At Organizational Solutions Inc. the privacy and protection of personal information is important to us. We are committed to protecting the privacy, confidentiality, accuracy and security of the personal information we collect, use, retain and disclose and we are also concerned about the personal information of our employees and representatives. To ensure the protection of client files, it is forbidden to remove original files from Organizational Solutions Inc. offices.
According to the first annual report issued by the Privacy Commissioner of Canada (1984), “Privacy is not simply a precious and often irreplaceable human resource; respect for privacy is the acknowledgment of respect for human dignity and of the individuality of [hu]man[ity].” Everyone has the legal right to have their privacy respected and their personal health information protected by the health practitioners from whom they are receiving healthcare services.
Therefore, Organizational Solutions Inc. has developed strict policies to ensure clients are receiving services in a manner that protects their privacy, as well as their personal health information. Specifically, the policies incorporate all relevant privacy legislation set forth by Canada’s federal government, namely the Privacy Act, the Personal Information Protection and Electronic Documents Act (PIPEDA), and Ontario’s Personal Health Information Protection Act (PHIPA).
Privacy of personal information is a critically important principle to everyone at Organizational Solutions Inc. We are committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for our services. We also try to be open and transparent about handling personal information.
Personal Health Information
Personal information refers to information about an identifiable individual. It includes information that relates to an individual’s characteristics (e.g., name, date of birth, home address, and telephone number), health (e.g., presenting problem, health history, health services received by the individual, social situation) or activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is not the same as business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
At Organizational Solutions Inc., the privacy and protection of personal information is important to us. At Organizational Solutions Inc., we are committed to protecting the privacy, confidentiality, accuracy, and security of the personal information we collect, use, retain and disclose. We are also concerned about the personal information of our employees and representatives. In order to ensure the protection of client files, it is forbidden to remove original files from Organizational Solutions Inc. Offices.
Individuals of which OSI manages or has managed their claim/file can legally request a copy of their information/file/documents through a formal written request to Organizational Solutions Inc. Valid; written consent is required where the individual requests that OSI share their file/personal information with a designated third party.
Personal information pertains to recorded data that identifies an individual, whether communicated through oral, electronic, or written form. Organizational Solutions Inc.’s personal information typically includes, but is not limited to, an individual’s:
Note: Personal Information does not include the name, title, business address, or telephone number of an employee of Organizational Solutions Inc.)
Please note: For the security and protection of our operations staff at OSI, we do not use or publish our last names on any communication for client or claim-related purposes, including requesting additional information from care providers. We also ask that our employees not publish their last names on any forums that indicate OSI as their place of employment, including LinkedIn.
Our policy at Organizational Solutions Inc. sets high standards for collecting, using, disclosing, and retaining personal information. For our clients, the primary purpose of collecting personal information about an individual is to provide Disability Management services for that person. We collect only the information we need for the purposes of managing claims. Our files are kept for the purpose of providing an early and safe return to work and assessment information. We retain information for as long as necessary for the purpose for which it was collected and in accordance with legislation.
Organizational Solutions Inc. uses our “Careers” page that serves to communicate career opportunities. When an individual submits their resume on our website by clicking the “Submit” button, they are submitting personally identifiable information.
For members of the general public and clients, our primary purpose for collecting personal information is to provide notice of special events, such as a seminar or conference, or to make them aware of services at Organizational Solutions Inc.
We also collect and disclose information for common purposes such as:
Using email or fax to communicate health information
The privacy of client emails and faxes containing vital medical information is paramount to Organizational Solutions Inc. As with the paper record, the client has the right to privacy and confidentiality of their personally identified medical information.
Organizational Solutions Inc.’s Health Professionals have a duty to retain the confidential nature of patient records at all times. Clients will be informed of privacy issues and will be given detailed instructions regarding the information they provide over the Internet.
All client data containing sensitive and confidential information is assigned security protections to control access to the information.
