Privacy Notice

Purpose

Transform Together Inc. is committed to client privacy and the confidentiality of the
personal information (“PHI”) it holds. This notice describes how information about you
may be used, collected, and disclosed; and how you can access this information, in
compliance with Ontario’s Personal Health Information Protection Act, 2004.

Your Client Record

Your client record includes oral or written information relevant to your health including
your date of birth, contact information, payment information, health number, health
history, family health history, details of your physical and mental health, information
related to providing health care, treatment or advice to you, the care and support you
received during your visits, results from tests and procedures, and information from
other health care providers.

The information in your health record belongs to you, but the health record itself is the
property of Transform Together Inc. and once provided by you to us your consent is
implied as a result of your consent to treatment deemed to have been provided to us
with your consent. Your client record is stored in our electronic client record system
(ECR) which is protected by multiple passwords and a firewall. All members of our team
have access to the ECR. All practitioners sign a privacy and confidentiality agreement
as part of their contract or agreement of service, and upon renewal of their contract or
agreement. In addition, all practitioners receive mandatory privacy training during
orientation and on an ongoing basis. The ECR is audited regularly for unauthorized use
and/or access. With limited exceptions, you have the right to access the health
information we hold about you, whether in the health record or elsewhere. If you request
a copy of your record, one will be provided to you at a reasonable cost. If you wish to
view the original record, one of our staff members must be present, and a reasonable
fee may be charged for this access. If you need a copy of your health record, please
ask your care provider or contact our Privacy Officer. In rare situations, you may be
denied access to some or all of your record (with any such denial being in accordance
with applicable law). We make every effort to ensure that all of your information is
recorded accurately. Please let us know if there is something that is incorrect. You have
a right to ask for a correction to your record if you disagree with what is recorded. In
most cases we will be able to make the requested correction but if not, we will ask you
to prepare a statement of disagreement to be attached to the record.

Our Practices

We collect, use and disclose (or share) your health information to:
● Treat and care for you
● Provide appointment reminders to you
● Comply with legal and regulatory requirements
● Plan or deliver our programs or services
● Plan, administer and manage our internal operations
● Conduct risk management, error management and quality improvement activities
● Educate our staff and students
● Dispose or modify the information to conceal your identity
● To seek your consent
● Respond to or initiate proceedings
● Be paid or process, monitor, verify or reimburse claims for payment
● For research purposes
● Compile statistics
● Fulfill other purposes permitted or required by law

Our collection, use and disclosure of your personal health information is done in
accordance with Ontario’s Personal Health Information Protection Act, 2004.

Your Choices

You have a right to make choices as to how your health information at Transform
Together Inc. is collected, used, and disclosed.

For most purposes, your consent to use your health information is implied as a result of
your consent to treatment unless you tell us otherwise. We may also collect, use and
disclose your health information in order to communicate or consult with other health
care providers about your care unless you tell us you do not want us to do so. You have
the right to ask that we not share some or all of your health record or information with
one or more of our team members, or ask us not to share your health record with one or
more of your external health care providers (such as a specialist). This is known as
asking for a “lockbox”. It is important to note that there may be an impact on our ability
to provide you with the best care if our healthcare professionals cannot access your
health record. For this reason, we ask that you discuss this with your designated
professional first.

There are other circumstances where we are not allowed to assume we have your
consent to share information. For example, we must have your permission to give your
health information to people who do not provide you with health care including health
professionals of Transform Together Inc. not involved in your care, your insurance
company or your employer. We may also need consent to communicate with any family
members or friends with whom you would like us to share information about your health
unless one or more of these individuals is your substitute decision-maker. When we
require and ask for your consent, you may choose to say no subject to some restrictions
under applicable law. If you say yes, you may change your mind at any time subject to
the requirement for you to provide us with reasonable notice. Once you say no, we will
no longer share your information unless you say so.

There are cases where we may collect, use or disclose your health information without
your consent, as permitted or required by law. For example, we do not require your
consent to use your information for billing, risk management or error management,
quality improvement purposes; or to disclose personal health information in a number of
permitted or required circumstances, including to eliminate or reduce a significant risk of
serious bodily harm; or to fulfill mandatory reporting obligations under other laws such
as for child protection or safe operation of a motor vehicle.

For More Information or Complaints

If you would like a copy of our Privacy Policy, please ask us.
We encourage you to contact us with any questions or concerns you might have about
our privacy practices.

Our Privacy Officer is:
Dannielle Samuel, MSW
123 Slater Street, 6th Floor
Ottawa, ON
K1P5G4
Telephone: 613-519-3517

If, after contacting us, you feel that your concerns have not been addressed to your
satisfaction, you have the right to complain to the Information and Privacy
Commissioner of Ontario. The Commissioner can be reached at: Information and
Privacy Commissioner of Ontario 2 Bloor Street East, Suite 1400 Toronto, Ontario M4W
1A8 1-800-387-0073 1-416-325-9195 (fax) or visit the IPC website via www.ipc.on.ca

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
1-800-387-0073
1-416-325-9195 (fax)
or visit the IPC website via www.ipc.on.ca