Our multi-disciplinary team consists of healthcare professionals, such as physiotherapists, occupational therapists, speech-language pathologists, and students, as well as office administrative staff. Together, we act as Health Information Custodians (HIC) or agents of our clients Personal Information and Personal Health Information. Butterfly Pediatric Therapy is responsible for the actions of our agents.
What is Personal Information?
Personal Information means information about an identifiable individual, such as your name, your child’s name, your postal address, email address, phone number, health information, and your child’s date of birth.
This policy does not apply to non-personally identifiable information, business contact information, or any information that you voluntarily share on publicly accessible websites (such as the comments section of our website, or on our social media pages).
Non-personally identifiable information and Cookies
Non-personally identifiable information includes any information that cannot be used to identify you, such as your website browsing activity, type of web browser, or aggregated statistical data such as time spent on the site or number of visitors to the site. Like many websites, we also use “cookies” to collect information. A cookie is a small data file that we transfer to your smartphone or computer’s hard disk for record-keeping. Non-personally identifiable information can be collected by us, and shared with third parties. Non-personally identifiable information may be used to administer the website, and improve the overall effectiveness of our website. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the website.
What is Personal Health Information?
Personal Health Information means identifying information about an individual in oral or recorded form, if the information relates to the health of an individual, and can include (amongst other information as defined in PHIPA):
- the physical or mental health of the individual, including information that consists of the medical history of the individual’s family;
- information relating to the providing of health care to the individual, including the identification of a person as a provider of health care to the individual; or
- information relating to payments or eligibility for health care in respect of the individual.
When do we Collect Personal Information or Personal Health Information?
We collect certain types of Personal Information and Personal Health Information when you engage the services of Butterfly Pediatric Therapy.
When you first register your child with Butterfly Pediatric Therapy for health care services (physiotherapy, occupational therapy, or speech-language pathology), we gather data for identification purposes along with brief medical history and primary concerns which is followed by a fulsome discussion regarding your child’s medical history, physician information, and other relevant medical information. We will generally ask you to provide your express informed consent in writing for the collection and use of your Personal Health Information.
As we proceed with meeting your child’s therapeutic needs, you may share or we may ask for updated medical information. We keep and maintain notes regarding each visit. These records constitute your child’s Personal Health Information.
We also require certain mandatory Personal Information which are necessary to enable our services, such as parent/guardian full names, emergency contact information, your child’s home address, your child’s date of birth, phone number.
Other examples of where we may collect and you may consent to providing us with Personal Information include entering a contest, filling out a survey, posting a review, submitting feedback, providing your email address for the purpose of receiving offers, updates, scheduling information, and newsletters.
What do we Use your Personal Information or Personal Health Information for?
Your Personal Health Information and Personal Information will only be used as necessary to provide you with our services.
We use Personal Health Information to provide our clients with health care services (physiotherapy, occupational therapy, or speech-language pathology). Personal Information and Personal Health Information may be used for the following purposes: (i) to create and maintain your client file; (ii) administer your use of our services; (iii) to provide administration services in respect of payments; (iv) to fulfill requests you may make, such as feedback or answering your questions; (v) to contact you; (vi) to comply with all applicable laws, cooperate with law enforcement, (vii) with your consent, to communicate with you via email regarding our services, such as providing you with your child’s appointment schedule, rescheduling or cancelling appointments, or answering any questions you may have regarding our services, (viii) with your consent, provide you with further information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing, fundraising, or promotional materials, and other information on services and products offered by us or third parties.
We will only retain your Personal Information and Personal Health Information for so long as it is necessary to fulfill your use of our services, and for legal, business and regulatory compliance, such as compliance with our regulatory Colleges. We ensure that any documents containing Personal Information or Personal Health Information are destroyed in a secure and irreversible manner.
Providing and Withdrawing Consent
You may withdraw your consent, or modify your consent (such as providing limitations or conditions on your consent), at any time.
Certain types of Personal Information and Personal Health Information in respect of the services are mandatory and necessary for the services that we are providing. If you do not provide the mandatory Personal Information or Personal Health Information, we cannot provide you with our services.
In certain circumstances, we may rely on your implied consent, unless you have expressly withdrawn or withheld consent.
Other types and uses of Personal Information are voluntary, and are only collected with your express consent. For example, if you sign up for email communications to receive our emails, offers, or newsletters, you are expressly volunteering and consenting to provide the information. You may withdraw your consent in respect of voluntary Personal Information at any time.
If we intend on viewing, collecting, using, or disclosing your Personal Information or Personal Health Information for a previously undisclosed purpose, we will obtain your consent before doing so, unless otherwise permitted by law.
Who can we Disclose your Personal Information or Personal Health Information to?
Butterfly Pediatric Therapy will only share your Personal Health Information or Personal Information as is necessary to administer and fulfill the services, and with your express consent (unless otherwise permitted by law). For example, you may wish for us to discuss your child’s progress or needs and share Personal Health Information with your child’s school or Children Treatment Centre therapist, with an equipment vendor, with a fundraising organization (such as Easter Seals), a third-party payor (such as the Assistive Devices Program or an insurer), or with your child’s physician.
We are permitted by law to disclose Personal Health Information in the event of an emergency.
Butterfly Pediatric Therapy may disclose your Personal Information to authorized third parties to administer the services, such as administering and processing payments, providing customer service, sending you emails and administering contests.
Butterfly Pediatric Therapy cooperates with government, regulatory and law enforcement officials, and private parties to enforce and comply with the law. We will disclose information as necessary or appropriate to respond to claims and legal processes, to protect the property and rights of Butterfly Pediatric Therapy or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. Butterfly Pediatric Therapy may disclose your information on a confidential basis to parties connected with a financing, sale, or other disposal of all or part of the business or assets.
Accessing and Updating Personal Information and Personal Health Information
With limited exceptions provided by law, you may view, update, correct our Personal Information and Personal Health Information by contacting us at email@example.com. For example, we may not delete our professional opinions as recorded in our client files, even if you disagree with our opinion. However, if there is an error in your file, we may be able to correct it.
We can facilitate your request to delete your Personal Information or Personal Health Information if we are not required to retain such information for business, regulatory, or legal reasons. If you delete mandatory information, you may not access our services. Please let us know of any changes to your Personal Information as soon as possible.
Security of Personal Information
We will notify you in the event of any theft, loss, or unauthorized use or disclosure of your Personal Health Information, report privacy breaches to the Information and Privacy Commissioner of Ontario, and report the same to our regulatory colleges, as required under PHIPA. You are also entitled to make a compliant to the Information and Privacy Commissioner of Ontario regarding any such privacy breaches.
Comments, Concerns and Questions
Please contact Keiri Porter, Privacy Officer at Butterfly directly at firstname.lastname@example.org
Last Updated: June 17, 2019