Patient Privacy Policy

1. Our Commitment to Privacy

Toronto Vision Therapy and Optometry ("TVTO," "we," "us") is committed to protecting the privacy and confidentiality of the personal information entrusted to us.

This policy describes how we collect, use, disclose, retain, and protect personal information in connection with services provided through TVTO. Clinical and related services are provided in connection with Ramesh Optometry Professional Corporation and Toronto Vision Therapy Inc.

We handle personal health information in accordance with Ontario's Personal Health Information Protection Act, 2004 ("PHIPA") and other applicable privacy laws and professional requirements.

2. Information We Collect

Depending on the services you receive and your interactions with us, we may collect information such as:

• identification and contact information;
• health and medical information relevant to your care;
• examination, assessment, treatment, vision therapy, and prescription information;
• referral and communication records;
• appointment and scheduling information;
• insurance, billing, and payment information;
• information contained in telephone calls, emails, forms, or other communications with us; and
• video images collected through security monitoring in common or administrative areas of the clinic.

We may collect information directly from you or, where permitted, from other persons or organizations such as health care providers, family members, substitute decision-makers, insurers, or referring professionals.

3. How We Use Information

We may collect and use personal information for purposes reasonably connected with providing and operating our services, including:

• assessing and providing eye care, vision therapy, optical, and related services;
• maintaining clinical and administrative records;
• scheduling and managing appointments;
• communicating with patients and other authorized persons;
• processing payments, insurance claims, and other billing;
• coordinating care with other health professionals;
• responding to questions, requests, or complaints;
• quality assurance, staff training, and service improvement;
• protecting patients, staff, property, and clinic operations;
• administering and operating the clinic; and
• meeting legal, regulatory, professional, and reporting requirements.

We limit our collection and use of personal information to what is reasonably necessary for the applicable purpose.

4. Communications, Recording and Monitoring

Telephone calls or other communications with TVTO may be recorded, transcribed, or reviewed for purposes such as quality assurance, training, documentation, and clinic administration, where permitted by law. Where notice or consent is required, we will take appropriate steps to obtain it.

Video surveillance may be used in reception, waiting, entrance, or other common and administrative areas for security and safety purposes. Surveillance cameras are not used in examination or treatment rooms or other areas where a higher degree of privacy would reasonably be expected.

Audio is not recorded as part of our video surveillance system.

From time to time, limited live monitoring of administrative areas may also be used for appropriate operational, supervisory, security, or training purposes.

5. Sharing Information

We do not sell personal health information.

We may disclose information where reasonably necessary and permitted or required by law, including to:

• health care providers involved in your care;
• insurers and other payors;
• persons you authorize to receive information;
• regulatory, governmental, or legal authorities;
• service providers and agents that support our technology, records, communications, billing, administration, or other clinic operations; and
• other persons where disclosure is permitted or required by law.

Service providers and agents are expected to protect information appropriately and use it only for authorized purposes.

6. Consent

Depending on the circumstances, we may rely on express or implied consent as permitted by law.

You may withdraw or place conditions on your consent, subject to legal, professional, contractual, or other applicable requirements. A withdrawal of consent does not apply retroactively and may affect our ability to provide certain services.

In some circumstances, the law permits or requires us to collect, use, or disclose information without consent.

7. Protecting Your Information

We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the information we hold.

These measures may include:

• limiting access to people who require the information for authorized purposes;
• password and access controls;
• secure information systems and physical storage;
• privacy and confidentiality requirements for staff and service providers;
• staff privacy training; and
• procedures for responding to privacy and security incidents.

No employee or other person working with TVTO may access patient information merely because it is available to them.

8. Retention and Disposal

We retain personal information for as long as reasonably necessary for the purposes for which it is maintained and to comply with applicable legal, regulatory, professional, and business requirements.

Different types of information may have different retention periods.

When information is no longer required, we take reasonable steps to securely destroy, delete, or de-identify it, as appropriate.

9. Access, Correction and Privacy Choices

Subject to applicable law, you may:

• request access to your personal health information;
• request correction of information that you believe is inaccurate or incomplete;
• ask how your information has been collected, used, or disclosed;
• withdraw or limit consent where permitted; and
• raise a concern or make a privacy complaint.

We may need to verify your identity before processing a request.

10. Privacy Officer

Questions, access or correction requests, and privacy concerns should be directed to our Privacy Officer:

11. Complaints

If you have a privacy concern, we encourage you to contact our Privacy Officer so that we can review it.

You also have the right to contact the Information and Privacy Commissioner of Ontario (IPC) regarding matters governed by PHIPA.

12. Changes to This Policy

We may update this policy as our practices, technology, services, or legal requirements change.

The current version will be made available through the clinic and may also be posted on our website.