March 2024
Cambridge Group of Clubs (“CGoC”, “we”, “us” or “our”) is committed to protecting the personal health information it collects through its sports medicine and chiropractic clinics (collectively, the “Clinics”). It is our policy to comply with our obligations set out under the Personal Health Information Protection Act, 2004 (“PHIPA”) in the course of providing health-related services to visitors of the Clinics. Our priority is to help ensure that your personal health information is treated with the utmost respect, dignity and sensitivity.
Please note that this Clinic Privacy Policy is separate from our website privacy policy, which can be found here.
CONTENTS
Collection of Personal Health Information
Permitted Uses and Disclosures of Personal Health Information
Consent
Safeguarding
Retention
Accessing and Correcting your Personal Health Information
Contact Us
Updates
Collection of Personal Health Information
“Personal health information” refers to identifying information about an individual in oral or recorded form, that (i) relates to the physical or mental health of an individual; (ii) relates to the providing of health care to an individual; (iii) is a plan of service within the meaning of the Long-Term Care Act, 1994 for an individual; (iv) relates to payments or eligibility for healthcare in respect of an individual; (v) relates to the donation by an individual of any body part or bodily substance of an individual; or (vi) is the individual’s health number or identifies a provider of healthcare to an individual or a substitute decision-maker of an individual.
In accordance with PHIPA, we collect personal health information only for lawfully authorized purposes, such as to provide you with health care services or assist in the provision of healthcare to you by other healthcare providers. We may collect this information either from you directly or, in some circumstances, from a person designated to make care decisions on your behalf.
The information that we may collect may include your name, date of birth, address, email address, health card/OHIP number, medical imaging information, referrals and collaborative reports from other physicians, health history, symptoms and other records of your visits and the care that you received from our Clinics. Our collection and use of personal health information is limited to that necessary to provide care, to assist in the provision of care and to properly carry out related administrative and reporting obligations. Individuals are never deceived or coerced in order to obtain consent for collection, use or disclosure of their information.
Permitted Uses and Disclosures of Personal Health Information
Your personal health information is used by our Clinic team to provide health care and as permitted or required under PHIPA. For example, we may use and disclose your personal health information:
- To treat and care for you.
- To receive payment for your treatment and care (e.g. from OHIP, WSIB, your private insurer, or other payors).
- To conduct risk management activities.
- To conduct quality improvement activities.
- For teaching purposes.
- To comply with legal and regulatory requirements.
- To fulfill other purposes as permitted or required by law.
The Clinic team is composed of physicians, support staff, and other health practitioners who are directly involved in your care or treatment or assisting in the provision of care. The Clinic team uses and shares information with other team members and staff on a “need to know” basis.
Personal health information is disclosed as necessary for the purpose for which it is collected, with consent, and as required or permitted by law. This includes disclosure (all external disclosures are done securely and could include de-identification if required) to your care providers to ensure continuity and coordination of care.
Consent
Where your consent is required for any collection, use or disclosure of your personal health information, you may withdraw or withhold consent by contacting us at the email noted at the bottom of this Policy.
Safeguarding
To protect your personal health information, we have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information (including personal health information) in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We are also committed to promptly investigate all complaints regarding our compliance with PHIPA. All privacy complaints will be treated in a confidential manner.
Retention
We retain your personal health information as long as necessary to fulfill the purposes of collection, including for the purposes of satisfying any regulatory, legal or reporting obligations or to resolve disputes.
Accessing and Correcting your Personal Health Information
In general, individuals have a right of access to a record of personal health information in the custody or control of a health information custodian, such as ourselves. If you believe that a record of personal health information is not as accurate or complete as necessary for its purpose, you may also make a written request to us to correct the record in question. To access or correct your personal health information, please email or write to us using the contact information set out at the bottom of this Policy.
We will respond to such requests within a reasonable timeframe and in accordance with applicable law. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
Contact Us
If you have a question or concern about your privacy, please contact us at: humanresources@cambridgegroupofclubs.com
If you wish to make a complaint about our privacy practices, you may contact the Information and Privacy Commissioner of Ontario at:
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Tel.: 1-800-387-0073
Fax: 416-325-9195
Website: www.ipc.on.ca
Updates
We may modify this Policy at any time. If we make changes, we will notify you by revising the date at the top of this Policy. We will provide you with advanced notice by the email or telephone number which we have on file or through a notice on our Sites if we make any material changes to how we collect, use or disclose your personal information. If you continue to access or use our services after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.