management or error management, quality improvement purposes. We also do not need your permission to share your information to keep you or someone else safe (it’s called to eliminate or reduce a significant risk of serious bodily harm); or to meet reporting obligations under other laws such as for child protection.
For More Information, Comments Or Complaints
We encourage you to contact us with any questions or concerns you might have about our privacy practices. You can reach the MMFHT Privacy Officer, Shirley Borges at:
Minto-Mapleton Family Health Team
Phone 519-638-2110
11 Andrews Drive West
Drayton ON N0G 1P0
If, after contacting us, you feel that your concerns have not been addressed to your satisfaction, you have the right to complain to the Information and Privacy Commissioner of Ontario. The Commissioner can be reached at: 1-800-387-0073 or visit the IPC website @ www.ipc.on.ca
Our Legal Responsibility
As one of your care providers, we are legally required to protect the privacy of your information. We collect information about you directly from you or from the person acting on your behalf. The information that we collect may include, for example, your name, date of birth, address, health history, record of your visits and the support you received during those visits.
We also may collect information about you from other sources if we have obtained your consent to do so or if the law permits us to do so. We make sure that only those people who need to see your information are allowed to look at it. We protect your information through our administrative policies and by adopting appropriate safeguards and security measures.
Your information includes data that identifies you and reports about the care and services you receive at any of the sites of the Minto-Mapleton Family Health Team clinics and physicians’ offices. Your record is our property, but the information in your file belongs to you and you may request to view your information at any time.
This notice applies to information in all forms – verbal, written and electronic. It includes all information created by anyone in any of our offices. As a provider of health care services, we are committed to protecting the privacy, confidentiality and security of all information, regardless of whether it is in verbal, written or electronic form.
Use Of Personal Health Information
We collect, use and share information to:
- Treat and care for you
- Provide appointment or preventative care reminders and/or send patient surveys to you
- Update you of upcoming events, activities and programs
- Deliver and evaluate our programs
- Plan, administer and manage our internal operations
- Be paid or process, monitor, verify or reimburse claims for payment
- Conduct risk management, error management and quality improvement activities
- Dispose of your information
- Seek your permission (or permission of a substitute decision maker) where appropriate
- Respond to or initiate proceedings
- Conduct research (subject to certain rules)
- Compile statistics
- Allow for the analysis, administration and management of the health system
- Comply with legal and regulatory requirements
- Fulfill other purposes permitted or required by law
Your Rights Regarding Your Personal Health Information (PHI)
You have a right to make choices and control how your information is collected, used, and shared, subject to some limits.
There is no magic age when you become able to make your own decisions about your information. You may make your own decisions if you are “capable”. Your physician or other care provider will decide if you are capable based on a test the law sets out. You may be capable of making some decisions and not others. If you are not capable – you will have a substitute decision-maker (often your parent(s) or guardian) who will make your information decisions for you. Who can act as a substitute decision-maker and what they have to do is also set out in law.
If you are under the age of 16, there are some additional rules to know. If you are capable to make your own information decisions, your parent(s) or guardian will also be allowed to make some decisions about your health record. But they won’t be able to make decisions about any records about treatment or counseling where we asked for your permission alone. We encourage you to share information with your family to have supports you need. And we also encourage you to ask your health care provider questions to find out more about privacy and your family.
We assume that when you come to have health care from us, you have given us your permission (your consent) to use your information, unless you tell us otherwise. We may also collect, use and share your information in order to talk with other health care providers about your care unless you tell us you do not want us to do so.
You have the right to ask that we not share some or all of your information with one or more of our team members or ask us not to share your information with one or more of your external health care providers (such as a specialist). This is known as asking for a “lockbox”.
There are other cases where we are not allowed to assume we have your permission to share information. We may need permission to communicate with any family members or friends with whom you would like us to share information about your health (unless someone is your substitute decision-maker). For example, we will also need your permission to give your information to your school or your boss or to an insurance company. If you have questions, we can explain this to you.
