Genesis Community Rehabilitation, Inc. provides community rehabilitation support and training. We provide progress notes and reports for persons living with the effects of an acquired brain injury and/or a mental health diagnosis. In the course of providing these services, we collect personal information about our clients in order to provide them with the most effective service.

Privacy of personal information is important to Genesis Community Rehabilitation, Inc. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We strive to maintain professionalism while handling personal information. All personal information under the care and control of Genesis Community Rehabilitation, Inc. shall be regarded as confidential and available only to employees of Genesis Community Rehabilitation, Inc. Personal information will only be used for the purposes for which it was collected. Exceptions include consent of the individual or as required by law.

All employees or persons providing services on behalf of Genesis Community Rehabilitation, Inc. will be subject to this policy. This document describes our privacy policy.

Primary Purpose and Consent

Our primary purpose for collecting personal information about clients is to understand their rehabilitation needs. We collect information regarding the client's accident or illness, medical health history, current physical condition and functioning as well as psychosocial situation in order to help determine what the needs are and then to provide a written report based on this information to the client’s insurance company.

What is Personal Information?

Personal Information includes any factual or subjective information, recorded or not, about an identifiable individual (for example, age, name, medical history, religion, gender, family status, income, ethnic origin, social status). Personal information does not include the name, title, and business address or business telephone number of an employee of an organization, which is not protected by privacy legislation.

Who we are

Our agency includes at the time of writing, associates who specialize in providing care to clients who have acquired brain injuries, mental health diagnoses and spinal cord injuries. We use a number of consultants and agencies that may, in the course of their duties, have limited access to the personal information we hold. These include computer consultants, office security and maintenance workers, bookkeepers and accountants, temporary workers, credit card companies, cleaners and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles by having them sign confidentiality agreements.

Why We Collect Personal Information

About Clients:

Like all rehabilitation professionals, we collect, use and disclose personal information in order to serve our clients. The primary purpose for collecting personal information is to provide written observations of physical, cognitive and behavioural issues that will be assessed and treated by regulated health professionals (i.e. Occupational Therapists, Speech Pathologists, Physiotherapists, Psychiatrists, Psychologists and Case Managers). For example, we collect information about a client's health history including family history, physical condition and function as well as social situation in order to help us observe what their current rehabilitation needs are. We then report the findings to the client's Case Manager, O.T., P.T., S.L.P. and insurance company on a weekly basis. Another primary purpose is to obtain a baseline of health and social information so that, in providing ongoing rehabilitation services, we can identify changes that are occurring over time.

About Members of the General Public:

The primary purpose for collecting personal information from members of the general public is to provide notice of upcoming special events (e.g., seminars or conferences), or to make them aware of particular rehabilitation services available.

For example, while we try to use work contact information where possible, we might also collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information. At any time and for any reason upon request, we will immediately remove any personal information from our distribution list.

About Contract Staff:

For people who are contracted to do work for us, our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending out payments). Examples of the type of personal information we collect for these purposes include resumes, home addresses and telephone numbers.

It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g. a SARS outbreak) or to investigate a possible breach of law (e.g. if a theft were to occur in the office). If contract staff wishes a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.

Why We Collect Personal Information: Related and Secondary Purposes

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

• To invoice customers for services not paid for at the time, or to collect unpaid accounts.
• To advise customers that the service should be reviewed (e.g. to ensure their satisfaction with the service provided).
• To advise customers and others of special events or opportunities (e.g., a seminar, development of a new service) that we have available.
• Our company reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf complete audits and continuing quality improvement reviews of our company, including reviewing client files and interviewing our consultants.
• Our Rehabilitation Support Workers are unregulated professionals that are members of the Vocational Rehabilitation Association of Canada (VRA) and/or the Ontario Association of Consultants, Counsellors, Psychometrists and Psychotherapists (OACCPP). 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 clients, 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 consultants 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.
• The cost of most services provided by the organization to clients is paid for by third parties (e.g. private insurance, OHIP and WSIB). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
• Clients or other individuals we deal with may have questions about our services after they have been received. We also provide ongoing services for many of our clients over a period of months or years, for which our previous records are helpful. We retain our client information for a minimum of seven years after the last contact to enable us to respond to those questions and provide these services. If Genesis Community Rehabilitation, Inc.’s assets were to be sold, the purchaser would want to conduct a “due diligence” review of the organization’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.

Protecting Personal Information

We understand the importance of protecting personal information. For that reason, we 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, passwords are used on all computers. All of our cell phones are digital, which signals are more difficult to intercept.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either through a direct line or is anonymized or encrypted.
• Our professionals are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• External consultants and agencies with access to personal information must enter into privacy agreements with us.

Retention and Destruction of Personal Information

We need to retain personal information for some time to ensure that we can answer any questions that clients might have about the services provided and for our own accountability to external regulatory bodies. However, we will not keep personal information for too long or unnecessarily in order to protect our client’s privacy.

We keep our client files for about seven years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting them again. However, if asked, we will remove such contact information right away. We keep any personal information relating to our general correspondence (i.e., with people who are not clients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire client file to our customer.

Clients Can Review Their Information

Subject to specific legislative limitations and exceptions, patients/clients (or their legal representatives) may access their own personal information contained in records held by Genesis Community Rehabilitation, Inc. This means that with only a few exceptions, clients have the right to see what personal information we hold concerning them. Often clients just have to ask. We can help clients identify what records we might have about them. We will also try to help clients understand any information they do not understand (e.g. short forms, technical language, etc.) We will need to confirm their identity, if we do not know them, before providing access. We reserve the right to charge a nominal fee for such requests.

If there is a problem we may ask our client to put the request in writing. If we cannot provide access, we will advise the client within 30 days if at all possible and advise of the reason, as best we can, why access cannot be given.

If a client believes there is a mistake in the information, they have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask clients to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from the client on the point and we will forward that statement to anyone else who received the earlier information.