Notice of Privacy Practices

Privacy of personal information is an important principle to Nutrition Noodles.

We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We try to be open and transparent about how we handle personal information.

This notice describes how medical information about you may be used, stored, and disclosed by Nutrition Noodles and how you can get access to this information. Please review it carefully.

Personal Health Information

Under the Personal Health Information Protection Act (PHIPA), personal health information is defined as information that can identify an individual (or can be combined with other information to identify an individual) and that relates to:

• the physical, nutritional or mental health of the individual (including family health history);

• the provision of health care to the individual; including identifying the individual’s health care provider(s)

• payments or eligibility for health care or coverage for health care

Why we Collect Personal Health Information

We collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal health information is to provide nutritional counselling services.

We collect information about clients’ health history, including their family history, physical condition and function and social situation in order:

• to help us assess what their nutrition care needs are, to advise them of their options and then to provide the nutrition care they choose to have.

• to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that are occurring over time.

• To provide you with care and assistance based on your needs

• To make sure your service providers have the most up-to-date and complete record of your health history and needs

• To help us see where there might be gaps or overlaps so we can ensure you are getting the proper support and services

• For general administration and management of our programs and services

• To comply with our regulatory obligations to The College of Dietitians of Ontario.

• To obtain payment for services provided

• To advise clients about special events or opportunities (e.g., email newsletters), send reminders for appointment bookings, or share resources that may support the nutrition treatment plan.

Your Rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Get an electronic or paper copy of your medical record: You can ask to see or get an electronic or paper copy of your client record and other health information we have about you. Ask us how to do this. We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee ($30.00 for the first 20 pages and 25 cents for every additional page)

Ask us to correct your medical record: You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.W e may say “no” to your request, but we’ll tell you why in writing within 60 days.

Request confidential communications: You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address. We will say “yes” to all reasonable requests.

Get a list of those with whom we’ve shared information: You can ask for a list of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make).

Get a copy of this privacy notice: You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you: If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will make sure the person has this authority and can act for you before we take any action.

File a complaint if you feel your rights are violated: You can complain if you feel we have violated your rights by contacting us directly by speaking to the dietitian or emailing us at nutritionnoodles@gmail.com Or file a report directly with the College of Dietitians of Ontario

Your Choices

Information that is collected by Nutrition Noodles is only shared under the following conditions with your consent. You have a choice in how the information is shared.

You have both the right and choice to tell us to:

• Share information with your family, close friends, or others involved in your care

• Share information to another health care professional within your circle of care

Our Uses and Disclosures

Nutrition Noodles assumes that they have an individual’s implied consent to collect, use or disclose personal health information for the provision of health care if the following conditions are met:

• the information was received from the individual, the individual’s substitute decision-maker or another health information custodian

• the information was received for the purpose of providing health care to the individual

• the information is collected, used, or disclosed for the purpose of providing health care to the individual

• if information is being disclosed, it must only be disclosed to another health information custodian; and

• the individual has not withheld or withdrawn consent

Primary purpose: We collect, use and disclose information about your health history, your physical condition and function and your social situation in order to help us assess what your needs are, to advise you of your options and then to provide the health care you choose to have

Secondary purposes for the use and disclosure of personal health information include:

1. Treat you: We can use your health information and share it with other professionals who are treating you..

2. To obtain payment for services or goods provided: We can use and share your health information to bill and get payment from health plans or other entities.

3. To conduct quality improvement and risk management activities

4. To review client files to ensure that we provide high quality services, including assessing the performance of our staff. External consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may conduct audits and quality improvement reviews on our behalf.

5. To comply with Regulatory College : Dietitians are regulated by the College of Dietitians of Ontario who may inspect our records and interview our staff as a part of its regulatory activities in the public interest. The College has its own strict confidentiality and privacy obligations. In addition, as professionals, we will report serious misconduct, incompetence, or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting illegal behaviour to the authorities. As well, we may be required by law to disclose personal health information to various government agencies (e.g. Ministry of Health, children’s aid societies, Canada Customs and Revenue Agency, Information and Privacy Commissioner, etc.).

6. To educate our staff and students: We value the education and development of future and current professionals. We will review client records in order to educate/train our staff and students about the provision of health care.

Storage of Personal Health Information

Records will be kept electronically on the Practice Better platform. Practice better is fully compliant with HIPAA, PIPEDA, PHIPA, and GDPR regulations. Their policies and security practices can be found here in further detail: https://help.practicebetter.io/hc/en-us/articles/234814027-Privacy-and-Security-on-Practice-Better

Other physical and electronic safeguards implemented to increase security include:

• Password protected laptop with two-factor authentication to limit unauthorized access

• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, strong passwords are used on all computers and mobile devices.

• Accurate documentation includes: Document, sign, and date complete, accurate, timely records related to professional services.

• Audit logs containing access to records, the type of information viewed, the identity of the person viewing the health information, the identity of the client will be maintained.

• Maintain equipment service records (e.g., preventative maintenance logs) according to applicable legislative, organizational/employer, and manufacturer recommendations.

We do not post any personal information about our clients on social media sites and our staff members are trained on the appropriate use of social media.

We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies.

• We keep our client files for at least ten years from the date of the last client interaction or from the date the client turns 18.

• We destroy paper files containing personal health information by cross-cut shredding. We destroy electronic information by deleting it in a manner that it cannot be restored. When hardware is discarded, we ensure that the hardware is physically destroyed or the data is erased or overwritten in a manner that the information cannot be recovered.

• Circumstances may require us to retain clinical records for a longer period, such as where litigation is contemplated or ongoing or where a request for access to the record is outstanding

• In the case that the Dietitian becomes incapacitated, the person responsible for the estate of the practitioner is responsible for complying with PHIPA until he or she is able to transfer the information to another custodian

Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information.

• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.

• We will identify the scope of the potential breach and take steps to contain it.

• We will Inform all individuals of the steps that have or will be taken to address the privacy breach and that the Information and Privacy Commissioner’s Office, Ontario has been informed.

• We must follow the duties and privacy practices described in this notice and give you a copy of it.

• In cases where Nutrition Noodles collects, uses or discloses your personal health information without your consent, it will do so only where it is required or permitted to do so by law.

  Changes to the Terms of this Notice

  We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our web site.