In this Policy, we use the word “Practitioner” to refer to physiotherapist, kinesiologists, nurses, wound clinicians, dietitians and other health professionals contracted or employed by My Home Rehab Inc. We use the word “You” to refer to any individual user of our services, such as a patient, Power of Attorney, or an individual browsing or using our websites and web-based resources. We use the word “Platform” to refer to our Medical Health Record software (Jane App).
What is personal Information
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
Who we are
We are a mobile multidisciplinary rehabilitation clinic composed of physiotherapists, kinesiologists, a wound care nurse and a dietitian. We specialize in the rehabilitation of age-related conditions and are committed to enhancing the overall physical health, fitness, and quality of life of seniors living in their homes and in facilities. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, bookkeepers and accountants, contract practitioners, credit card companies, and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have third party assurances that they also follow appropriate privacy principles.
Primary purpose for collecting personal information
Like all practitioners, we collect, use and disclose personal information in order to serve our patients. For our patients, the primary purpose for collecting personal information is to provide rehabilitation treatments, practitioner guidance and advice. For example, we collect information about a patient’s health history, including their family history, physical condition and function and social situation in order to help us 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 we can identify changes that are occurring over time.
We will explain how we intend to use your personal information prior to, or while collecting it. It will be used only for those purposes which we have explained to you. We will obtain your consent to utilize your personal information for any other purpose(s). The primary purposes for collecting your personal information might include:
To verify eligibility for MSP, ICBC & WCB.
Information about your transactions with us such as account balances & payment history.
Information about your rehabilitation progress for third-party payers to maintain your records of treatment.
Information to contact, correspond with & respond to your inquiries or requests.
to communication with you regarding our services & to permit newsletter & informational communication regarding physical wellness needs.
Tabulating information that is of relevant interest to our business such as how our patients are responding to treatment or tracking patterns of specific types of injury profiles.
Physiotherapists are regulated by the College of Physiotherapists of BC who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our patients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
Patients or other individuals we deal with may have questions about our goods or services after they have been received. We also provide ongoing services for many of our patients over a period of months or years for which our previous records are helpful. We retain our patient information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our patient’s records).
If My Home Rehab Inc or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
We collect this information to serve you better.
Disclosing Personal Information to Others
My Home Rehab Inc stores and processes your personal information in Vancouver, B.C. Canada. We maintain security standards and procedures via third parties to prevent unauthorized access to your confidential, personal information. Their security standards and procedures are updated and tested regularly to improve the protection of and to assure the integrity of your personal information.
We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and our internal policies. We take appropriate measures to enforce employee privacy responsibilities.
Each of our suppliers and agents, as part of their contract with us, are “bound” to protect your privacy. Your personally identifiable information is to remain confidential and may not be used for any unauthorized purpose.
When we respond to a legal request or regulatory body inquiry, we ensure the validity of each specific order. If considered valid, we then disclose only the requested information. Otherwise we will seek your verbal and written consent prior to disclosing your personally identifiable information.
We may provide your personal information to other persons not affiliated with My Home Rehab Inc, such as regulators, service providers or credit reporting agencies. Confidential personal information is only provided wherein we have your written consent or where the law requires our cooperation.
Access to Your Information
Access and Accuracy: With only a few exceptions, you, the client reserves the right to see what personal information is on record with My Home Rehab Inc. We will provide you with reasonable access to your personal information and information about My Home Rehab’s use and disclosure of that information. We will make every reasonable effort to keep your personal information accurate and up to date. In order to confirm your identity, we may ask you to put your request in writing before providing you with this access. We will also assist you by translating “difficult to understand” information (e.g., short forms, technical language, etc.). Please note that we may not be able to provide information about you from our records if:
it contains references to other persons
it is subject to legal privilege
it contains information proprietary to My Home Rehab Inc
it is too costly to retrieve
or cannot be disclosed for other legal reasons.
If we must deny you access to review your personal records, we will promptly inform you. We will also provide explanation why we are unable to comply with your request to review your personal records. Also, we do not maintain disclosure records for regular or routine actions. If you have questions regarding decisions made about you, we will explain the rationale.
Protection of personal information
Our third-party platform (Jane App) protects your personal information, including Patient Data, by:
Using industry standard security controls such an encryption and an SSL (Secured Sockets Layers) certificate to ensure information is transmitted over a secured connection between your browser and their web server.
Using state-of-the-art data centres with appropriate security and compliance certifications, such SOC 2 and EU-US Privacy Shield that are HIPAA compliant.
Having their personnel sign strict confidentiality agreements to ensure they understand the confidential nature of the data we process, and only accessing your account when you request assistance from us.
Requiring password protection of your user account with a password set by you. We cannot access or identify your password. The only way to recover a password is for you to initiate a reset via the email address or mobile phone number you use for the Services.
While Jane App employ industry standard measures to protect your information, no electronic communication can ever be completely secure. You share responsibility for protection of your personal information by setting a strong password and by keeping your username and password confidential.
Customer Service Correspondence
If you send us documented correspondence, including e-mails, faxes and third-party communications, we will retain this information as part of your clinical record. Customer service opinions are critical to us; therefore we will also retain customer service correspondence in your clinical record. We retain this documented correspondence in order to:
measure & improve upon our customer service, &
to investigate potential fraud or other violations of our User Agreement.
We may, over time, delete these records. Under the laws of British Columbia, we are obligated to safely maintain access to your clinical records for a period of seven (7) calendar years. We will protect your personal information with appropriate safeguards and security measures.
My Home Rehab Web Site and Platform Policy:
Non-identifiable information: My Home Rehab Inc web site and Jane App platforms automatically collects certain non-identifiable information regarding their users, such as:
the internet protocol (IP)address of your computer,
the IP address of your service provider,
the date and time you access the web site,
the internet address of the web site from which you linked directly to our web site,
the operating system you are using,
the sections of the web site you visit,
the web site pages read, and images viewed, and
the content you download from the web site.
My Home Rehab Inc uses this non-identifiable information for web site and platform system administration purposes and to improve our services.
My Home Rehab takes responsibility for personal information in its possession and holds all third parties responsible for personal information that may be transferred to a third party for processing.
We will investigate and respond to your concerns pertaining to all aspects of how we handle your personal information.
If you identify an error in the content, you have the right to request that it be corrected. This applies to factual information only and not to our documented, professional opinions. We may ask you to provide written notification that our personal file or record is in error.
Third Party Vendors/Other Web Sites
Our web site contains links to other web sites or Internet resources. When you click on a link you are contacting another web site or Internet resource. My Home Rehab Inc has no responsibility or liability for control over these other web sites or Internet resources or their collection, use and disclosure of your personally identifiable information.