Commencing in 2004 The Personal Health Information Protection Act (PHIPA) applies to all allied health clinics in Ontario that collect, use or disclose personal information in the course of doing commercial business. Personal information is information about an identifiable individual. Personal information includes information that relates to a person’s personal characteristics, health, activities or views. Business information, including information on a business card, and collated information where the individual’s information cannot be identified is not protected by privacy legislation.
Accountability for Personal Information
Novah Healthcare is responsible for personal information under its control and has designated a Health Information Custodian who is accountable for Novah Healthcare’s compliance with PHIPA:
Dr. Trung Ngo
Unit 104 - 170 Queensway West
Mississauga, ON L5B 3A8
Identifying Purposes for the Collection of Personal Information
Novah Healthcare will identify the purposes for which personal information is collected. The primary purposes are the delivery of direct patient care, the administration of the health care system, research, teaching, statistics, and meeting legal and regulatory requirements. The kind of information that Novah Healthcare may collect may include but is not limited to:
- Personal characteristics (gender, age, identification or claim number, home address, phone number, language spoken, etc.).
- Health Information (health history, health condition, test results, physical examination findings, diagnosis, clinical opinion, functional measurements, treatment notes, prognosis, treatment responses, recommendations, etc.).
- Activities (occupation, profession, employer, work hours, etc.).
Consent for the Collection, Use, and Disclosure of Personal Information
Novah Healthcare will ensure that individuals will be advised of the purposes for which the information will be used.
Limiting Collection of Personal Information
The collection of personal information will be limited to that which is necessary for the purposes identified by Novah Healthcare. Information will be collected by fair and lawful means.
Limiting Use, Disclosure, and Retention of Personal Information
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
Ensuring Accuracy of Personal Information
Personal Information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Ensuring Safeguards for Personal Information
Safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Novah Healthcare will protect personal information regardless of the format in which it is held.
Openness About Personal Information Policies and Practices
Novah Healthcare will make information on its policies and practices available in a variety of ways. For example, Novah Healthcare may choose to post signs, make brochures available in its place of business, or provide online access.
Individual Access to Own Personal Information
Upon request, an individual will be informed of the existence, use, and disclosure of his/her personal information and will be given access to that information. An individual will be able to challenge the accuracy and the completeness of the information and have it amended as appropriate.
In certain situations, Novah Healthcare may not be able to provide access to all the personal information it holds about an individual. Exceptions to the access requirement will be limited and specific. The reasons for denying access will be provided to the individual upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security, commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
To gain access to personal information individuals can make a verbal or written request and must provide proof of identity. Novah Healthcare may require some time to retrieve the requested information. Nominal fees will apply for the making of copies of personal information. In some circumstances Novah Healthcare may request that the personal information be sent to an appropriate health practitioner for explanation if the information is sensitive. Novah Healthcare reserves the right to deny access to personal information with a complete explanation why.
Challenging Compliance with Novah Healthcare’s Privacy Policies and Practices
An individual will be able to address a challenge concerning compliance with this policy to the Health Information Custodian. Novah Healthcare will put procedures in place to receive and respond to complaints or inquiries about its policy relating to the handling of personal information.
For more general inquiries, the Information and Privacy Commissioner of Ontario oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
Toronto Area: 416-326-3333
Long distance: 1-800-387-0073