Privacy Policy

ACCOUNTABILITY

Organizational Solutions Inc. has implemented guidelines and procedures that protect the way we collect, hold and use personal data that clients and their employees submit. Organizational Solutions Inc. acknowledges client expectations that personal information disclosed to Organizational Solutions Inc. will only be used for the purpose of providing the services of case management and for furthering evidence-based best practices and will not be released without informed consent. Each employee and representative at Organizational Solutions Inc. is responsible for personal information under their control.

A Privacy Officer has been assigned to implement and oversee compliance with the Privacy Program. In addition, Compliance Officers within selected areas of the business have been designated to assist the Privacy Officer and to work with the operational team to ensure all procedures related to the handling of Personal Information comply with the policy requirements. An Organizational Solutions Inc. internal audit of privacy practices will be conducted on a periodic basis.

Duty of Health Professionals
“Confidentiality refers to the trust placed that the information shared will be respected and used only for the purpose disclosed. Confidentiality is an inherent requirement of the daily activities of any health record professional (Styffe, 1997).”

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.

IDENTIFYING PURPOSES

The purpose for which any personal information is being collected will be identified before or at the time the information is collected. 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 also collect and disclose information for common purposes such as:

• To invoice clients for goods and services or to collect unpaid accounts.
• To advise clients that their service should be reviewed (e.g. to ensure service is still relevant to personal needs).
• To advise customers and others of special events or opportunities (e.g. seminars or conferences or new service options).
• For reviewing client and other files for the purpose of ensuring our high standards and services are being met. This may include external consultants such as lawyers, accountants, or private consultants on our behalf and continuing quality control reviews of our Company and its standards and services.
• We use aggregate data for research to advance the evidence-based nature of the profession.
• Occasionally, there may be the opportunity to win prizes through participation in periodic prize draws or other promotions on our website, at seminars, or elsewhere. To enter, we may ask that an individual provide their name, address, and phone number. Unless they opt out by contacting us, the information provided will be collected, used, and disclosed as provided in this Privacy Policy.

We also use a third-party provider to help us gather information about the areas that are visited on our website in order to evaluate and improve the customer experience and the convenience of the website. The third-party provider is contractually restricted with the information provided to us in any manner.

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. Representatives must also obtain consent, if applicable, for the collection of an individual’s personal information from another source, such as health care providers or insurance companies.

Individuals will be given a choice for any collection, use or disclosure of personal information that is not necessary to provide a product of service (e.g. marketing communications). They will also be informed that they may withdraw their consent at any time, subject to legal or contractual restrictions and reasonable notice, and with an understanding that a withdrawal may result in a product or service being discontinued. Requests to withdraw consent for the continued processing of personal information must be provided in writing to the Privacy Officer at privacyofficer@orgsoln.com.

Personal information must be limited to the purpose identified at the time of consent. Personal information may be used for research/analytics without consent only if the information has been anonymized/de-identified.

LIMITING COLLECTION

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 or, if the client was less than 18 years of age at the time of the last contact, for ten (10) years following the day the client would have turned 18. 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 are in place with respect to the destruction, erasure, or anonymizing of personal information once it is no longer required.

ACCURACY

Personal information will remain accurate, complete, and current as necessary for the identified purposes for which it is to be used. Representatives must take reasonable steps to confirm that personal information is accurate and up to date before making decisions using that information.

Requests to update or correct personal information that cannot be amended by an individual through the online portal must be submitted in writing to the Privacy Officer at privacyofficer@orgsoln.com.

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.

SAFEGUARDING INFORMATION

Organizational Solutions Inc. will protect personal information with safeguards appropriate to the sensitivity of the information provided. All employees and representatives of Organizational Solutions Inc. must undergo privacy and security training within the first thirty days of their employment, and annually thereafter.

These safeguards include reasonable technical, administrative, contractual, and physical safeguards to protect all personal information against loss, theft, unauthorized access, modification, or disclosure. Organizational Solutions Inc.’s employees and representatives have a duty to retain the confidential nature of patient records at all times.

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. Personal information is only transmitted via email when using password-encrypted PDF documents. Personal information must never be discussed (including over the phone) in any public place, or where anyone is present who does not have a need to know such information in connection with their duties and responsibilities to the Organization. Personal information must not be disclosed in a message left on a voicemail or answering machine without the individual’s specific prior consent. In addition, if a request is made by an individual by phone, the representative will authenticate the caller before discussing the individual’s personal information.

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. To ensure the protection of client files, it is forbidden to remove original files from Organizational Solutions Inc. offices.

Contractors
The people who are contracted to do work for us are required to have prior knowledge and consent to Organizational Solutions Inc.’s Privacy Policy. Our primary purpose for collecting personal information is to ensure we can contact them in the future (work assignments) for necessary work-related communications (sending paycheques), letters of reference, or an evaluation of their work.

Claim Audit Agreement
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.

Privacy Impact Assessments (PIA)
When acquiring, developing, or making significant changes to a system or process that involves the processing of Personal Information, management must apply the Organization’s Privacy Impact Assessment and toll to ensure adequate steps are taken to protect Personal Information.

OPENNESS

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. A publicly available version of the Privacy Policy is made available on the corporate website. Upon written request, we will respond to inquiries about our practices related to the management of personal information.

INDIVIDUAL ACCESS

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.

Organizational Solutions Inc. will give access to an individual who wishes to review or verify personal information. 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.

Requests for details regarding the personal information held and how it has been used and disclosed must be submitted in writing to the Privacy Officer at privacyofficer@orgsoln.com.

Individuals may request to have their personal information that we have in our possession to be deleted. Requests to delete an individuals personal information must be submitted in writing to the Privacy Officer at privacyofficer@orgsoln.com. Organizational Solutions Inc. will make its best efforts to fulfil such requests, subject to legal limitations and contractual agreements. Deleting information may result in a product or service being discontinued.

WEBSITE INFORMATION

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.

LINKS TO OTHER SITES

The privacy policy only covers Organizational Solutions Inc.’s website. When you visit our website, you may discover that it contains links that may take you to sites operated by third parties that are not within Organizational Solutions Inc.’s control and are not covered by this Privacy Policy. If you use a link, you are advised to check their applicable privacy practices and policies for each particular new site. We at Organizational Solutions Inc. do not accept any responsibility or liability for the practices of other websites.

ADDRESSING COMPLAINTS AND SUGGESTIONS

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 such as:

• questions, concerns or inquires regarding the Organization’s data handling policies or practices
• request to know the identity of the individual(s) designated by the Organization to oversee compliance with the privacy laws, and complaints regarding the Organization’s handling of Personal Information

All of the above can be directed to the Privacy Officer at 905-315-7179 or 1-866-674-7656 or by emailing privacyofficer@orgsoln.com.

If you have any other questions about this Privacy Policy, write to:
Liz R. Scott, Privacy Officer / CEO
ORGANIZATIONAL SOLUTIONS INC.
2186 Mountain Grove Ave., Suite #253
Burlington, ON L7P 4X4
privacyofficer@orgsoln.com