Privacy

As a provider of healthcare services to adults with physical disabilities and acquired brain injuries Traverse Independence collects, uses, discloses, retains and protects personal information about its clients. Traverse Independence is a personal health information custodian under the Ontario Personal Health Information Protection Act, 2004.

Traverse Independence is committed to protecting the privacy, confidentiality, and security of all personal information to which it is entrusted.

What is "Personal Information"?

Personal information is information that is about or can be linked to an identifiable individual.  Personal information includes personal health information.

"You" and this Privacy Policy

Traverse Independence may hold personal information about its clients. Our commitment to appropriately handle personal information extends not only to the client but also to their family. Accordingly, any reference in this privacy policy to "you" or "your" may be taken where the context permits as a reference to both you and your family.

Collection, Use and Disclosure of Personal Information

Traverse Independence collects and shares with appropriate health service providers personal information in order to:

• determine your eligibility for services
• assess your requirements for services
• develop with you an Individual Service Plan
• provide you with services
• assess resources
• monitor and evaluate the quality of services provided.

Traverse Independence only collects, uses and discloses personal information necessary for the purposes identified and within the limits of each staff member’s identified job role.  If we wish to use or disclose your personal information for any other purpose, we will seek your consent unless consent is not required by law.

Traverse Independence may disclose information to a third party health care provider that you or your family has contracted to provide health services to you or to other health care custodians that provide you with health care services. Traverse Independence may also disclose personal information when legal obligations require this.

Personal Information We Collect and May Disclose

The amount and type of personal information we may hold about you depends on the nature of the services that we provide to you.

Personal information collected regarding clients may include name, address, birth date, health information, current service providers and services being received, personal historical information and contact information.

Traverse Independence collects personal information primarily from its clients. Traverse Independence may also collect personal information from other sources such as clients' families, clients' professional advisors (accountants, trustees), health care providers (e.g. doctors, case managers and other health professionals), and other third parties that represent that they have the right to disclose the information to Traverse Independence.  We may collect from and exchange personal information with government and other funding bodies.

Traverse Independence may disclose information to a third party health care provider that you or your family has contracted to provide health services to you or to other health care custodians that provide you with health care services.

Consent

By applying to Traverse Independence for services and by entering into a service contract with Traverse Independence, you confirm the following:

• you consent to the collection, use and disclosure by Traverse Independence of your personal information for the purposes described in this privacy policy
• you have obtained the consent of each member of your family to the collection, use and disclosure by Traverse Independence of his or her personal information for the purposes described in this privacy policy where applicable
• you will give to your family members a copy of this Privacy Policy and make them aware of the contents of it.

The form of any other consent sought by Traverse Independence may vary, depending on the circumstances and type of personal information involved.

You may inform Traverse Independence that you are withdrawing your consent at any time, subject to legal or contractual restrictions and reasonable notice. A withdrawal of consent must be in writing.  However if you withdraw your consent Traverse Independence may not be able to provide you with services and may terminate any service contracts between you and Traverse Independence providing for such services.

Security

Traverse Independence maintains administrative, technical and physical safeguards to protect personal information in its control against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. These safeguards are appropriate to the sensitivity and nature of the information. We have made our employees aware of the importance of maintaining the confidentiality of personal information.

Retention

Traverse Independence retains your personal information for a sufficient time for the purposes for which it is collected and for such period thereafter as may be required by law. Traverse Independence has adopted minimum and maximum retention periods for personal information.

Keeping Information Accurate

Traverse Independence will use reasonable efforts to ensure that your personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Traverse Independence will update or amend any personal information that it holds about you if it is provided with updated or amended information by you. Please keep us informed of changes to your personal information.

Access to Personal Information

You may review and revise, correct or update any of the information that Traverse Independence has on file about you at any time and you may also learn how Traverse Independence has used it and to whom Traverse Independence has disclosed it.

If you wish to review or update your information, you may do so by contacting Traverse Independence in any of the ways described below. Depending upon the nature of your request, we may require you to properly identify yourself to verify your right to receive the personal information requested.

Complaints

An individual shall be able to address a challenge concerning compliance with Traverse Independence's privacy, confidentiality and security to the privacy officer who will provide him or her with Traverse Independence's complaint procedure.

Complaints may also be directed to the Information and Privacy Commissioner of Ontario.

How to Contact Us

If you have questions or concerns regarding this privacy policy or Traverse Independence's collection, use and disclosure of your personal information, or to make an access request or for further information about Traverse Independence's privacy practices, please contact the Traverse Independence Privacy Officer at the address below.

Traverse Independence will answer your written inquiries about this Privacy Policy and its procedures and personal information management practices within 30 days, or up to 60 days upon extension, and in as understandable a format as possible.

Changes to this Privacy Policy

Traverse Independence reserves the right to revise this Privacy Policy from time to time. The date this Privacy Policy was last revised appears below.

(August, 2020)