Introduction

This Privacy Charter has been adopted to guide how our clinic collects, uses, and safeguards Health Information.

Our Clinic respects the privacy rights of our patients and employees and is committed to protecting the personal information that we collect from you.

We have adopted this Privacy Statement to guide how we collect, use and disclose the information you provide to us.

Health Information

The InspiroMed Clinic respects the privacy, confidentiality, and access rights of our patients and is committed to protecting the health information that we collect.

The following principle(s) reflect our privacy practices and inform you of the principles and guidelines which Dr. Kumar Ramlall uses to protect the personal health information of individuals from whom we collect, use or disclose in the course of our health operations, as subject to the provisions of the Health Information ACT (HIA). This legislation applies to health information we collect, use and disclose to provide our patients with health care.

Certain of the practices that we have adopted reflect requirements set out in provincial privacy legislation. This legislation may apply to information we currently have on record and have always collected, used, and disclosed to provide our employees or patients with medical services. While you could give us your permission in an informal way, such as providing us with your insurance card to document your insurance provider, in some situations we must have your consent to collect, use, and disclose your personal information.

Principles

1. Principle 1- Accountability

we are accountable for the personal information that you give to us.

Our Clinic is accountable for all personal information in our possession or control. This includes any personal information that we must share with third parties to provide services to you. We have established policies and procedures aimed at maintaining the privacy of our patients and our employees. We have appointed a Privacy Officer to oversee privacy issues for our Clinic. We have also educated our employees about our Privacy Policy and their role in protecting your privacy. If you have questions about our privacy practices, you are free to contact our Privacy Officer.

2. Principle 2- Identifying Purposes

Our Clinic will tell you why we collect your personal information before the information is collected.

A notice has been posted explaining why we collect individually identifying health information and the legal authority that authorizes us to collect it. Individually identifying health information is collected only for the following purposes.

Treatment: We will use your personal information to provide you with health-related services. We may use your information to coordinate care with other healthcare providers. Communication with Individuals Involved in Your Care or Payment for Your Care: Health professionals such as physicians, nurses, and pharmacists, using their professional judgment, may disclose to your health care designated personal information that is directly relevant to their involvement in your care. Health-related educational communications: We may contact you to provide appointment reminders or information about treatment alternatives, or other health-related benefits and services that may be of interest to you.

3. Principle 3- Consent

of individuals will be obtained before or when their health information is collected, used or disclosed, except where authorized by law. When you receive health services of any kind from this clinic, we collect individually identifying personal information and health information from you and share this within the clinic and with other health service providers that need the information to provide you with health services.

The personal health information that you provide to us is collected, used and disclosed in accordance with the provisions of the Health Information Act (HIA), and is primarily used to provide diagnostic, treatment and care services to you, and to bill the Alberta Health Care Insurance Plan for services provided. The privacy provisions of the legislation require that we protect your health information from unauthorized access, use, disclosure, or destruction.

4. Principle 4-Limiting Collection

The amount and type of health information collected will be limited

We will collect personal information only for the purposes that we have identified or as otherwise permitted by law. In addition, we will only collect as much health information as is essential to carry out the purpose for which we are collecting it.

Your health information will be collected directly from you, except in the limited circumstances where we are authorized by the HIA to indirectly collect such information.

5. Principle 5- Limiting Use, Disclosure, and Retention

Health information will be used and disclosed only for the reasons for which it was provided unless otherwise permitted by law. It will be retained as per the retention guidelines of the appropriate regulatory body or as required by law and will be securely destroyed at the end of the retention period.

We will keep your personal information only if necessary, to accomplish these purposes.

In the event our Clinic changes ownership or is closed, you will be contacted with information about the change and, where applicable, where your information has been transferred. You will be free to continue to use that Clinic or to have your information transferred to the Clinic of your choice.

6. Principle 6- Accuracy

We take efforts to ensure the health information in our custody and control is accurate and complete before using or disclosing that health information will be kept as accurate, complete, and up-to-date as possible on an ongoing basis or notification by the individual. We update our registration and billing data as required. We ensure our clinic records are complete and accurate and track additions and amendments. We correct inaccurate or incomplete information when know.

Subject to limited and specific exceptions in the HIA, individuals have a right of request corrections or amendments to this information.

7. Principle 7- Safeguards

Your health information will be protected from unauthorized access, use, disclosure or destruction.

We have assessed the risks to your health information and implemented administrative technical and physical safeguards to eliminate or minimize the risk. Examples of these safeguards include office policies and procedures that ensure health information cannot be seen by unauthorized persons, having employees sign oaths of confidentiality, electronic security mechanisms like firewalls and password protection, and securing the

clinic when we are close.

8. Principle 8- Openness

We have established policies and procedures aimed at maintaining the privacy of our patients

We will make readily available to individuals’ specific information about our policies and procedures relating to the management of health information. We will be open about our policies and procedures with respect to the management of health information. Individuals will be able to acquire information about our policies and procedures at minimal or no cost and without unreasonable effort. This information will be made available in a form that is generally understandable.

9. Principle 9-Individual Access

Individuals have a right to access their health information that is in our clinic’s custody and control within the provisions of the HIA.

Individuals have a legal right to access their health information in a medical record subject to limited and specific expectations as stipulated by law [HIA s11 910 & (2)]. During the provision of health services, we will share your health information with you or your authorized representative verbally and allow access to provide copies of your health information records (including information in Alberta Netcare).

Our clinic has the right to collect payment for fees for access requests as allowed per HIA regulations.

10. Principle 10-Challenging Compliance

We monitor compliance with our privacy policies and procedures and have a process for handling complaints and handling of health information

We regularly assess our health information safeguards and ensure our physicians and staff know what they are and that they follow them, we have put in place sanctions for anyone who breaches or attempts to breach our safeguards to demonstrate the importance we place on preserving privacy and confidentiality. We investigate all privacy complaints or suspected privacy breaches, and take appropriate remedial measures including amending policies, disciplining staff etc.

We have a process for handling requests for correction or amendments to health information. In the event that a complaint cannot be resolved, the clinic Privacy Officer will advise the individual of the mechanism for referral of the complaint to the College of Physicians and Surgeons of Alberta, or the Office of the Information and Privacy Commissioner of Alberta.

Personal Employee Non-Health Related Information

Our clinic also respects the privacy rights of our employees and is committed to protecting the personal information that we collect from them.

As an employer, we will collect employees’ personal information specific to payroll requirements. We will use this information in a way that is reasonable to fulfill our obligations to abide by Personal Information Protection Act (PIPA) legislation in Alberta. The type of information may include an employee’s resume, letter of employment/contract, salary or wage history, performance-related documents (including performance reviews, commendations, and disciplinary action), and tax forms. We will maintain this information securely. Employees have the right to review their own employee records by the clinic Privacy Officer.

These privacy principles were developed based on the 10 privacy principles in the CSA Model Code for the Protection of personal information (also known as the ’10 fair information principles’). These principles form the basis of Canadian privacy and access legislation.