When we require and ask for your permission, you may choose to say no. If you say yes, you may change your mind at any time. Once you say no, we will no longer share your information unless you say so. Your choice to say no may be subject to some limits.
BUT there are cases where we may collect, use or share your information without your permission, as permitted or required by law. For example, we do not require your permission to use your information for billing, risk management or error management, quality improvement purposes. We also do not need your permission to share your information to keep you or someone else safe (it’s called to eliminate or reduce a significant risk of serious bodily harm); or to meet reporting obligations under other laws such as for child protection.
For More Information, Comments Or Complaints
We encourage you to contact us with any questions or concerns you might have about our privacy practices. You can reach the MMFHT Privacy Officer, Shirley Borges at:
Minto-Mapleton Family Health Team
Phone 519-638-2110
11 Andrews Drive West
Drayton ON N0G 1P0
If, after contacting us, you feel that your concerns have not been addressed to your satisfaction, you have the right to complain to the Information and Privacy Commissioner of Ontario. The Commissioner can be reached at: 1-800-387-0073 or visit the IPC website @ www.ipc.on.ca
Accessible Customer Service
A. BACKGROUND
The Minto-Mapleton Family Health Team (MMFHT) is committed to providing client-centred service.
The MMFHT wants to ensure that it complies with Provincial standards to provide accessible customer service to all our clients, including those with a disability.
Provincial Accessibility Standards
The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) was passed by the Ontario Legislature with the goal of creating standards to improve accessibility across the province in five areas:
· Customer Service
· Information and Communication
· Transportation
· Employment
· Built Environment
The Accessibility Standards for Customer Service is the first of the five standards and will take effect on
Jan. 1, 2012. This standard details specific requirements for service providers such as the Family Health Team.
The following is a summary of the key requirements of the Accessibility Standards for Customer Service:
1. Establish policies, practices and procedures for providing goods or services to people with disabilities.
2. Communicate with a person with a disability in a way that takes their disability into account.
3. Set a policy to allow people to use their own personal assistive devices to access our goods or services.
4. Allow people with disabilities to be accompanied by their guide dog or service animal in those areas of our premises that are open to the public, unless the animal is excluded by law.
5. Permit people with disabilities who use a support person to bring that person with them while accessing goods or services in premises open to the public or third parties.
6. Train staff, volunteers, contractors and any other people who interact with the public or other third parties on our behalf on a number of topics as outlined in the Customer Service Standards.
7. Establish a process for people to provide feedback on how you provide goods or services to people with disabilities. Also outline how you will respond to any feedback and take action on complaints.
8. Provide notice when facilities or services that people with disabilities rely on are unavailable.
B. PURPOSE
This policy establishes that goods and services provided by the MMFHT shall be provided to persons with disabilities and all clients in accordance with the following key principles:
- Dignity: Service is provided in a respectful manner consistent with the needs of the individual.
- Independence: Services for persons with disabilities shall support their independence while respecting their right to safety and personal privacy.
- Equity/Equality of Outcome: Service outcome is the same for persons with disabilities as for persons without disabilities.
- Integrated: Services allow people with disabilities to fully benefit from the same services, in the same place, and in the same or similar way as other clients.
In addition to the above key principles as provided for in the Customer Service Standard, the MMFHT will be:
- Sensitive: Service is provided in a manner that is respectful to an individual’s needs.
- Responsive: Service is delivered in a timely manner, considering the nature of the service and the accommodation required. For example, if needed, alternate formats will be provided by a specific deadline.
C. SCOPE
The subject policy is delivered in accordance with the Accessibility for Ontarians with Disabilities Act, 2005, and Regulation 429/07 Accessibility Standards for Customer Service, and is applicable to all policies, procedures and processes of the MMFHT.
D. PROCEDURES
1. Assistive Devices
Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. In the event a person with a disability is hindered from accessing goods or services and after consulting with the client, the MMFHT will accommodate the client by using any other assistive measures available.
