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Form 1: Public Statement

My Privacy Commitment to You: I am committed to protecting your privacy and ensuring the confidentiality of your personal health information. The types of personal health information I collect may include your name, address, phone number, email address, date of birth, health history, family health history, health measurements, health services provided to or received by you, and identity of your health care providers.

I collect, use and disclose personal health information for the following purposes: (1) to provide nutritional consulting to my clients; (2) to conduct quality improvement and risk management activities; (3) to obtain payment for services provided (from you or others); (4) to advise clients about special events or opportunities (but I will always obtain express consent to do so). I will collect, use and disclose only as much personal health information as is needed to achieve these purposes. You can withhold or withdraw your consent to the collection, use or disclosure of your personal health information by contacting me directly (details below).

Access to Health Records: You have the right to seek access to your health records that I keep and to ask me to correct a record if you believe it is inaccurate or incomplete. Please contact me for more information.

Questions or Concerns?

If you have questions or want to make a complaint about my privacy practices, please contact: Jennifer Jodouin. You also have the right to complain to the Information and Privacy Commissioner of Ontario at the address below if you have concerns about my privacy practices or how your personal health information has been handled: Information and Privacy Commissioner/Ontario

2 Bloor Street East, Suite 1400,

Toronto, Ontario M4W 1A8

Telephone: Toronto Area (416/local 905): (416) 326-3333

Long Distance: 1 (800) 387-0073 (within Ontario)

TDD/TTY: (416) 325-7539

FAX: (416) 325-9195

www.ipc.on.ca

Form 2: Privacy Policy for Unregulated Health Professional

Privacy of personal information is an important principle to Healthy Living With Jenn. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the nutritional services that I provide. I try to be open and transparent about how I handle personal information. This document describes my privacy policies.

What is Personal Health Information?

Personal health information is information about an identifiable individual. Personal health information includes information that relates to:

  • the physical or mental health of the individual (including family health history);
  • the provision of health care to the individual (including identifying the individual’s health care provider);
  • Payments;
  • or the identification of the individual’s substitute decision-maker.

Who Is "Healthy Living With Jenn"?

Healthy Living With Jenn, includes at the time of writing, just one nutritional consultant. I use a number of consultants and agencies that may, in the course of their duties, have limited access to personal health information that I hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, lawyers, temporary workers to cover holidays, credit card companies, website managers and cleaners. I restrict their access to any personal information I hold as much as is reasonably possible. I also have their assurance that they follow appropriate privacy principles.

Why I Collect Personal Health Information

I collect, use and disclose personal information in order to serve my clients. For my clients, the primary purpose of collecting personal health information is to provide nutritional advice and consultation. For example, I collect information about a client’s health history, including their family history, physical condition and function and social situation in order to help assess what their health needs are, to advise them of their options and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services I can identify changes that are occurring over time.

I also collect, use and disclose personal health information for purposes related to, or secondary to, my primary purposes. The most common examples of my related and secondary purposes are as follows:

  • Related Purpose #1: To obtain payment for services or goods provided. Payment may be obtained from the individual or others.
  • Related Purpose #2: To conduct quality improvement and risk management activities. I review client files to ensure that I provide high-quality services. External consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may conduct audits and quality improvement reviews on my behalf.
  • Related Purpose #3: To promote my practice, new services, special events and opportunities (e.g. a seminar or conference) that I have available. I will always obtain express consent from the client prior to collecting or handling personal health information for this purpose.
  • Related Purpose #4: To comply with external regulators.  As a professional, I believe that I should report information suggesting illegal behaviour to the authorities. In addition, I may be required by law to disclose personal health information to various government agencies (e.g. Ministry of Health, children’s aid societies, Canada Customs and Revenue Agency, Information and Privacy Commissioner, etc.). Consent, for this reason, is not required.

Protecting Personal Information

I understand the importance of protecting personal information. For that reason, I have taken the following steps:

  • Paper information is either under supervision or secured in a locked or restricted area.
  • Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, strong passwords are used on all computers and mobile devices.  Personal health information is only stored on mobile devices if necessary. All personal health information stored on mobile devices is protected by strong encryption.
  • Electronic information is either anonymized or encrypted before being transmitted.  I do not post any personal information about my clients on social media sites.
  • External consultants and agencies with access to personal information must enter into privacy agreements with me.

Retention and Destruction of Personal Information

I need to retain personal information for some time to ensure that I can answer any questions you might have about the services provided and for my own accountability. However, in order to protect your privacy, I do not want to keep personal information for too long. I keep our client files for at least seven years from the date of the last client interaction or from the date the client turns 18.

I destroy paper files containing personal health information by cross-cut shredding. I destroy electronic information by deleting it in a manner that it cannot be restored. When hardware is discarded, I ensure that the hardware is physically destroyed or the data is erased or overwritten in a manner that the information cannot be recovered.

You Can Look at Your Records

With only a few exceptions, you have the right to see what personal information I hold about you, by contacting myself, Jennifer Jodouin. I can help you identify what records I may have about you. I will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). I reserve the right to charge $30.00 for the first twenty pages of records and 25 cents for each additional page. I may ask you to put your request in writing. I will respond to your request as soon as possible and generally within 30 days, if at all possible. If I cannot give you access, I will tell you the reason, as best I can, as to why. 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 I may have formed. I may ask you to provide documentation that our files are wrong. Where I agree that I’ve made a mistake, I will make the correction. At your request and where it is reasonably possible, I will notify anyone to whom I sent this information (but I may deny your request if it would not reasonably have an effect on the ongoing provision of health care). If we do not agree that I have made a mistake, I will still agree to include in my file a brief statement from you on the point.

If there is a Privacy Breach

While I will take precautions to avoid any breach of your privacy if there is a loss, theft or unauthorized access of your personal health information I will notify you. Upon learning of a possible or known breach, I will take the following steps:

  • I will contain the breach to the best of our ability, including by taking the following steps if applicable
    • Retrieving hard copies of personal health information that have been disclosed
    • Ensuring no copies have been made
    • Taking steps to prevent unauthorized access to electronic information (e.g., change passwords, restrict access, temporarily shut down the system)
  • I will notify affected individuals
  • I will provide my contact information in case the individual has further questions
  • I will provide the Commissioner’s contact information and advise the affected individual of their right to complain to the Commissioner.
  • I will investigate and remedy the problem, by:
    • Conducting an internal investigation
    • Determining what steps should be taken to prevent future breaches (e.g. changes to policies, additional safeguards)
    • Depending on the circumstances of the breach, I may notify and work with the Information and Privacy Commissioner of Ontario.

Do You Have Questions or Concerns?

I can be reached at 705-770-7056 or This email address is being protected from spambots. You need JavaScript enabled to view it. I will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about my privacy practices, you may make it in writing to myself. I will acknowledge receipt of your complaint, and ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing. You also have the right to complain to the Information and Privacy Commissioner of Ontario if you have concerns about my privacy practices or how your personal health information has been handled, by contacting:

Information and Privacy Commissioner/Ontario

2 Bloor Street East, Suite 1400 34

Toronto, Ontario M4W 1A8

Telephone: Toronto Area (416/local 905): (416) 326-3333

Long Distance: 1 (800) 387-0073 (within Ontario)

TDD/TTY: (416) 325-7539

FAX: (416) 325-9195

www.ipc.on.ca

This policy is made under the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3. It is a complex statute and provides some additional exceptions to the privacy principles that are too detailed to set out here.

 

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