We, at the Harbourfront Health and Wellness Centre, are committed to collecting, using and disclosing personal information in a responsible manner, and only to the extent that it is necessary for the services we provide. We will be open with our handling of your information, as you will see from this Privacy Policy.

Please note that in this document, patient and client are considered to be interchangeable terms.

What is personal information?
Personal information refers to any information that can identify an individual. Personal information that we collect may include:

• Name, address, telephone number, fax number, e-mail address, date of birth, social insurance number, occupation, name of employer, place of employment, insurance company, insurance coverage
• Education, gender, sexual orientation, ethnicity, health history, health records, family history, hours of work, income
• Activities or views (e.g. religion, politics, opinions, community involvement)

Information related to a person’s business is not protected by privacy legislation.

Who are we?
Harbourfront Health & Wellness Centre is a multidisciplinary services company and aims to provide patients access to the full resources of Eastern and Western medicine in a balanced approach of healthcare. We specialize in the management and operation of medical/wellness services which include but are not limited to Medical walk-in clinic, Naturopathic medicine (including homeopathy, Traditional Chinese Medicine and acupuncture, diet and nutritional counseling, lifestyle counseling, botanical Medicine, hydrotherapy, soft tissue manipulation), Rehab physiotherapy, Chiropractic, Massage therapy, Acupuncture, Sports nutrition, Laser and cosmetic, Pediatric sports medicine, and Dermatology.

Collecting Personal Information:
Primary Purposes: For our clients, the primary purpose for collecting personal information is to help us assess what your health concerns are, to advise you of your options, to provide the health care you desire and to establish and maintain contact with you.

Related purposes: For our clients, related purposes for collecting personal information include: invoicing and statements, accounting and tax records, follow up services, quality control, communication with other health care providers, insurance claims, education (e.g. newsletter/articles, seminar announcements), marketing and compliance with regulation by a licensing/regulatory body. You can choose not to be part of some of these related purposes; for example, declining seminar announcements or newsletters. Please be aware that it may not be possible to decline some of the related purposes, such as information required by a regulatory body.

For members of the general public (non-clients), our primary purpose for collecting personal information is to allow the practitioners or staff to follow up on inquiries, ensure your request was properly handled (quality control), and provide information updates if you have expressed interest in receiving such notices.

For contract staff, our primary purpose for collecting personal information includes: communications, client communication, accounting and tax records, quality control, and education.

Protecting Personal Information:
We understand the importance of protecting personal information. For that reason, we have taken steps to safeguard your personal information from unauthorized access, disclosure, use or tampering.

Safeguards are in place to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Your personal information is protected, whether it is recorded on paper or electronically.

Practitioners and staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our Privacy Policy.

Retention and Destruction of Personal Information:
We are required by the Board of Directors of Drugless Therapy - Naturopathy to retain client files (containing personal information) for a minimum of seven years.

Care is exercised in the destruction of personal information to prevent unauthorized access to the information even during disposal and destruction.

Accuracy of Personal Information:
This clinic endeavours to ensure that your personal information is as accurate, complete, and as up-todate as necessary for the purposes that it is to be used.

Information shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information is used to make a decision about you as our patient.

With only a few exceptions, you have the right to see what personal information we hold about you. 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 any professional opinions we may have formed.

Consent:
This clinic will seek informed consent for the collection, use and/or disclosure of personal information, except where it might be inappropriate to obtain your consent, and subject to some exceptions set out in law.

Consent is required for the collection of personal information and subsequent use or disclosure of that information. In order for the principles of consent to be satisfied, our clinic has undertaken reasonable efforts to ensure that you are advised of the purposes for which information is being used, and that you understand those purposes. Once consent is obtained, we do not need to see your consent again unless, the use, purpose or disclosure changes.

Consent for the collection, use and disclosure of personal information may be given in a number of ways, such as:

• Signed medical history form
• Signed introductory questionnaire
• Taken verbally over the telephone and then charted
• E-mail
• Written correspondence

You may withdraw consent upon reasonable notice.

Do you have a concern?
Our Information Officer is Barbara Heckadon, Clinic Manager and she can be reached at barbarahhwc@yahoo.ca to address any questions or concerns 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.

Thank you for your interest in our Privacy Policy. If you have a concern about the professionalism or competence of our services, or the mental or physical capacity of any of our professional staff, we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to file a complaint with any of the regulatory boards of the individual practitioner(s). For example, if you have a complaint concerning one of our naturopathic doctors, you can contact the Board of Directors of Drugless Therapy - Naturopathy (call 416-866-8383 or at BoardofNaturopathicMedicine.on.ca).

For more information on Ontario’s Personal Health Information Protection Act please visit the website of the Information Privacy Commissioner at ipc.on.ca.