Privacy of personal information is an important principle to The Nutrition Room. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We try to be open and transparent as to how we handle personal information. This document describes our privacy policies when you use our website.
WHAT IS PERSONAL INFORMATION
Personal information is recorded information about an identifiable individual. The personally identifiable information collected on this website may consist of name, telephone numbers and/or email addresses. We use this data to fulfil you requests for information. By using this website, you agree to the collection of information and use of information as is described in this policy. Personal information is also collected during your sessions with Registered Dietitian's at The Nutrition Room. This information may include personal characteristics (e.g., gender, age, race/ethnic origin, marital or family status), health status (e.g., health history and/or health conditions, surgical history and treatment history, medications) and/or social history (e.g. socioeconomic status, religion, physical activity, home address or phone number)
WHO WE ARE
Our organization, The Nutrition Room, includes Jennifer Bennett, Registered Dietitian and Certified Diabetes Educator and Katie Keller, Registered Dietitian. We may interact 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. We restrict their access to any personal information as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
WE COLLECT PERSONAL INFORMATION:
About Clients (PRIMARY PURPOSES)
Like all Registered Dietitians, we collect, use and disclose personal information in order to serve our clients. The primary purpose for collecting personal information about clients is to provide dietetic services that are individualized and specific to a client’s needs. 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 clients written or verbal consent, but this might occur in an emergency or where we believe the client would consent if asked, but is unable to speak for him or herself (e.g., the client is unconscious). Personal and private medical information that is collected during sessions is stored in accordance to the personal information protection and electronic documents acts (PIPEDA).
WE COLLECT PERSONAL INFORMATION:
Like most organizations, we also collect, use and disclose information for purposes related to our primary purposes. The most common examples of our secondary purposes are as follows:
To invoice clients for services that were not paid for at the time of service or to collect unpaid accounts.
To review client files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff.
To abide by The College of Dietitians of Alberta who may collect and review our records and/or interview staff as part of their regulatory activities. Additionally, 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 our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and communicate with The Nutrition Room as needed.
To ensure that the cost of some services provided by the organization is paid for by third parties (e.g., private health insurance). These third-party payers often have the clients consent or legislative authority to direct us to collect and disclose to them, certain information in order to demonstrate client entitlement to this funding.
To retain accurate client information for a minimum of 10 years (as required by The College of Dietitians of Alberta), after the last contact to enable us to respond to questions from clients about the services that were rendered or for legal purposes.
To ensure viability of the business if The Nutrition Room or its assets were to be sold. The purchaser would want to conduct a “due diligence” review of the records to ensure that the business has been honestly portrayed. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written contract ensuring all personal information remains 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.
We may use "usage data" to collect information on how the website is being used. This may include information such as the users IP address, browser type, pages of that website that were visited, time and date of visit and time spent on the website.
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Paper information is either under supervision or secured in a locked or restricted area.
Electronic hardware is either under supervision or 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 personal information is transmitted through a password protected document via email.
External consultants and agencies with access to personal information must enter into privacy agreements with us.
The Nutrition Room has implemented generally accepted standard of technology and operation security in order to protect your personal information from loss, misuse, alteration or destruction. Only authorized Registered Dietitians of The Nutrition Room are provided access to personal data and are required to treat this information as confidential.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
Personal information is retained for 10 years to ensure that we can answer any questions clients might have about the services provided and for accountability to external regulatory bodies. After this retention period, we destroy paper files containing personal information by shredding. Electronic information is destroyed by manually deleting files and when the hardware is discarded, we ensure that the hardware is physically destroyed.
CLIENT ACCESS TO INFORMATION
Clients have the right to see what personal information is collected and retained about them. The identity of the client must be confirmed with photo identification before The Nutrition Room provides access to information. We reserve the right to charge a nominal fee for such requests if any printing or mailing is required. In some situations, your request may have to be in writing. If we cannot give you access to your personal information, we will provide a written explanation as to why the request could not be met. We will provide this information within 30 business days.
If the client believes there has been a mistake in the information collected, the client has the right to ask for it to be corrected. This applies to factual information and not to any professional opinions that may have been documented. We may ask the client to provide documentation to support that our files are incorrect. Where agreed upon regarding the incorrect information, we will make the correction and notify anyone to whom we sent this information to. If not agreed upon, we will agree to include in our file a brief statement from the client on which information they deem as incorrect. This information will also be sent to anyone who received the earlier information however our records will not be altered.
DO YOU HAVE A QUESTION?
Jennifer Bennett RD, CDE can be reached at: Katie Keller RD can be reached at:
PHONE (587) 439-2865 PHONE (403) 975-5227
Jen/Katie will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about any of the privacy practices, you may make it in writing to Jennifer Bennett RD, CDE or Katie Keller, RD. They will acknowledge receipt of your complaint and ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
College of Dietitians of Alberta
1320, 10123 99 Street
Edmonton AB T5J 3H1
TOLL FREE 1-866-493-4348
For general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street, Ottawa ON, K1A 1H3