PRIVACY POLICY
Commitment to Privacy
Centre Jubilee Centre (CJC) is committed to respecting, safeguarding and protecting your personal health information (PHI) and complying with the provisions of the Personal Health Information Protection Act, (PHIPA) 2004, which requires that PHI be kept private and secure. We strive to provide our clients with excellent care and services. Every member of the Jubilee Centre must abide by our commitment to privacy in the handling of (PHI).
Applicability of this Privacy Policy
This Privacy Policy attests to our commitment to privacy and demonstrates how we strive to ensure that client privacy and their (PHI) is protected. Our Privacy Policy applies to client (PHI) that is in our possession and control.
What is Personal Health Information (PHI)?
Personal Health Information (PHI) is information pertaining to your health that can be linked to your identity. It may include demographic information, facts and information about you including mental, social and service history, family/home environment, the provision of health care and your health card number.
The 10 Principles of Privacy
Our Privacy Policy reflects our compliance with fair information practices, applicable laws and standards of practice.
1. Accountability
We take our commitment to securing client privacy very seriously. Each Clinician and employee associated with the Centre is responsible for the personal information under his/her control. Our employees are informed about the importance of privacy and receive information periodically to update them about our Privacy Policy and related issues.
2. Identifying Purposes: Why We Collect (PHI)
We collect (PHI) to establish a relationship and:
• to provide the addiction and mental health services requested
• to prevent harm or respond to emergency situations
• to inform the allocation of resources and for reporting to the Ministry of Health/OH-North
• to measure the effectiveness of our services
We obtain most of our information about you directly from you, or from other agencies whom you have authorized to disclose to us. You are entitled to know how we use your information. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purposes.
3. Consent
You have the right to determine if and how your personal health information is used and disclosed. For most health care purposes, your consent is implied as a result of your request and consent to treatment.
Except as otherwise permitted under applicable law, personal information is collected, used or disclosed based on your implied or express consent.
While you may withdraw or place limits on your consent, doing so could prevent the Jubilee Centre from accurately assessing your health or clinical status and may result in ineffective or insufficient treatment or service.
While we take every precaution to ensure your confidentiality, we are required to release your information without your consent in the following circumstances:
• between CJC staff and consultants employed by CJC for consultation, supervision and quality assurance purposes.
• when information is obtained about a child who may be in need of protection
• where you are at risk of self-harm or at risk of harming others
• where CJC is served with a subpoena
• when the Ministry of Health/OH-North is investigating or auditing our records.
4. Limiting Collection
We collect information by fair and lawful means and collect only that information which may be necessary for purposes related to the provision of your care or treatment.
5. Limiting Use, Disclosure and Retention
The information we request from you is used for the purposes identified. We will seek your consent before using the information for purposes beyond the scope of the identified purposes.
Clients will be required to sign and date a Consent to Disclose Personal Health Information Form prior to service being provided by the Centre.
Your personal health information (PHI) is kept by the Jubilee Centre for as long as it remains necessary or relevant for identified purposes, or as required by law, and will be destroyed thereafter. PHI records are retained for up to ten years after the last service was provided, beyond which point they will be shredded/destroyed.
6. Accuracy
We endeavour to ensure that all decisions involving your personal information are based upon accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on you to disclose all material information and to inform us of any relevant changes or corrections to the PHI in our possession.
7. Safeguards: Protecting Your Information
We protect your information with appropriate safeguards and security measures. The Centre maintains personal information in a combination of paper and electronic files. Recent paper records concerning individual’s personal information are stored in locked files kept onsite at our office.
Access to personal information will be authorized only for Clinicians and employees associated with the Centre, and agents who require access in the performance of their duties as permitted by the Centre and in compliance with the Centre’s safeguards, and to those otherwise authorized by law.
We provide information to health care providers acting on your behalf, on the understanding that they are also bound by this policy, laws and ethics to safeguard your privacy. Other organizations must agree to abide by our Privacy Policy.
Our computer systems are password-secured and constructed in such a way that only authorized individuals can access secure systems and databases.
If you send us an e-mail message that includes personal information, such as your name included in the “address”, we will use that information to respond to your inquiry. Please remember that e-mail is not necessarily secure against interception. If your communication contains PHI, you should not send it electronically unless the e-mail is encrypted or your browser indicates that the access is secure.
8. Openness: Keeping You Informed
The Centre has prepared this plain-language Privacy Policy to keep you informed. You may view a copy by visiting our website at www.jubileecentre.ca.
If you have additional questions or concerns about privacy, we invite you to contact us by phone and we will address your concerns to the best of our ability.
9. Access and Correction
Under the Personal Health Information Protection Act (PHIPA), 2004, you have the right to request access to and correction of your record of personal health information. With limited exceptions, we will grant you access to the information we retain about you within a reasonable time, upon presentation of a written request and satisfactory identification.
We may charge you a fee for this service and if so, we will give you notice in advance of processing your request.
If you find errors of fact in your personal health information, please notify us as soon as possible and we will make the appropriate corrections. We are not required to correct information in relation to clinical observations or opinions made in good faith. You have a right to append a short statement of disagreement to your record if we refused to make a requested change.
If we deny your request for access to your personal information, we will advise you in writing of the reason(s) for the refusal and you may then challenge our decision.
10. Challenging Compliance
If you have any questions, concerns, or complaints regarding the privacy and/or information practices at CJC, we encourage you to contact our Privacy Officer. We will answer your questions and will promptly investigate any concerns raised regarding this policy and/or about any aspect of our handling of your (PHI). You can reach us at:
Centre Jubilee Centre
Att: Clinical Director (Privacy Officer)
140 Jubilee Ave. West
Timmins, ON
P4N 2M9
705-268-2666 ext: 226
705-267-6882 (fax)
Although we will make every effort to resolve all privacy concerns, if you are not able to resolve a privacy issue directly with our organization, you may contact:
Office of the Information and Privacy Commissioner of Ontario
2 Bloor St. East, Suite 1400
Toronto ON M4W 1A8