This email and any attachments may be confidential or legally privileged. If you received this message in error or are not the intended recipient, you should destroy the email message and any attachments or copies, and you are prohibited from retaining, distributing, disclosing, or using any information contained herein. Please inform us of the erroneous delivery by return email. Thank you for your cooperation.
CONFIDENTIEL: Ce courriel est confidentiel et protégé. L’expéditeur ne renonce pas aux droits et obligations qui s’y rapportent. Toute diffusion, utilisation ou copie de ce message ou des renseignements qu’il contient par une personne autre que le (les) destinataire(s) désigné(s) est interdite. Si vous recevez ce courriel par erreur, veuillez m’en aviser immédiatement, par retour de courriel ou par un autre moyen.
The document accompanying this fax transmission contains confidential information belonging to the sender, which is legally privileged. The information is intended solely for the use of the individual or entity named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on or regarding the contents of this faxed information is strictly prohibited. If you have received this fax in error, we apologize and ask that you immediately notify the above by telephone to arrange for the return of the fax.
Organizational Solutions Inc.’s Health Professionals must be knowledgeable regarding the risks and benefits as well as mechanisms for protecting patient privacy, confidentiality, and systems security in our present information age.
Duty of Health Professionals
All of Organizational Solutions Inc.’s Health Professionals have a duty to retain the confidential nature of patient records at all times. Health information management includes not only the collection of patient data but also protecting it, interpreting it, and analyzing it to make decisions.
Organizational Solutions Inc.’s Health Professionals will ensure that they comply with the professional standards of their governing regulatory bodies in maintaining security accountability. Every reasonable effort will be taken to ensure subcontractors also adhere to Organizational Solutions Inc.’s privacy standards.
An Organizational Solutions Inc. internal audit of privacy practices will be conducted on a periodic basis.
The following is classed as Confidential Information:
Any information relating to the Company that is freely in the public domain may not be considered “Confidential.” In the event that an employee can prove that information was possessed before it was received from Organizational Solutions Inc. or that information was gained from an unrelated third party, said information will not be classified as “Confidential.”
Signed member consent
All claim forms include express informed consent wording, permitting Organizational Solutions Inc. to gather medical and personal information to use for the identified purpose and to share specific information with the authorized parties as necessary.
Retention of Medical Forms
Organizational Solutions Inc. has taken reasonable measures to provide security for any personal information stored in Organizational Solutions Inc.’s offices, such as passwords, read-only options, and secure filing cabinets in a secure room.
Audits are only allowed if specified in the client contract. Auditors must sign a confidentiality agreement when a claims audit takes place. Should Organizational Solutions Inc. subcontract the services outlined in the policy to another firm, Organizational Solutions Inc. will require the subcontracted firm to commit in writing (signed and dated) to the complete privacy and security of any personal information to which they may have access.
Claims Audit Agreement
If there is a suspected or actual breach of a client’s private and confidential information, Organizational Solution Inc. must:
If you require more information in regard to our privacy breach process, please contact us at email@example.com.
We are required by legislation to retain personal information for a period of time to ensure that we can answer any questions clients might have about the services provided and for our own accountability to regulatory colleges.
As required by our regulatory colleges, Organizational Solutions Inc. retains personal information for seven years following the client’s last contact or, if the client was less than 18 years of age at the time of the last contact, for ten years following the day the client would have turned 18.
Under our general correspondence, we keep any personal information relating to people who are not clients contained in newsletters, seminars, and marketing activities for six months after the newsletter ceases publication or a seminar or marketing activity is over.
