Privacy and Confidentiality
Lutherwood is committed to protecting the privacy of the personal information of its employees, clients, residents, donors, volunteers and other shareholders. We value the trust of those we work with and of the public, and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that you share with us.
Privacy of Your Personal Health Information
Lutherwood is responsible for protecting your privacy and we take this very seriously. Many safeguards are in place to protect your personal information and/or personal health information. All Lutherwood programs follow the privacy principles as outlined in the Personal Health Information Protection Act (PHIPA), as well as the Personal Information Protection and Electronic Documents Act (PIPEDA). If you have any questions about our privacy safeguards, please ask your worker or ask to speak with our Privacy Officer.
Purpose of Information Being Collected and Used
When you enter one of our programs, we start a file. We only collect information necessary to provide service and to support you. A file is kept to document and track your participation in a Lutherwood program(s) and may include:
- Goals and progress on goals;
- Recommendations that are made;
- Case notes regarding meetings or sessions we have;
- Information we collect on your behalf, including any previous involvement with other organizations, assessments, counselling reports, medical and/or school information.
On an ongoing basis, we are required to report non-identifying information collected from you to our funders (including the Ministry of Health and Ministry of Children, Community, and Social Services). Examples of what would be reported include number of families served, number of clients reporting a positive experience, and number of clients on a waiting list.
Direct and Indirect Collection of Information
Information will be collected from you directly as part of your participation in service. There may be circumstances where information is collected indirectly when it reduces risk or when it is not possible to collect it directly from you in an accurate, complete and/or timely manner.
Exceptions to Confidentiality
The law indicates that confidentiality is limited when a person discloses any of the following:
- Abuse to themselves or to another person (physical, sexual, emotional);
- Intention to hurt themselves (suicidal);
- Intention to hurt another person (homicidal); or
- Where a Lutherwood staff member has reason to suspect that a young person has been or is currently being abused or at risk of abuse.
Under these conditions our staff members have a professional and legal “duty to report” the information they have received to the appropriate authorities including
- To Family and Children’s Services if the young person is under the age of 18) and there is reasonable suspicion they may be in need of protection ;
- To a police officer if the need is urgent;
- To a medical practitioner if the need is urgent;
- To authorized staff of the Ministry;
- To courts with proper warrants.
Access to Your Records
It is your right, and it’s important to us, that you have the opportunity to understand why we collect the information in your file and for you to be able to ask any questions that may arise during or after your time receiving service. At any time, you may request to see your file and/or request a copy of information from your file and/or make corrections to information in your file. The process for this is to set up an appointment with the Program Manager. A time will be arranged for the two of you to meet and review your record.
Storage of Records
Your file may be in paper and/or electronic format. Paper files are kept in a locked file cabinet within a locked room. Electronic files are part of a web-based client information system that has many security features in place. Your file cannot be accessed without an assigned and secure password.
Your files are kept for as long as required by standards and legislation. You may ask your worker how long records are kept specific to your program area.
Your Informed Consent
‘Informed consent’ for both participation in a service and for the release of information, means that it has been explained to you both in language and format that is understandable to you, the reasons or purpose of the program/services and the purpose for the consent to the release of information. It is important that you have had a chance to ask questions and possibly get another opinion before signing the consent, if you wish.
We would like you to be aware that as a participant in a Lutherwood program or service, your personal health information may be shared with other relevant Lutherwood staff members and joint service delivery partner staff who are working with you and your care team.
For staff to either collect information or talk to non-Lutherwood people (a counsellor, family doctor, school, OW caseworker, landlord etc.) about you, we ask for your permission or ‘consent’ in writing. A signed consent is your written permission for us to ask for and/or share information with specific agencies or organizations or in some cases particular, individuals.
Consent can be withdrawn at any time by informing us in writing. Once consent is withdrawn, we can no longer seek or share information on your behalf. Withdrawal of consent cannot reverse any action that was already taken with your previous consent.