2. Service animals
Service animals, such as but not limited to Guide dogs, Hearing dogs, Seizure Response dogs, other certified service animals shall be permitted entry to all MMFHT facilities and meeting rooms which are open to the public. A service animal is defined as: “Any animal where it is readily apparent that the animal is used by the person for
reasons relating to his or her disability and if the person provides a letter from a physician or nurse or other government issued certification confirming that the person requires the animal for reasons relating to the disability.”
Service animals are not permitted:
· Where food preparation is being undertaken; or
· as otherwise disallowed by law.
Where a Service Animal is to be denied access to a facility or meeting room, other accommodations may be afforded, such as:
· alternate meeting format, such as teleconference/videoconference, where technology permits;
· deliver the goods or service at an alternate time or location;
· any other assistive measures available to deliver a good or service to ensure equality of outcome.
Owners of Service Animals may receive information from staff as to the location of fresh water for the service animal and where service animals may be walked to relieve themselves.
3. Support Persons
Support Persons shall be permitted entry to all MMFHT facilities and meeting rooms which are open to the public. Where a Support Person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises, the person with a disability shall be accompanied by a Support Person when on the premises. The client shall determine whether a Support Person is necessary, however where an employee believes that a Support Person should be in attendance to protect the health and safety of the client or others, the following criteria shall be used in consulting with the client:
1. when there is a significant risk to the health and safety of the person with a disability or others (the mere possibility of risk is insufficient);
2. when the risk is greater than the risk associated with other clients;
3. when the risk cannot be eliminated or reduced by other means;
4. when the assessment of the risk is based on consideration of the duration of the risk, the nature and severity of the potential harm, the likelihood that the potential harm will occur, and the imminence of the potential harm; and
5. when the assessment of the risk is based on the individual’s actual characteristics, not merely on generalizations, misperceptions, ignorance or fears about a disability.
4. Notice of Service Disruptions
In the event a temporary service disruption occurs that would limit a person with a disability from gaining access to MMFHT facilities, goods or service, the MMFHT will post notice or otherwise make the disruption known to clients in the following methods/places:
- Notice on entrance doors
- Notice on website
- Phone message
If an unexpected disruption occurs, persons with disabilities will be accommodated by the use of other means possible to deliver the goods and service, such as:
· the goods and service delivery agent may provide the goods or service directly to the person with a disability at an alternate place and time, as deemed appropriate.
All notices of disruption shall include:
· the name of the event/service;
· the normal service location being impacted;
· alternate service locations, if available;
· alternate service methods, if available;
· hours of service availability;
· contact information; and
· any other information deemed appropriate to deliver a good or service.
5. Training
All employees of the MMFHT providing direct service to persons with a disability shall be trained in the various aspects of accessible client service delivery. All training, regardless of format, shall have regard for:
· An overview of the purposes of the Accessibility Act and an awareness of the subject
· Instruction on how to interact and communicate with people with various types of Disabilities
· Instruction on interacting with people with disabilities who use assistive devices or require the assistance of a guide dog, other service animal or a support person;
· Instruction on the use of equipment or devices available, such as wheelchairs;
· Instruction on what to do if a person with a disability is having difficulty accessing your services.
Training shall be mandatory for all new employees upon their initial orientation. In addition, all employees will receive “refresher” training on a regular basis and more comprehensive training should there be changes to this policy.
Training records shall be maintained for all training completed under this Policy.
6. Feedback process
Feedback may be provided by a person with a disability in the manner deemed most convenient to them, such as in person, by telephone, in writing, or by delivering an electronic e-mail.
Feedback may be provided directly to the service provider or:
Administrator
Minto-Mapleton Family Health Team
11 Andrews Drive West
Drayton ON N0G 1P0
Phone: 519-638-2110
Fax: 519-638-5096
Email: sborges@mmfht.ca
All feedback will be kept in strict confidence and used to improve client service. In addition, the author of the feedback will be provided a response in the format in which the feedback was received outlining actions deemed appropriate, if any.
