Our Privacy Policy

We will protect the privacy of all the information you give us.

The information you or your child gives us about your child and your family is important to our work at Boomerang Health. It is important for the assessment and treatment of your child, so that we can provide them with the best care possible. We promise to make sure that all of your child’s personal health information is kept private. This page explains why we collect information about you, your child and your family, and how we use it. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We strive to be open and transparent regarding how we handle personal information.

What is personal health information (PHI)?

Personal health information refers to data about an identifiable individual. Personal health information includes information that relates to: an individual’s personal characteristics (e.g., name, age, gender, address), health (e.g., developmental and medical history, assessment and treatment history); or activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). This information may include records of your child’s visits to Boomerang Health and the care that they received during those visits. We collect personal health information about a patient from the patient, their caregivers, and/or from the person responsible for making decisions on the patient’s behalf.

How we collect, use and disclose personal health information? 

We collect, use, and disclose personal health information to care for your child and their family. We also collect information for our records, as required by law. Boomerang Health’s obligations regarding personal health information are outlined in Ontario’s health information privacy legislation, the Personal Health Information Protection Act, 2004 (PHIPA). In the course of carrying out patient care and administrative functions, Boomerang Health collects, retains, uses, discloses, and ultimately disposes of confidential personal information and personal health information relating to its patients and its staff, within its custody and control.

Primary Purposes:

A. Collecting, using and disclosing information about clients

We collect, use, and disclose personal information to serve our patients. For our patients, the primary purpose for collecting personal information is to provide assessment and treatment services. For example, we collect information about a patient’s developmental history, including their family history, medical history, and current functioning, to help us assess what their language, motor, social, emotional, behavioural or physical needs are, to advise them of their options and then to provide the care they choose to have. A second primary purpose is to obtain a baseline of developmental and health information so that, in providing ongoing services, we can identify changes that occur over time. It would be rare for us to collect such information without express consent from the patient or from the legally responsible caregiver, but this might occur in an emergency (e.g., the patient is unconscious) or where we believe the patient would consent if asked, and in a situation if it is impractical to obtain consent (e.g., a family member passing a message on from our patient and we have no reason to believe that the message is not genuine).

Each time a patient visits Boomerang Health, we collect information about the patient. For example, we collect the results of any assessments and document the progress of treatment. Within Boomerang, we share the patient’s information with only those individuals who need it for their work and are part of the patient’s circle of care. We work as a multidisciplinary team and may consult with allied health practitioners on the team if we believe such consultation would be beneficial for your child’s care. We also give your information only to those who have a right to it by law. Sometimes we collect, use and disclose personal health information about a patient from other sources (for example, schools, a referring doctor) if we have the patient’s and/or legal caregiver’s consent or if the law permits.

These are the people who may see your/your child’s information:

• The patient;
• The caregiver(s) of a patient/the individuals legally responsible for making decisions for a patient;
• Professionals/practitioners with whom your child works;
• Professionals/practitioners outside of Boomerang Health, with your consent;
• Students, interns, and others are training at Boomerang Health;
• Other people, if the child and/or caregivers agree, or when the law requires or permits it. See limits of confidentiality for further information about when the law requires the sharing of personal health information without express consent.

Limits of Privacy: Confidentiality

There are five situations when health care practitioners are obligated, either legally or ethically, to share information:

• When there is a concern that a child is being harmed or is at risk of being harmed, this may include actual or suspected physical, emotional, or sexual abuse, neglect, or a pattern of failure to follow through on necessary treatment. The healthcare practitioner is required to contact the Children’s Aid Society (CAS) or an equivalent agency.
• When Boomerang Health staff and/or documentation are “subject to subpoena” by the court (that is, when they are requested by a judge for a legal proceeding in family or criminal court).
• If someone presents an imminent danger to themselves or to others (e.g., if a child or caregiver is considered suicidal or homicidal).
• If it is reported that a member of another regulated health profession has been sexually inappropriate. In this case, a report will be made to the professional’s college. The patient’s name will not be reported without expressed consent.

B. Collecting, using and disclosing information about members of the general public

For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might 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 do not disclose information about members of the general public to third parties. On our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a course, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.

C. Collecting, using and disclosing information about contract staff, volunteers and students

For people who are contracted to do work for us (e.g., temporary workers), 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 (e.g., sending out paycheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency, or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect, use and disclose information about their work related performance and provide a report as authorized by them.

Related and Secondary Purposes:

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

• To invoice patients and families for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
• To advise patients and families that their product or service should be reviewed (e.g., to ensure a product is still functioning correctly and appropriate for their current needs and to consider modifications or replacement).
• To inform patients, families, and others about special events or opportunities (e.g., seminars, development of new services, arrival of new products) that we have available.
• Our clinic reviews patient and other files to ensure that we provide high-quality services, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may, on our behalf, do audits and continuing quality improvement reviews of our Clinic, including reviewing patient files and interviewing our staff.
• Dietitians, massage therapists, nurses, occupational therapists, physicians, physiotherapists, psychologists, social workers, and speech-language pathologists are licensed and regulated professionals in Ontario through their respective professional colleges. These licensing bodies may inspect our records and interview respective staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our patients or other individuals to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
• The cost of some goods/services provided by the organization to patients is paid for by third parties (e.g., OHIP, private insurance, charities). These third-party payers often have your consent or legislative authority to direct us to collect and disclose certain information to them, to demonstrate patient entitlement to this funding.
• Patients, families, 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 patients over a period of months or years, for which our previous records are helpful. We retain our patient information for a minimum of ten years after the child turns 18 or 10 years after the last contact (for those 18 and older) to enable us to respond to those questions and provide these services (our regulatory Colleges also require us to retain our patient records).

