Privacy Policy
Introduction
Privacy of personal information is an important principle in the provision of quality care to our patients. We understand the importance of protecting your personal information. We are committed to collecting, using, and disclosing your personal information responsibly. We also try to be as open and transparent as possible about the way we handle your personal information.
We have tried to make our office Privacy Policy as easy to understand as possible. To ensure that you see how we are complying with the federal privacy legislation, the Personal Information and Protection and Electronic Documents Act (PIPEDA), our privacy code is organized to follow the Act’s ten interrelated principles that are the foundation of PIPEDA.
Definitions
Collection -The act of gathering, acquiring, or obtaining personal information from any source, including third party sources by any means.
College – College of Naturopathic Physicians of British Columbia
Consent – A voluntary agreement with what is being done or is being proposed to be done. Express consent may be given explicitly either orally or in writing.
Disclosure – Making personal information available to others, besides the naturopathic physician or the naturopathic physician’s staff.
Legislation – the Health Practitioner’s Act, regulations made under this Act, and the Personal Protection and Electronic Documents Act (PIPEDA)
Registrant – A registrant of the College of Naturopathic Physicians of British Columbia
Office – The naturopathic medical office and when referencing access to information, the Privacy Information Officer, and the naturopathic medical office
Patient – an individual about whom the naturopathic physician collects personal information in order to carry out diagnosis, prognosis, and treatment including controlled acts
Personal Information – Information about a patient that is recorded in any form and this includes: the patient’s name, address, telephone number, social insurance number, fax number, email address, gender, marital status, children, date of birth, occupation, medical records, health records, insurance company, insurance coverage, history, place of work, employer
PIPEDA Principles
Principle 1: Accountability
The naturopathic physicians in this office are responsible for information collected by them, or under their direction, and under their control.
Accountability for this office’s compliance rests with the designated individual or individuals, even though others in the office may be responsible for the day-to-day collection and processing of personal information.
The identity of the individual designated by the naturopathic physician to oversee the compliance, the Privacy Information Officer will be made known upon request.
The office is responsible for information in our possession or custody, including information that has been transferred to a third party for processing. We will use contractual or other means to provide a comparable level of protection while the information is being accessed and/or processed by that third party.
Our office will implement policies and practices to give effect to the principles, including:
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Implementing policies to protect personal information
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Establishing procedures to receive and respond to complaints and inquiries
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Training staff about privacy policies and practices
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Developing information to explain privacy policies and procedures
Principle 2: Identifying Purposes for Collecting Information
The purpose for which information is collected in this office will be identified before or at the time the information is collected.
This office collects personal information for the following purposes:
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To deliver safe and efficient patient care
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To identify and to ensure continuous high quality service
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To assess your health needs
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To advise you of treatment options
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To enable us to contact you
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To establish and maintain communication with you
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To offer and provide treatment, care, and services in relationship to preventative medicine, acute and chronic naturopathic health care generally
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To communicate with other treating health-care providers, including specialists, family practitioners, referring physicians, and any other provider involved in the care of a patient
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To allow us to maintain communication and contact with you to distribute health-care information and to book and confirm appointments
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To allow us to efficiently follow-up for treatment, care, and billing
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For teaching and demonstrating purposes on an anonymous basis
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To comply with legal and regulatory requirements, including the delivery of patient’s charts and records to the College of Naturopathic Physicians of British Columbia in a timely fashion, when required, according to the provisions of the Health Practitioners Act
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To comply with the agreements/undertakings entered into voluntarily by the member with the College of Naturopathic Physicians of British Columbia, including the delivery and /or review of patient’s charts and records to the College in a timely fashion for regulatory and monitoring purposes
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To permit potential purchasers, practice brokers or advisors to evaluate the naturopathic practice
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To allow potential purchasers, practice brokers or advisors to conduct an audit in preparation for a practice sale
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To deliver your charts and records to the Naturopathic Doctor’s insurance carrier to enable the insurance company to assess liability and quantify damages, if any
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To prepare materials for the College of Naturopathic Physicians of British Columbia complaints committee
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To invoice for goods and services
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To process credit card payments
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To collect unpaid accounts
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To assist this office to comply with all regulatory requirements
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To comply generally with the law
This office will identify the purposes for which personal information is collected, at or before the time of collection. We will only collect that information necessary for the identified purposes.
When personal information has been collected and is to be used or disclosed for a purpose not previously identified, the new purpose will be identified prior to its use or the disclosure. Your consent is required before the information can be used or disclosed for that purpose.
