Effective Date: January 1, 2025
Shift Concussion Management ("we", "us", "our") is committed to protecting your privacy and safeguarding your personal health information. This Privacy Policy explains how we collect, use, disclose, and protect your information in compliance with the Personal Health Information Protection Act, 2004 (PHIPA) and other applicable Ontario and Canadian privacy laws.
1. Information We Collect
We may collect the following types of information when you use our services:
Personal Health Information (PHI)
- Medical history and health records
- Assessment results, treatment plans, and clinical notes
- Symptoms, diagnoses, and recovery progress
- Information from referring healthcare providers
Personal Information
- Name, address, phone number, and email address
- Date of birth and gender
- Emergency contact information
- Insurance and billing information
Website Usage Information
- IP address and browser type
- Pages visited and time spent on our website
- Cookies and similar tracking technologies
2. How We Use Your Information
We use your information for the following purposes:
- Healthcare Services: To provide concussion assessments, treatment, and ongoing care
- Appointment Management: To schedule, confirm, and remind you of appointments
- Communication: To respond to your inquiries and provide important health information
- Billing: To process payments and insurance claims
- Quality Improvement: To improve our services and patient experience
- Legal Compliance: To meet regulatory and legal obligations
3. How We Share Your Information
We may share your personal health information only in the following circumstances:
- With Your Consent: When you explicitly authorize us to share information with other healthcare providers, family members, or third parties
- Circle of Care: With other healthcare providers directly involved in your care (as permitted under PHIPA)
- Legal Requirements: When required by law, court order, or to protect public health and safety
- Service Providers: With trusted third-party service providers who assist in operating our clinic (e.g., appointment scheduling systems, secure messaging platforms), subject to strict confidentiality agreements
We do not sell your personal information to third parties for marketing purposes.
4. Your Rights Under PHIPA
Under Ontario's Personal Health Information Protection Act, you have the right to:
- Access: Request access to your personal health information held by us
- Correction: Request correction of inaccurate or incomplete information
- Withdraw Consent: Withdraw your consent for the collection, use, or disclosure of your information (subject to legal and contractual restrictions)
- Complaint: File a complaint with the Information and Privacy Commissioner of Ontario if you believe your privacy rights have been violated
To exercise any of these rights, please contact our Privacy Officer using the contact information below.
5. Data Security
We implement appropriate technical and organizational measures to protect your personal health information, including:
- Encrypted data storage and transmission
- Secure access controls and authentication
- Regular security assessments and updates
- Staff training on privacy and security practices
- Physical security measures at our clinic locations
While we strive to protect your information, no method of transmission over the Internet is 100% secure. We encourage you to contact us directly for sensitive health discussions.
6. Data Retention
We retain your personal health information for the period required by Ontario healthcare regulations, which is generally:
- Adult patients: 10 years from the date of last entry in the record
- Minor patients: 10 years from the date of last entry, or until the patient reaches age 18, whichever is longer
After the retention period, records are securely destroyed in accordance with privacy regulations.
7. Website Cookies and Analytics
Our website uses cookies and similar technologies to improve your experience. These may include:
- Essential Cookies: Required for website functionality
- Analytics Cookies: Help us understand how visitors use our website
- Preference Cookies: Remember your settings and preferences
You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.
8. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.
9. Changes to This Policy
We may update this Privacy Policy from time to time. Significant changes will be posted on our website with an updated effective date. We encourage you to review this policy periodically.
10. Contact Us
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact our Privacy Officer:
Shift Concussion Management
Attention: Privacy Officer
142 Wyndham St N, Guelph, ON N1H 4E8
Phone: (519) 822-2226
Email: info@shiftconcussion.ca
Information and Privacy Commissioner of Ontario
If you are not satisfied with our response to a privacy concern, you may contact:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
Phone: (416) 326-3333 or 1-800-387-9080
Website: www.ipc.on.ca