Privacy Policy

Effective: April 2025
Clinic Address: 73 Water Street N., Suite 504, Cambridge, Ontario, Canada

Introduction and Scope

Regain Retain Physiotherapy is the business name of a corporation legally named Michelle Lumasag Physiotherapist Professional Corporation, which is hereinafter known as RRP. This policy applies to all RRP staff. Michelle Lumasag is the sole staff member practicing and the Primary Information Officer.

Purpose: Our Commitment to Your Privacy

At RRP, we respect and protect your privacy. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is fundamental to RRP operations. We are committed to maintaining the confidentiality and security of your personal health information (PHI) in accordance with Ontario’s Personal Health Information Protection Act (PHIPA) and, where applicable, the Personal Information Protection and Electronic Documents Act (PIPEDA).

Policy Statement

We collect personal and health information to provide you with high-quality physiotherapy services. This may include:

  • Your name, address, phone number, and email

  • Date of birth and emergency contact information

  • Medical history, treatment records, and clinical notes

  • Referrals and diagnostic reports from your physician or other providers

  • Private insurance details

  • Billing and payment records

Consent may also be required for diagnostic tests from entities other than RRP. RRP is the sole owner of your information. It is not shared or sold to other organizations. This information is collected directly from you or, with your consent, from other healthcare providers.

Definitions

Personal Information – Identifying information about an individual, including personal characteristics such as name, age, contact info, credit card details, and health services received.

Consent – Given when an individual signs the intake form electronically after reviewing this policy on the RRP website. This authorizes RRP to collect, use, and disclose the individual’s information for the purposes stated.

Implied Consent – Granted when an individual signs a form allowing RRP to obtain or verify information from third parties, such as insurance companies.

RESPONSIBILITIES

A. Owner – Michelle Lumasag

  • Immediately advise clients of any breach

  • Annually review and sign the policy

  • Follow responsibilities, procedures, and guidelines

B. RRP Information Privacy Officer (IPO) – Michelle Lumasag

  • Oversee collection, use, and disclosure of personal information

  • Implement privacy procedures

  • Respond to public and patient inquiries

  • Operate complaints procedure

  • Train staff on the Privacy Policy

  • Monitor compliance

  • Publish information-handling policies

  • Respond to access and correction requests

  • Handle privacy complaints

C. Health Information Custodian (HIC) – Michelle Lumasag

  • Notify affected persons of any breaches

  • Contain and document breaches

  • Report to the College of Physiotherapists of Ontario as required

  • Ensure staff follow privacy procedures

  • Provide access/correction to records

  • File written breach reports

PROCEDURES

COLLECTION OF PERSONAL INFORMATION

We collect personal information directly from you or a representative with your consent. This may be by:

  • Telephone (verbal or text)

  • Electronic forms

  • Virtual or in-person interviews

  • Faxes or letters from your healthcare team

  • Direct messaging via email or social media (with consent)

Purpose of Use and Disclosure

Your information may be used or disclosed to:

  • Provide assessment, treatment, and follow-up care

  • Document clinical progress

  • Communicate with your healthcare team

  • Submit insurance claims

  • Schedule appointments and send reminders

  • Conduct internal audits or quality improvements

  • Fulfill legal or professional obligations

Access and Correction

You may request to access or correct your records or withdraw consent. Requests must be in writing and include valid ID. We may charge:

  • $30 for the first 20 pages

  • $0.25 for each additional page

We’ll respond within 30 days. If we can’t fulfill the request, we’ll explain why. You may challenge our decision.

If there’s an error in the record, you may ask for it to be corrected. If we disagree, we’ll note your request in the record.

Retention and Destruction

We retain records for 10 years, as required by the Regulated Health Professions Act. Paper files are shredded the same day and digitized using Jane Software. Electronic files are securely deleted. On request, we may return the file to you.

When Consent is Not Required

RRP may disclose your personal information without consent under specific circumstances, including:

  • When required by law (e.g., court order, police investigation)

  • Emergency situations threatening health or safety

  • In-house statistical or research purposes

  • When the information is publicly available

  • To investigate a breach of contract

Safeguarding Your Information

Physical Safeguards:

  • Locked cabinets

  • Supervised access to paper files

  • Secure transfers and prompt shredding

Administrative Safeguards:

  • Staff confidentiality agreements

  • Privacy training for authorized personnel only

Technical Safeguards:

  • Secure, password-protected computer systems

  • Double-lock storage for hardware

  • Data encryption

We use Jane Software, which is PHIPA-compliant and encrypts all data transmission. RRP’s website links to the Jane booking site. No personal info is collected directly through the RRP website.

External consultants with access to information sign privacy agreements.

Privacy Breach

If a breach occurs:

  1. Contain the breach and recover data

  2. Notify affected individuals and provide contact information

  3. Investigate and prevent future incidents

  4. Report to the Information and Privacy Commissioner if necessary

Questions, Concerns, or Complaints

Contact Information Officer:
Michelle Lumasag, Registered Physiotherapist
Phone: 519-212-6400
Email: michelle@regainretainphysio.com
Address: 73 Water St. N., Suite 504, Cambridge, ON N1R 7L6

You may also contact the Information and Privacy Commissioner of Ontario:

  • Website: www.ipc.on.ca

  • Email: info@ipc.on.ca

  • Phone (Ontario): 1-800-387-0073

  • TTY: 416-325-7539

  • Address: 2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8

Annual Review:
This document will be reviewed in April 2026.