7. Notice of Availability of Documents
This policy and any other document deemed to be a key in the delivery of goods and service will be made available upon request in a format that takes into account the person’s disability to any person to whom it provides goods or services.
Notwithstanding the above, this policy will be made available on the MMFHT’s website: www.mmfht.ca and made available to any person to whom it provides goods or services by any other method or format as is reasonable in the circumstances.
The Minto-Mapleton Family Health Team (MMFHT) is committed to providing client-centred service.
The MMFHT wants to ensure that it complies with Provincial standards to provide accessible customer service to all our clients, including those with a disability.
Provincial Accessibility Standards
The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) was passed by the Ontario Legislature with the goal of creating standards to improve accessibility across the province in five areas:
· Customer Service
· Information and Communication
· Transportation
· Employment
· Built Environment
The Accessibility Standards for Customer Service is the first of the five standards and will take effect on
Jan. 1, 2012. This standard details specific requirements for service providers such as the Family Health Team.
The following is a summary of the key requirements of the Accessibility Standards for Customer Service:
1. Establish policies, practices and procedures for providing goods or services to people with disabilities.
2. Communicate with a person with a disability in a way that takes their disability into account.
3. Set a policy to allow people to use their own personal assistive devices to access our goods or services.
4. Allow people with disabilities to be accompanied by their guide dog or service animal in those areas of our premises that are open to the public, unless the animal is excluded by law.
5. Permit people with disabilities who use a support person to bring that person with them while accessing goods or services in premises open to the public or third parties.
6. Train staff, volunteers, contractors and any other people who interact with the public or other third parties on our behalf on a number of topics as outlined in the Customer Service Standards.
7. Establish a process for people to provide feedback on how you provide goods or services to people with disabilities. Also outline how you will respond to any feedback and take action on complaints.
8. Provide notice when facilities or services that people with disabilities rely on are unavailable.
B. PURPOSE
This policy establishes that goods and services provided by the MMFHT shall be provided to persons with disabilities and all clients in accordance with the following key principles:
- Dignity: Service is provided in a respectful manner consistent with the needs of the individual.
- Independence: Services for persons with disabilities shall support their independence while respecting their right to safety and personal privacy.
- Equity/Equality of Outcome: Service outcome is the same for persons with disabilities as for persons without disabilities.
- Integrated: Services allow people with disabilities to fully benefit from the same services, in the same place, and in the same or similar way as other clients.
In addition to the above key principles as provided for in the Customer Service Standard, the MMFHT will be:
- Sensitive: Service is provided in a manner that is respectful to an individual’s needs.
- Responsive: Service is delivered in a timely manner, considering the nature of the service and the accommodation required. For example, if needed, alternate formats will be provided by a specific deadline.
C. SCOPE
The subject policy is delivered in accordance with the Accessibility for Ontarians with Disabilities Act, 2005, and Regulation 429/07 Accessibility Standards for Customer Service, and is applicable to all policies, procedures and processes of the MMFHT.
D. PROCEDURES
1. Assistive Devices
Persons with disabilities shall be permitted to obtain, use or benefit from goods or services through the use of their own assistive devices. In the event a person with a disability is hindered from accessing goods or services and after consulting with the client, the MMFHT will accommodate the client by using any other assistive measures available.
2. Service animals
Service animals, such as but not limited to Guide dogs, Hearing dogs, Seizure Response dogs, other certified service animals shall be permitted entry to all MMFHT facilities and meeting rooms which are open to the public. A service animal is defined as: “Any animal where it is readily apparent that the animal is used by the person for
reasons relating to his or her disability and if the person provides a letter from a physician or nurse or other government issued certification confirming that the person requires the animal for reasons relating to the disability.”
Service animals are not permitted:
· Where food preparation is being undertaken; or
· as otherwise disallowed by law.