Office staff collecting personal information will be able to explain to you the purpose for which the information is being collected.
When you sign the Patient Consent Form, you will be deemed to understand and accept this office’s collection, use, and disclosure of your information for the specified purposes.
Principle 3: Consent
This office will seek informed consent for the collection, use, and 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 office has undertaken reasonable efforts to ensure that you are advised of the purposes for which information is being used, and that you understand these purposes. Once consent is obtained, we do not need to seek 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:
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Signed medical history form
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Signed introductory questionnaire
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Taken verbally over the telephone and then charted
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E-mail
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Written correspondence
You may withdraw your consent at any time upon reasonable notice.
Principle 4: Limiting Collection of Personal Information
The collection of personal information by our office shall be limited to that which is necessary for the purposes identified in this Privacy Policy.
Principle 5: Limiting Use, Disclosure, and Retention
Personal information shall not be used or disclosed for purposes other than those for which the information is collected, except with your express consent, or as required by law.
Our office has protocols in place for the retention of personal information.
Retention of information is defined and referenced in the College of Naturopathic Physicians of British Columbia’s Guidelines on Naturopathic Medical Recordkeeping.
In destroying personal information, our office has developed guidelines to ensure secure destruction in accordance with the College of Naturopathic Physicians of British Columbia’s Guidelines on Naturopathic Medical Recordkeeping.
Principle 6: Accuracy of Personal Information
This office endeavors to ensure that your personal information is as accurate, complete, and as up-to-date as necessary for the purposes that it is to be used.
The extent to which your personal information shall be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interest of our patients.
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.
Principle 7: Safeguards for Personal Information
Our office has taken appropriate measures 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 information is protected whether recorded on paper or electronically.
Our office staff is aware of the importance of maintaining the confidentiality of personal information.
Care is used in the care and destruction of personal information to prevent unauthorized access to the information even during disposal and destruction.
Principle 8: Openness about Privacy
Our office will make readily available to you specific information about our office policies and practices relating to the management of personal information.
This information includes:
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A Patient Information Sheet that outlines the name of the Privacy Information Officer who is accountable for our office privacy policies. This is the person to whom you can direct any questions or complaints. The Information Sheet also describes how to access your personal information held in this office.
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A copy of our Patient Consent Form that explains how this office collects, uses, and discloses your personal information
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Our office privacy policy
Principle 9: Patient Access to Personal Information
Upon written request and with reasonable notice, you shall be informed of the existence, use, and disclosure of your personal information, and shall be given access to that information.
Upon written request and with reasonable notice, our office will advise you whether or not we hold personal information about you.
Our office will allow you access to this information.
Upon written request and with reasonable notice, our office shall provide you an accounting of how your personal information has been used, including third party disclosures. In providing this information, we will attempt to be as specific as possible.
When it is not possible to provide a list of the organizations or individuals to which there has been a disclosure about you, we will provide you with a list of such organizations or individuals to which we may have disclosed information about you.
We will respond to your request within a reasonable period time, and at minimal or no cost to you. The request for information will be provided or made available in a form that is generally understandable.
The Naturopathic Physician will comply with the regulations of her governing College that define patient access to records.
You are free to challenge the accuracy and completeness of the information and seek to have it altered, amended, or changed. This process is explained in the Patient Information Sheet.
When a challenge is not resolved to your satisfaction, we will record the substance of the unresolved challenge.
When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question. This disclosure may be appropriate where a Naturopathic Physician has been challenged about a change to a service date or services rendered under consideration for insurance benefits.
Principle 10: Challenging Compliance
You shall be able to challenge compliance with these principles with the office’s Privacy Information Officer who is accountable within the naturopathic medical office for the Naturopathic Physician’s compliance. Our office has in place procedures to receive and respond to your complaints or inquiries.
This information, including the name of the Privacy Information Officer, is included in the Patient Information Sheet, available on request.
The procedures are easily accessible and simple to use.
Our office has an obligation to inform our patients who make inquiries about how to access the privacy complaint process in our office, and about how to access that process. This information is outlined in the Patient Information Sheet.
The Privacy Officer will investigate each and every complaint made to the office in writing.
If a complaint is found to be justified, the Privacy Information Officer will take appropriate measures, including, if necessary, amending any office policies and practices.
Patients will be provided with information about how to contact the Privacy Commissioner of Canada to forward any unresolved complaint. This information is included in the Patient Information Sheet, available on request.