At Odyssey Health Services Inc. (OHS), protecting the confidentiality and privacy of all information; from and about our patients; from and about our 3^rd party clients who pay for our services; or about our professional staff and employees, is of vital importance.  This has always been the case.  With the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) we are providing this additional detailed information about our information protection practices.

Patient Information

Much of the following patient related information is available in our Patient Guide.

At OHS, maintaining your privacy and confidentiality has always been extremely important to us.  Protecting patient information is always of the highest priority to us.  We adhere to the same rules and practices of confidentiality that apply to all Registered Psychotherapists and Registered Kinesiologists in Ontario.

All of the information that we gather about you, in interview, in various meetings, and from other health-care professionals is gathered with your explicit and informed consent.  It is maintained in your patient file, under the control of our health-care professionals and is released only with your consent (with the exceptions noted below).

Reports are provided to third parties and to other health-care professionals only with your written consent (see exceptions).  Clinical records are maintained in secure circumstances for a minimum of 10 years after the last date of contact with the patient.

Information that you provide to us is shared with all of the clinical team, because you are being assessed and/or treated by a team of professionals rather than a single individual.

Information may also be shared with health-care professionals that are part of our extended professional team whom you do not meet directly.  In some cases, we may have one of our consulting psychologists review information in your file in order to provide support and/or advice to our therapists.  All such individuals adhere to, and are governed by, the same laws, practices and regulations to maintain confidentiality as those individuals you actually meet with.

Administrative staff will also be involved in activities such as typing, proofreading, copying, filing, receiving and sending mail and receiving and placing phone calls.  These staff are all trained to adhere to all professional standards and the regulated health-care professionals they work for are ultimately responsible for their conduct.  When information has to be mailed or faxed, appropriate caution is exercised to insure accuracy of destination addresses and numbers and that receiving health-care professionals exercise appropriate protection of privacy.  Considerable efforts are made to ensure that methods of information transmission are secure and protected from tampering.

OHS considers it important to continue to analyse the effectiveness of the interventions that we undertake.  Therefore, we may, from time to time, summarize patient data in papers that are submitted for scientific or professional publication.  This involves extracting data from patients’ files in a way that their anonymity is protected and no individual patient, or their particular circumstances, can be identified.  Demographics (e.g. average age, gender distribution, average length of time off work) and group outcomes (e.g. average change in patients’ function, proportion of patients who return to work; average length of treatment) are typically summarized in such papers.  Such publications allow for examination of our methodology and outcome statistics by the scientific community, without compromising an individual patient’s right to privacy.  Your data may be included in such analyses, but always in a way where your individual privacy is protected.

Your insurer (including various automobile insurers, workers’ compensation boards and long-term disability carriers) or employer may require that you consent to the provision of reports to them or your access to benefits or employment may be affected.  You should ensure that you understand any such consequences to withholding consent, and we will make every effort to ensure we and you understand such circumstances.

In some cases, if you deny us your consent to communicate with your other health-care professionals, we may not be able to continue with our assessment or treatment because we feel that a specific level of communication is vital to proper clinical practice.  We would advise you of this and if you still wish to withhold consent, we would not proceed under such circumstances.

Exceptions to strict confidentiality:

1. There are statutory requirements that oblige us to report circumstances where we feel a child may be at risk, or where an individual has been sexually abused by a regulated health-care professional.

2. In some provinces, legislation requires health-care professionals to report to the ministry responsible for the licensing of drivers the circumstances of any patient that has a medical condition that may impair the patient’s ability to drive safely.

3. If we feel an individual is an immediate risk to her or himself or to others we may have an ethical obligation to break confidentiality in order to protect the life of our patient or others.

4. We may be ordered by the courts or police (through a court ordered search warrant) to produce records that the court feels it or the police require.

5. Our regulatory bodies (i.e. The College of Psychotherapists of Ontario, The College of Kinesiologists of Ontario) do have the legal authority to appoint investigators to audit a health-care professional’s conduct and practice, in order to ensure that appropriate professional standards are being met. They do have the legal authority, in certain cases, to audit patients’ files as part of such an investigation without obtaining the patient’s consent or notifying the patient.

6. In certain cases, if a patient has been injured at work, or in a motor vehicle accident, where payment for treatment services, or income replacement benefits, are available from a government body such as a WSIB Ontario; legislation may permit the government empowered body to demand reports respecting the assessment and treatment by certain health-care practitioners of conditions deemed relevant to that body (e.g. work-related injuries or automobile accident related injuries) without the written consent of the patient.

7. In rare cases, the third party paying for treatment may request an independent audit to insure that the services they have paid for have been rendered in an appropriate manner. This would be carried out by an independent regulated health-care professional, who is not an employee of either OHS or the third party payer and who is bound by all the same professional obligations as we are.  They would not disclose specific clinical information, but rather simply confirm that services have been rendered in accordance with accepted professional standards.

Employee Information

We gather only personal information that is necessary in order for us to comply with provincial and federal employment and taxation requirements; to enrol staff in our group benefits plan; to insure that all of our professional staff are appropriately covered by liability insurance; and to be able to contact in routine and emergency circumstances our staff and/or the individuals they have identified as emergency contacts or next-of-kin.  Information is only gathered with the employee’s knowledge and consent.

During the hiring process, information may be gathered with respect to previous employment; to confirm professional credentials; and to allow us to appropriately evaluate a candidate for a particular position.  Once again, all knowledge and information is only gathered with the candidate’s consent.  Information gathered may include the completion of personnel or psychometric tests relevant to the position under consideration.

Necessary contact information about employees or employment candidates is provided to staff who have a need to be able to contact other staff.

All personal information is maintained in separate personnel files, in locked storage, and accessible only by relevant senior personnel.  Information is not made available to outside parties without the explicit knowledge and consent of the employee involved.  Personal information including details of the employment contract and compensation are not discussed with co-workers.  Only senior management are aware of such information, and only when such information is required for them to carry out their responsibilities to the organization effectively.

Information that is shared with patients and third party payors, including clinical staff names and credentials, is only that information which is essential for the therapeutic process and is reviewed with staff in advance of being made available to patients, clients paying for our services, and in informational documents and our website.

Information respecting an individual’s performance of their employment responsibilities is shared only with relevant management and supervisory personnel.  Written information is maintained in appropriate secure and locked files.

Client (3rd Party Customer) Information

It is also the policy of OHS to guard and protect information made available to us by 3^rd parties such as insurers or employers.  This includes not only the information that they may provide to us respecting patients that they refer to us, but also their identity as our customers; information we may acquire about their individual business or clinical practices; and contact information respecting their organisations and their employees.

Medical or clinical information that is provided to us by 3^rd parties such as insurers, or the occupational health departments of employers, is kept in the prospective or present patient’s clinical file and treated with exactly the same professional standards as any other patient information.

Contact information or business practice information that we are aware of respecting such 3^rd parties, is used only to provide the agreed upon service to that party.  Customer’s identity or other information would not be provided to any outside agency without the explicit authorization of the customer involved.

Accountability

Should you have any questions, enquiries or complaints please contact our Privacy Officer, Ms. Janet Marlin (the Director of Odyssey Health Services Inc.), at our head office in Burlington; or the Cognitive Behavioural Therapist with whom you are involved.

For Ms. Janet Marlin:

Ms. Janet Marlin

Odyssey Health Services Inc.

602 – 1100 Burloak Drive

Burlington, ON  L7L 6B2

Telephone: 289-440-0523

Facsimile: 905-390-3017

Email: janetmarlin@ohs-jma.com