Where a Service Animal is to be denied access to a facility or meeting room, other accommodations may be afforded, such as:
· alternate meeting format, such as teleconference/videoconference, where technology permits;
· deliver the goods or service at an alternate time or location;
· any other assistive measures available to deliver a good or service to ensure equality of outcome.
Owners of Service Animals may receive information from staff as to the location of fresh water for the service animal and where service animals may be walked to relieve themselves.
3. Support Persons
Support Persons shall be permitted entry to all MMFHT facilities and meeting rooms which are open to the public. Where a Support Person is necessary to protect the health or safety of the person with a disability or the health or safety of others on the premises, the person with a disability shall be accompanied by a Support Person when on the premises. The client shall determine whether a Support Person is necessary, however where an employee believes that a Support Person should be in attendance to protect the health and safety of the client or others, the following criteria shall be used in consulting with the client:
1. when there is a significant risk to the health and safety of the person with a disability or others (the mere possibility of risk is insufficient);
2. when the risk is greater than the risk associated with other clients;
3. when the risk cannot be eliminated or reduced by other means;
4. when the assessment of the risk is based on consideration of the duration of the risk, the nature and severity of the potential harm, the likelihood that the potential harm will occur, and the imminence of the potential harm; and
5. when the assessment of the risk is based on the individual’s actual characteristics, not merely on generalizations, misperceptions, ignorance or fears about a disability.
4. Notice of Service Disruptions
In the event a temporary service disruption occurs that would limit a person with a disability from gaining access to MMFHT facilities, goods or service, the MMFHT will post notice or otherwise make the disruption known to clients in the following methods/places:
- Notice on entrance doors
- Notice on website
- Phone message
If an unexpected disruption occurs, persons with disabilities will be accommodated by the use of other means possible to deliver the goods and service, such as:
· the goods and service delivery agent may provide the goods or service directly to the person with a disability at an alternate place and time, as deemed appropriate.
All notices of disruption shall include:
· the name of the event/service;
· the normal service location being impacted;
· alternate service locations, if available;
· alternate service methods, if available;
· hours of service availability;
· contact information; and
· any other information deemed appropriate to deliver a good or service.
5. Training
All employees of the MMFHT providing direct service to persons with a disability shall be trained in the various aspects of accessible client service delivery. All training, regardless of format, shall have regard for:
· An overview of the purposes of the Accessibility Act and an awareness of the subject
· Instruction on how to interact and communicate with people with various types of Disabilities
· Instruction on interacting with people with disabilities who use assistive devices or require the assistance of a guide dog, other service animal or a support person;
· Instruction on the use of equipment or devices available, such as wheelchairs;
· Instruction on what to do if a person with a disability is having difficulty accessing your services.
Training shall be mandatory for all new employees upon their initial orientation. In addition, all employees will receive “refresher” training on a regular basis and more comprehensive training should there be changes to this policy.
Training records shall be maintained for all training completed under this Policy.
6. Feedback process
Feedback may be provided by a person with a disability in the manner deemed most convenient to them, such as in person, by telephone, in writing, or by delivering an electronic e-mail.
Feedback may be provided directly to the service provider or:
Administrator
Minto-Mapleton Family Health Team
11 Andrews Drive West
Drayton ON N0G 1P0
Phone: 519-638-2110
Fax: 519-638-5096
Email: sborges@mmfht.ca
All feedback will be kept in strict confidence and used to improve client service. In addition, the author of the feedback will be provided a response in the format in which the feedback was received outlining actions deemed appropriate, if any.
7. Notice of Availability of Documents
This policy and any other document deemed to be a key in the delivery of goods and service will be made available upon request in a format that takes into account the person’s disability to any person to whom it provides goods or services.
Notwithstanding the above, this policy will be made available on the MMFHT’s website: www.mmfht.ca and made available to any person to whom it provides goods or services by any other method or format as is reasonable in the circumstances.