You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

How we protect your information?

We protect your information in these ways:

• We ask your permission before we collect, use, or show your/your child’s or your family’s information to anyone for any purpose other than our main activities, such as providing care.
• Patient personal health information is entered into an electronic medical record (EMR). Boomerang Health has taken reasonable steps to ensure that these records are secure and protected from theft, loss, and unauthorized use, disclosure, copying, modification, or disposal.
• We ensure that your information remains private. Only the people who need to see your child’s personal records are allowed to look at them. Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• We take steps to make sure no one steals or loses your information. We also work to ensure that no one copies, changes, uses, shares, or discards your information unless it is permitted.
• Paper information is either under supervision or secured in a locked or restricted area.
• Electronic information is hosted on a secure server and is protected from unauthorized access, loss, theft or disclosure. See “EMR Safeguards” below.
• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. Additionally, passwords are used on computers and telephone voicemail systems.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either directly or with identifiers removed or encrypted.
• We take steps to ensure that everyone who performs services for us protects your privacy and uses your personal health information only for the purposes you have agreed to. External consultants and agencies with access to personal information must enter into privacy agreements with us.
• We keep your information correct and up-to-date. You can see the information we collect about you or your family. See “Seeing and correcting your personal health information” below.
• We keep your information only for as long as it is needed or required by law. See “Retention and Destruction of Personal Health Information” below.
• We will investigate any concerns you may have regarding the privacy of your information. We have a designated person responsible for ensuring the confidentiality of our information. That person can give you more information about how Boomerang Health protects a patient’s privacy.

EMR Safeguards

• Only authorized staff use the EMR. No unauthorized person can access identifiable health information.
• Each authorized user is assigned a unique identity in the EMR.
• The EMR is protected by password controls or data encryption.
• Any electronic signature can be authenticated.
• Identifiable health information is always transmitted securely.
• Data is regularly backed up, and the backed-up data is stored securely.
• Data is recoverable if the system goes down, and data recovery protocols are regularly tested and maintained.
• Patient records within the EMR are accessible and readable for at least 10 years after the last time the patient has been seen (or 10 years after a minor patient turns 18), even if the technology changes.
• A process is in place to ensure the continuity of practice if the EMR is inaccessible.
• Before any hardware containing EMR data is disposed of, all identifiable health information is scrambled or removed and can never be reconstructed.

Retention and Destruction of Information

We need to retain personal information for a specific period to ensure that we can address any questions you may have about the services provided and to maintain our accountability to external regulatory bodies. However, we do not want to retain personal information for too long to protect your privacy.

We retain our patient files (for individuals 18 and over) for a period of ten years. For younger patients, we retain our files for 10 years after the patient’s 18th birthday. We retain any personal information related to our general correspondence (i.e., with individuals who are not patients), newsletters, seminars, and marketing activities for a reasonable period after the newsletter ceases publication or a seminar or marketing activity concludes.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.

Seeing and Correcting Your Personal Health Information

With only a few exceptions, a patient and/or their legally responsible caregiver has the right to view the personal information we hold about them. Often, all you have to do is ask. We will also strive to help you understand any information you do not comprehend (e.g., acronyms, technical language, etc.). We will need to confirm your identity if we do not know you before providing you with this access. We reserve the right to charge a nominal fee for such requests. If there is a problem, we may ask that you submit your request in writing. If we cannot provide you with access, we will inform you, to the best of our ability, within 30 days, of the reason why we cannot do so.

If a patient believes that there is an error in the information, the patient or the legally responsible caregiver has the right to request that it be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation to verify that our files are accurate. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point, and we will forward that statement to anyone else who received the earlier information. If you want to correct any of your own information, you can contact our Privacy Officer (see contact information below).

How to contact us?

If you require additional information or have privacy concerns, please contact Boomerang Health’s Privacy Officer at 905-553-3155 ext. 244 or by e-mail at info@boomeranghealth.com. You may also send a fax to 905-553-8120 or write to:

Privacy Officer, Boomerang Health
9401 Jane Street, Suite 211
Vaughan, Ontario L6A 4H7

If you do not want us to use your information for specific purposes, such as contacting you about your satisfaction with our services, please let us know. Kindly provide us with your full name/child’s full name, date of birth, and a home phone number so we can contact you if we need to verify the information.

You also have the right to complain to the Information and Privacy Commissioner of Ontario if you believe we have violated your rights. The Commissioner can be reached by phone at 416-326-3948, by fax at 416-325-9195, by e-mail at commissioner@ipc.on.ca, through www.ipc.on.ca or by mail at:

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario, M4W 1A8