Electronic Communication Consent as per Service Agreement (Section I)
Lutherwood recognizes that the use of technology can be a timely and friendly way to communicate however before we agree to communicate via email or text, it is important that everyone understands and accepts the risks and guidelines involved.
- The privacy and security of electronic communication through email and smart phones cannot be guaranteed. To ensure that all confidential information is secure, you are advised to use password protection on all electronic devices.
- Electronic communication is not always the best way to communicate. At times a face-to-face meeting with staff may be suggested.
- You are encouraged to always double check where you have addressed an email or text before sending, as it can be misaddressed and sent to unintended or unknown persons.
- Staff’s email address or contact information is not to be included in any mailing lists. If this occurs, it may result in not being allowed to continue electronic communication with Lutherwood staff.
- Deleted emails may not be permanently deleted; back-up copies may exist on a computer or in cyberspace.
- Emails can introduce viruses into a computer system and potentially damage the files. Emails can be viewed by Lutherwood IT staff for security purposes.
- Emails and text messages will be summarized and entered into your file as part of your record. Client records can be used as evidence in court. All copies of emails will be deleted by Lutherwood.
- No phone or online video software is entirely secure. Lutherwood computer systems have strong internal security, which helps protect my privacy and confidentiality. Lutherwood will not be responsible for breaches of your confidential information if they are not the direct result of intentional misconduct.
- There is no guarantee that staff will respond to email or text messages immediately. If you need immediate assistance please do not call your worker, call 911 or seek assistance in other ways appropriate.
- You are asked to inform your worker of any changes to your email/text address.
Phone & Video Services as per Service Agreement (Section J)
The use of technology can sometimes be a helpful way to provide service to you and your family, when meeting in person is not possible or suitable. However, before we agree to offer services (such as support or therapy) through phone or video options, it is important that you and your family understand and accept the risks and guidelines involved.
- To ensure your privacy, you should choose a private and quiet place where our conversation cannot be overheard and free from distraction. When meeting by phone or video, there is a risk of others finding out about you working with Lutherwood if you did not want them to know.
- You are asked not to record this session without the direct permission of everyone involved.
- All individuals present for the phone or video session must be within view of the camera or acknowledge their presence so that everyone is fully aware of who is participating.
- It is necessary to let staff know of your location and provide an emergency contact, and that in the event of an emergency, emergency services may be called to your location.
- There could be interruptions in meetings due to technology or connection failures, and we will create a plan in advance for what to do if this happens.
- Everything outlined in the service agreement that applies to in-person meetings also applies to phone and video meetings. Phone and video meetings will be summarized and entered into your file as part of your record, in the same way as in-person meetings.
- Phone and video meetings are not always the best way to communicate and staff may decide that they are no longer appropriate. Face-to-face meetings with staff or other alternatives may be suggested if phone or video meetings are no longer suitable.
- You are requested to use a private internet connection rather than public/free wifi, as this increases confidentiality and security.
- You are responsible for paying for your own internet costs.
- You are to use passwords on all your devices as this controls who has access and improves confidentiality and security.
- No phone or online video software is entirely secure. Lutherwood computer systems have strong internal security, which helps protect your privacy and confidentiality. Lutherwood will not be responsible for breaches of your confidential information if they are not the direct result of intentional misconduct of Lutherwood.
The contact information we receive from you as a donor and the amount of your donation is the minimum required by Canada Revenue Agency for the issuance of an official tax receipt. We will not provide or share your personal information with third parties unless:
- You authorize us to share the information.
- Sharing the information is necessary to process a donation.
- We are required to by law.
Who can I contact for more information about this privacy statement?
If you would like to know more about Lutherwood’s privacy policies or if you have any questions, concerns or complaints relating to Lutherwood’s handling of personal health information, we invite you to contact our Privacy Officer, Sherrie Hyde, by email or at 519-884-1470.
You have the right to complain to the Information and Privacy Commissioner of Ontario if you think your rights have been violated at https://www.ipc.on.ca/
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