Privacy Policy
Purpose
The George Hull Centre is committed to meeting the highest standard of ethics with respect to the collection, use, security and disclosure of personal information with clients, staff, consultants, volunteers, donors and business associates. We are committed to meeting or exceeding the privacy standards established by relevant legislation, including Ontario’s Personal Health Information Protection Act (PHIPA) and Part X of the Child, Youth and Family Services Act.
Definitions
Personal Health Information (under the Personal Health Information Protection Act)
Personal health information is “identifying information” about an individual, whether oral or recorded. It includes any information about an individual’s health or health care history. “Identifying information” means information that could identify an individual when used alone or with other information.
The types of personal health information we collect, use and store may vary depending upon the individuals involved and the nature of their relationships with The George Hull Centre. For clients (children, youth and families), we collect personal health information that may include a client’s name, address, date of birth, health card information, and personal/family information related to assessment, diagnosis, medication, counselling and treatment.
Personal Information (under Part X of the Child, Youth and Family Services Act)
Personal information is information about an identifiable individual, such as:
- information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual,
- information relating to the education or the medical, psychiatric, psychological, criminal or employment history of the individual,
- the personal opinions or views of the individual,
- the views or opinions of another individual about the individual,
- correspondence by the individual that is implicitly or explicitly of a private or confidential nature, and any replies to that correspondence that would reveal the contents of the original correspondence.
When Do We Need Consent?
The George Hull Centre will not collect, use or disclose personal health information and/or personal information (hereafter called ‘client information’) without a client’s consent, or his or her parent’s or substitute decision maker’s consent, or as required by law. For most purposes, consent is implied as a result of consent to treatment. However, in some circumstances, express, and sometimes written, consent may be required.
We may rely on a client’s or parent’s implied consent to share their information with an authorized agent, as long as the sharing is related to the provision of service and the client has not expressly stated otherwise.
In the event that there is a finding of incapacity to consent with respect to a client, (i.e. the person providing the service is of the opinion that the client cannot understand the information relevant to making an informed decision and/or cannot appreciate the reasonably foreseeable consequences of the decision), the consent of a Substitute Decision Maker will be obtained as required by and set out in relevant legislation.
How We Use the Information We Collect
The use of information may vary depending upon the individuals involved and the nature of their relationships with us.
With limited exceptions, we obtain most personal health information directly from our clients and collect only as much information as is necessary to meet the purpose of the collection.
The use of personal information will be limited to the purposes for which the information is collected.
Client information may be used:
- To provide assessment, counselling and treatment services;
- For quality assurance and accreditation purposes to determine the effectiveness of services with the goal of improving services;
- For the purposes of analysis or compiling statistical information with respect to the management of, evaluation or monitoring of services, the allocation of resources or service planning;
- To comply with all legal and regulatory requirements;
- To contact individuals regarding upcoming events, activities, and programs that may be of interest.
Unless otherwise required by law, The George Hull Centre does not share personal information with third parties without specific consent.
We will not share client information with anyone outside of The George Hull Centre, our authorized agents or other health care providers involved in a client’s care, without his or her consent.
We will only share client information with other professionals, agencies and schools who are involved in the care, education and treatment of a client if the client or his or her parent/guardian provides consent for us to do so.
Exceptions:
- There may be circumstances where we are required by law or a court order to share client information with others. This includes an obligation to contact police when we learn that an individual may be at risk of harm and to report to the Children’s Aid Society all incidents of suspected child abuse, neglect or a reason to believe that a child may be in need of protection. It also includes requirements to provide statistical information used for service system planning to funders.
- Personal Information and Personal Health Information collected from clients (including information about the client and family and the types of services received) is provided to the Lead Agency for Toronto, East Metro Youth Services. The Lead Agency may conduct analysis on the aggregated data it receives for the purpose of planning the delivery of better services to our clients. De-identified information is also sent to the Ministry of Health, who funds the services, on a periodical basis for the purpose of conducting province-wide analysis and planning on the services provided.
Safeguards and Security
All information is protected by physical and electronic security measures appropriate to the nature of the information, and is accessible only by authorized personnel.
Retention of Client Records
Client records are retained for a minimum of 10 years after the client’s 18th birthday, with the following exceptions and notes:
- Residential treatment programs: client records are retained for 20 years after the last entry in the record with respect to the resident, or, where the resident dies, for 5 years after the death of the resident (CYFSA 2017, Reg.156/18, s.93(2)). In the event that a residential program closes, client records are transferred from The George Hull Centre to the Ontario Ministry of Children, Community and Social Services;
- Preschool Speech & Language: client records closed in the same year are destroyed once the youngest participant has turned 28;
- Family Group Conferencing Toronto: client records are retained for 7 years after the date of closure.
The Clinical Records coordinator and supervisor are responsible for the destruction of files once each year. Hardcopy files are shredded on-site. A cross-check is performed between a computer printout and the hardcopy files to ensure that all files are accounted for, and to prevent accidental destruction of files before the end of the period. Any missing hardcopy files are added to the printouts used for subsequent years. Electronic files are deleted, except for Family Group Conferencing records where the data is de-identified rather than deleted.
Registration information collected for participants in non-treatment groups, such as name, address, and date of birth, will be destroyed in the next fiscal year following the group.
Client registration and attendance data for participants in EarlyON Centre programs is collected electronically into Excel spreadsheets and transferred each quarter into EYSIS, a centre-based electronic database. Excel spreadsheets are deleted when the data is transferred to EYSIS.
YellowSchedule contact data for inactive clients is deleted once per year. Inactive clients are those that have not been sent reminders in the 12-month period prior to the removal date.
Partially completed intake records and accompanying material will be retained for one year and then destroyed if the intake is not completed.
Contact Information
Questions, concerns or complaints relating to the Centre’s privacy policy on the treatment of personal information should be sent to the attention of the Privacy Officer at the Centre, who is appointed by the Executive Director:
Rick Arseneau
Privacy Officer
81 The East Mall, 3rd floor
Toronto, Ontario
M8Z 5W3
416 622 8833 (237)
For more information, you can contact the Information and Privacy Commissioner of Ontario:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario
M4W 1A8
416 326 3333 or 1 800 387 0073
www.ipc.on.ca
info@ipc.on.ca