The purpose of this Act is to protect the privacy rights of all Canadians and to establish rules for the collection, use or disclosure of personal information by organizations in the course of any commercial activity.

Effective January 1, 2004 the Halton Hills Speech Centre will be obtaining consent for each individual before collecting or using any personal information. The information will be collected by fair and lawful means. The Halton Hills Speech Centre will not deny any treatment to individuals who refuse consent unless the information is required to carry out treatment.

The Halton Hills Speech Centre has implemented the following Privacy Policy as required by PIPEDA.

The Halton Hills Speech Centre collects specific information on individuals. The primary purpose for this collection of information is to:

1. identify client information for assessment and/or treatment purposes;
2. advise clients of the need for follow-up appointments;
3. collect information about the general public to further awareness of speech and language issues.
4. collect information on employees, contract staff, volunteers and students. This will allow us the opportunity to provide performance appraisals, provide feedback to instructors or write references, if requested.
5. advise clients of alternate therapy options, if appropriate.

The secondary purposes for collection of information is to:

1. advise individuals of upcoming seminars or new programs that the Halton Hills Speech Centre is preparing;
2. assist with the Halton Hills Speech Centre database. This information allows the Halton Hills Speech Centre to track client satisfaction. The Halton Hills Speech Centre distributes questionnaires on a yearly basis which will help with improvement of services;
3. track demographics of clients in regards to geography, referral source, age group to assist with expansion of services to specific populations;
4. assist with billing and accounting purposes to ensure that all financial issues are handled in a timely and orderly manner;
5. work with third parties (e.g. Bookkeeping services, Legal services, Information Technology, Janitorial Services) No information will be released to third parties unless they have entered into a confidentiality and non-disclosure agreement with the Halton Hills Speech Centre;

The knowledge and consent of an individual is required prior to the collection, use or disclosure of information. All individuals contacting the Halton Hills Speech Centre will be asked for consent to obtain the above information. This will be documented on the intake form. On the date of the initial assessment a Service Agreement will be provided with information about the Privacy Policy and the opportunity will be given to give consent. Any consent that has been given can be withdrawn at any time, as required by law.

Any information obtained may be disclosed without the consent of the individual party, if required by law or in an emergency situation where it is felt to be in the best interests of the individual.

Further consent is required from an individual if the Halton Hills Speech Centre wishes to use information in a way that is not outlined above. The individual will be contacted for this consent prior to any use or disclosure of information by the Halton Hills Speech Centre.

Information collected shall be limited to the purposes identified.

Information collected for the purposes stated above will only be used for the purposes stated above. Information collected will not be used for any other purpose without the prior consent of the individual. The Halton Hills Speech Centre will contact the individual to obtain consent and to document the consent if information collected is to be used for another purpose.

Information collected will be kept for (10 years past a child's eighteenth birthday, or 10 years post treatment), as outlined by the College of Speech-Language Pathologists and Audiologists of Ontario. The information will be destroyed at the end of this time period. Destruction of records is carried out by shredding within the offices of the Halton Hills Speech Centre using a cross-cut shredder. Electronic information is destroyed by deleting it from the hard drive.

Personal information will be released to third parties only if the release is required by law or if a third party has entered into a confidentiality and non-disclosure agreement with the Halton Hills Speech Centre. There are no other circumstances under which our company will provide personal information to third parties.

All information collected is to be kept accurate, complete and up-to-date. Information will be reviewed on an annual basis by the office staff of the Halton Hills Speech Centre to ensure accuracy. All individuals will be contacted within the month of each year following initial intake of information to have their information reviewed and corrected until it is determined that the information is no longer pertinent or necessary, at which time it will be destroyed as outlined above.

It is of utmost importance to the Halton Hills Speech Centre that all information collected is protected in a manner appropriate to its sensitivity. This will ensure that no unauthorized access will be allowed.

Physical Security: All information contained in charts, reports or other media will be held in locked filing cabinets with access restricted to everyone except for office staff and Speech-Language Pathologists that require the information to perform their daily tasks.

All telephone conversations will be held in the strictest confidence. Individuals may be requested to be placed on hold temporarily or may be requested by the office staff to leave a number where they may be reached. This will ensure that any conversation between the individual and the office staff will remain confidential. No conversations between individuals and staff or contractors of the Halton Hills Speech Centre will be carried out via speakerphone. Appointment bookings and reminders will also be carried out in a confidential manner.

Organizational Security: All computers have password protected screensavers as well as staff pass codes. This will ensure that no unauthorized personnel will have access to information collected from individuals. The computer network of the Halton Hills Speech Centre is set up in such a way that all individual specific reports are filed in an area that is accessible only to the Speech-Language Pathologist preparing the reports and the office staff responsible for its distribution.

Technological Security: The Halton Hills Speech Centre is very much aware of the need for security with respect to information accessed via websites, e-mail or fax. The website of the Halton Hills Speech Centre is maintained by Collett Designs. All information collected on our website is stored in a secure location and is accessible only by designated staff of the Halton Hills Speech Centre.

No client sensitive information will be sent via E-mail. All such documentation will be sent either as a .pdf file or encrypted to ensure that no unauthorized personnel has access to this information and that the information cannot be changed by anyone other than the reporting Speech-Language Pathologist.

All faxes distributed from the Halton Hills Speech Centre will include a cover page outlining the person, company and fax number it is being sent to. It will also state the name of the originating person from the Halton Hills Speech Centre. Faxes will also clearly state that the Halton Hills Speech Centre is to be contacted if a fax is received in error to ensure correction of information.

Individuals have the right to know what information the Halton Hills Speech Centre has collected from them as well as how it is to be used. Individuals also have the right to amend any information that is incorrect. Any individual requesting access to their information must contact the Privacy Officer at the Halton Hills Speech Centre at 905-873-8400. The individual will be requested to complete a Personal Information Request form as well as make an appointment with the Speech-Language Pathologist responsible for the individual's file and/or the Privacy Officer with respect to general information gathered about them.

The individual has the right to review these records in the presence of the Speech-Language Pathologist and/or Privacy Officer. The individual is then able to satisfy their request or have corrections/amendments made under the guidance of the Speech-Language Pathologist and/or Privacy Officer. Corrections may only be made to factual information and not professional opinions. The individual may be requested to provide documentation stating that information in the file is incorrect. If an error has been made, a statement will be added outlining the correction and notification will be sent to anyone receiving the initial information. If there is no consensus as to whether an error has been made a statement will be added outlining the discussion and resulting change, if any.

Information in a chart or document that is not relevant to that particular individual and which may infringe upon the rights of others will not be disclosed. Information in a chart or document will not be accessible if the Speech-Language Pathologist feels it would not be in the best interest of the individual.

If access to information cannot be given, the individual will receive a letter from the Privacy Officer within 30 days outlining why the information is not accessible.