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PRIVACY POLICY – DYNAMIC FUNCTIONAL SOLUTIONS INC.


Privacy of personal information is an important principle to Dynamic Functional Solutions Inc. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. Our company strives to be open and transparent as to how we handle personal information, and we freely disclose our privacy policies to our customers.

The following document describes our privacy policies.

WHAT IS PERSONAL INFORMATION?


Dynamic Functional Solutions Inc. considers personal information to be information about an identifiable individual.

Personal information includes information that relates to an individual’s:

  • personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status);
  • health (e.g., health history, health conditions, health services received, current medical status); or,
  • activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).

Personal information is different from business information (e.g., an individual’s business address and telephone number), and is not protected by privacy legislation.

WHO WE ARE


At the time of writing, Dynamic Functional Solutions Inc. includes 30 administrative staff as well as a roster of 500+ health professionals (regulated and certified).

We also 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, accountants 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.

THE COLLECTION OF PERSONAL INFORMATION: PRIMARY PURPOSE

About Clients


As a medical assessment service provider, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide assessment services. For example, we collect information about a client’s health history, physical condition and function, as well as psychosocial status in order to help us assess what their health needs are.
A secondary purpose for obtaining a baseline of health information is so that in providing ongoing health services we can identify changes that occur over time.

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. Examples of the type of personal information we collect for those purposes include registration numbers, home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it may happen in the case of a health emergency (e.g., an H1N1 flu virus outbreak).

About Members of the General Public


While we rarely require information from members of the general public, our primary purpose for collecting such personal information is to provide notice of special events (e.g., when hiring) or to make known the services provided by Dynamic Functional Solutions Inc. For example, while we try to use work contact information when possible, we may collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not for any reason possible, we will upon request immediately remove any personal information from our distribution list.

WE COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES


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

  • To invoice customers for goods or services, or to collect unpaid accounts.
  • The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., OHIP, WSIB, private insurance, Assistive Devices Program). These third-party payers often have our clients’ 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 goods or services after they have been received. We also provide ongoing services for many of our clients for which our previous records are helpful. We retain our client information to enable us to respond to those questions and provide these services.
  • In the event that Dynamic Functional Solutions Inc. or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of our 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 written assurance 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.

Dynamic Functional Solutions Inc. offers our customers and clients the opportunity to be omitted from some of these related or secondary purposes.

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 computers. All of our cell phones are digital as these 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 has identifiers removed or is encrypted.
  • Employees 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 you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We keep our client files for ten years.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, the hard drive is physically destroyed to ensure any information previously stored on it cannot be retrieved.

CAN CLIENTS LOOK AT THEIR INFORMATION


Clients are generally not afforded the opportunity to see what personal information we hold about them. With only a few exceptions, Dynamic Functional Solutions Inc. will direct our clients to seek this information from our customers or third parties who have paid for the assessments.

When the client has already obtained the information from our customer, we will try to help them understand any information they do not understand (e.g., short forms, technical language, etc.). We confirm their identity, before providing them with information.

If we are directed by our customers or a higher authority to provide the personal information we have regarding a client, we are able to do so. We reserve the right to ask that such requests be made in writing.

If there is a problem with the information that we have, we may ask our clients to put their request in writing. If our clients believe 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 rendered by our Medical Evaluators. We may ask clients to provide documentation that indicate our files are wrong. Where we agree that we have made a mistake, we will make the correction and notify any party to whom we sent this information. If we do not agree that a mistake has been made on our part, we will still agree to include in our file a brief statement from the client on the issue, and that statement will be forwarded onto any other party who had received the initial information.

DO YOU HAVE A QUESTION?


Our Information Specialist, Simon Mah can be reached at:
120 Traders Blvd, Suite 105 | Mississauga, ON | L4Z 2H7
Phone 1 (877) 897-5515

He will attempt to answer any questions or concerns you may have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Specialist. He will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal written decision with reasons.

If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we ask that you discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to their regulatory body.

This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

112 Kent Street
Ottawa, Ontario K1A 1H3
Phone (613) 995-8210 | 800-282-1376 | Fax (613) 947-6850 | TTY (613) 992-9190
www.privcom.gc.ca





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