Once a file has been retained for the time outlined above, we destroy it consistent with PHIPA guidelines. To safeguard the privacy of Organizational Solutions Inc. clients, we cross-shred paper files containing personal information. We destroy electronic information by securely deleting or overwriting it (whichever is more secure), and once the hardware is discarded, we ensure the hard drive is physically destroyed. Provide for withdrawal of consent- Clients have the right to withdraw consent at any time (subject to legal or contractual restrictions and reasonable notice); OSI provides a convenient way for them to do so easily, inexpensively, and with immediate effect. Withdrawal of consent can be completed by emailing firstname.lastname@example.org or calling 905-315-7179 or 1-866-674-7656. We may ask that all requests be made in writing to Organizational Solutions Inc. If we cannot provide access, we will inform the requesting individual/client within a secure and timely manner and provide a reason why we cannot provide access.
In working for Organizational Solutions Inc., employees shall not divulge, disclose, provide or disseminate Confidential Information to any third party not employed by Organizational Solutions Inc. at any time, for any reason, unless Organizational Solutions Inc. gives written authorization.
Furthermore, Confidential Information shall not be used for any purpose other than its reasonable use in the normal performance of employment duties for Organizational Solutions Inc.
Upon termination of employment with Organizational Solutions Inc., employees shall promptly return (without duplicating or summarizing) any and all material pertaining to Organizational Solutions Inc. business in their possession, including, but not limited to, all client information (charts, lists, etc.), physical property, documents, keys, electronic information storage media, manuals, letters, notes, and reports.
We understand the importance of protecting personal information. For that reason, we have taken the following steps in the storage and maintenance of our client’s personal information and personal health information, consistent with PHIPA and PIPEDA requirements:
The purpose for which any personal information is being collected will be identified before or at the time the information is collected.
The personal information will be limited to that which is necessary for the purposes identified. Personal information will be collected under policies and procedures that are fair and lawful.
Limiting Use, Disclosure, and Retention
Personal information will not be used, disclosed, or retained for purposes other than those for which the information was collected unless the individual gives permission for another reason or it is permitted under law. Personal information will be retained as long as the file is active and for such periods as prescribed by applicable laws. A file will be deemed inactive when the case is closed. Information in an inactive file will be retained for seven (7) years, except in cases in which a long latency disease exists, e.g. hearing loss or there is a current legal issue or ligation in progress. Long-latency disease files will be retained for 30 years. Guidelines will be developed with respect to the destruction, erasure, or anonymizing of personal information once it is no longer required.
Personal information will remain accurate, complete, and current as necessary for the identified purposes for which it is to be used.
Organizational Solutions Inc. will protect personal information with safeguards appropriate to the sensitivity of the information provided (Please refer to the Employee Procedure for Safeguarding Personal Information Policy). Personal information is only transmitted via email when using password-encrypted PDF documents.
Organizational Solutions Inc. will make specific policies and procedures for an individual’s personal information available in a manner that the information is readily available and easy to understand.
Individual Access-Client access to records
It is the policy of Organizational Solutions Inc. that clients have a legal and moral right to know what information is contained about them in their records.
If a client believes there is a mistake in the information contained in their record, they have the right to ask for it to be corrected; this applies to factual information and not to any professional opinions we may have formed. We may ask that clients provide documentation that supports the notion that our files are incorrect. If changed, a statement of changed information is included in the record. If the request for a change is declined, the client may file a notice of disagreement in the record.
Organizational Solutions Inc. will give access to an individual who wishes to review or verify personal information. A written request must be sent to email@example.com.
Upon request to review, their file identity will be verified. Once identity is verified, the individual will be permitted to review personal information that has been collected; individuals can make a request in writing to Organizational Solutions Inc. and, within a reasonable amount of time, ask how their personal information is being used and to whom it has been disclosed.
Individuals can address any complaint or suggestion regarding compliance with the above principles. Organizational Solutions Inc. has policies and procedures to receive, investigate, and respond to complaints and suggestions. You may learn more about these policies and procedures by contacting the Privacy Officer at 905-315-7179 or 1-866-674-7656.
B) General Private Sector Privacy Acts:
Liz R. Scott, Privacy Officer / CEO
ORGANIZATIONAL SOLUTIONS INC.
2186 Mountain Grove Ave., Suite #253
Burlington, ON L7P 4X4