Your privacy is extremely important to Direct Dietitian Services. Your personal information will only be collected to the extent necessary for the services provided.
What is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (ex., sex, gender identification, age, home address or phone number, family status), the health (ex., health history & health conditions, medications & supplements, health services received) or their activities and views (ex., beliefs expressed by an individual, an opinion or evaluation of an individual).
Activities of Direct Dietitian Services
Rebecca Picot, Registered Dietitian (RD) works with a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, bookkeepers and accountants, website and email hosts, credit card companies, and lawyers. Access to personal information is restricted as much as is reasonably possible. These companies have also given their assurance that they follow appropriate privacy principles.
We Collect Personal Information:
Primary Purposes
Like all Registered Dietitians, personal information is collected, used and disclosed in order to serve you, the client. The primary purpose for collecting personal information about you is to provide you with dietetic services. We collect information about your health and diet 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. A second primary purpose is 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. It would be rare for us to collect such information without the client’s express consent, but this might occur in an emergency (e.g., the client is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our client and we have no reason to believe that the message is not genuine).
Related and Secondary Purposes
Like most organizations, we also collect, use and disclose information for purposes related to our primary and secondary purposes. The most common examples of our related and secondary purposes are as follows:
- To invoice clients for services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
- Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff.
- Registered Dietitians are regulated by the Saskatchewan Dietitians Association (SDA), who may inspect our records and interview us as part of their regulatory activities in the public interest. SDA has privacy obligations as well. 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 us 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.
- As directed by law, we retain client information for a minimum of ten years after the last contact
- If Direct Dietitian Services or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchase would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written consent to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information is secured in a locked cabinet, accessed only by Rebecca Picot, RD.
- Electronic hardware is secured in a locked or restricted area at all times. In addition, passwords are used on computers.
- Paper information is transmitted through sealed, addressed envelopes.
- Electronic information is transmitted a password protected or encrypted email.
Retention and Destruction of Personal Information
I 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. However, we do not want to keep personal information too long in order to protect your privacy. We keep client files for approximately ten years. We destroy paper files containing personal information by confidential shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Direct Dietitian Services will keep secure records of each record destroyed, including a summary of what was destroyed, the time-frame of the health information, how the information was destroyed and by whom.
You can look at your information
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, 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 you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. 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.
Questions or Concerns?
Rebecca Picot can be reached at rebecca@directdietitian.ca.
If you have a concern about the professionalism or competence of Rebecca Picot’s dietitian services, you are entitled to complain to her regulatory body, Saskatchewan Dietitians Association. For more information, please visit their website https://www.saskdietitians.org/ or call 306-359-3040 or email registrar@saskdietitians.org
If you have any concerns regarding your privacy or confidentiality, you may also wish to contact the Office of the Privacy Commissioner at: webmaster@oipc.sk.ca or call 306-787-8350.