Policies & Privacy

Ontario Partners in Health (OPiH) is committed to protecting individual privacy and the confidentiality of the personal health information it holds. This notice describes how health information about you may be used, collected, and disclosed and how you can access this information, in compliance with Ontario’s Personal Health Information Protection Act, 2004.

Your Health Record

Your health record includes information relevant to your health including your date of birth, contact information, health history, family health history, details of your physical and mental health, record of your visits, the care and support you received during those visits, results from tests and procedures, and information from other health care providers.

Information regarding your health care visits is recorded in your electronic health record – it is stored in OPiH’s Collaborative Health Record (CHR) system which is password and firewall protected. This includes information from visits to the after hours clinic, to allied health professionals (i.e. mental health counsellor, pharmacist, etc.), to specialists (i.e. allergist, gynecologist, psychiatrist, etc.) and to primary care providers at BWFHT. All members of our healthcare team have access to electronic health records.

All staff and providers receive mandatory privacy training during orientation and on an ongoing basis. All staff and providers sign a privacy and confidentiality agreement during orientation and annually. Electronic Health Records are audited for unauthorized use and/or access as per BWFHT’s CHR Audit Policy.

The information in your health record belongs to you, but the health record itself is the property of Ontario Partners in Health [Explanatory note: based on case law, health information custodian owns the physical or electronic records].

With limited exceptions, you have the right to access the health information we hold about you, whether in the health record or elsewhere. If you request a copy of your record, one will be provided to you at a reasonable cost. If you wish to view the original record, one of our staff members must be present, and a reasonable fee may be charged for this access. If you need a copy of your health record, please contact our Health Records Department in writing at: 100 Marie Curie Private, Suite 300, Ottawa, ON, K1N 6N5. In rare situations, you may be denied access to some or all of your record (with any such denial being in accordance with applicable law and as per PHIPA).

We make every effort to ensure that all of your information is recorded accurately. Please let us know if there is something that is incorrect. You have a right to ask for a correction to your record if you disagree with what is recorded, and in most cases we will be able to make the requested correction, or otherwise we will ask you to prepare a statement of disagreement to be attached to the record.

Our Practices

We collect, use and disclose (meaning share) your health information to:

• Treat and care for you
• Deliver our programs
• Plan, administer and manage our internal operations
• Be paid or process, monitor, verify or reimburse claims for payment
• Provide appointment reminders to you
• Conduct risk management, error management and quality improvement activities
• Educate our staff and students
• Respond to or initiate proceedings
• Conduct research (subject to certain rules)
• Compile statistics
• Allow for the analysis, administration and management of the health system
• Comply with legal and regulatory requirements
• Fulfil other purposes permitted or required by law

Our collection, use and disclosure (sharing) of your personal health information is done in accordance with Ontario law.

Your Choices

You have a right to make choices and control how your health information at the BWFHT is collected, used, and disclosed, subject to a few exceptions. (Patient Lockbox Request Form)

For most health care purposes, your consent to use your health information is implied as a result of your consent to treatment, unless you tell us otherwise. We may also collect, use and share your health information in order to communicate or consult with other health care providers about your care unless you tell us you do not want us to do so.

You have the right to ask that we not share some or all of your health record with one or more of our staff members or ask us not to share your health record with one or more of your external health care providers (such as a specialist). This is known as asking for a “lockbox”.  It is important to note that there may be an impact on our ability to provide you with the best care if our healthcare professionals cannot access your health record.  For this reason, we ask that you discuss this with your family doctor first.

There are other circumstances where we are not allowed to assume we have your consent to share information.  For example, we must have your permission to give your health information to people who do not provide you with health care, including health professionals in the Organization not involved in your care, your insurance company or your employer. We may also need consent to communicate with any family members or friends with whom you would like us to share information about your health (unless one or more of these individuals is your substitute decision-maker).

When we require and ask for your consent, you may choose to say no. If you say yes, you may change your mind at any time. Once you say no, we will no longer share your information unless you say so. Your choice to say no may be subject to some restrictions under applicable law and reasonable notice.

There are cases where we may collect, use or disclose your health information without your consent, as permitted or required by law. For example, we do not require your consent to use your information for billing, risk management or error management, quality improvement purposes; or to disclose personal health information in a number of permitted or required circumstances, including to eliminate or reduce a significant risk of serious bodily harm; or to fulfil mandatory reporting obligations under other laws such as for child protection or safe operation of a motor vehicle.

For More Information or Complaints

If you have any questions or concerns about our privacy practices we invite you to contact our Privacy Officer at:

BWFHT Privacy Officer
100 Marie Curie Private, suite 300
Ottawa, ON K1N 6N5

privacyofficer@opih.ca

If, after contacting us, you feel that your concerns have not been addressed to your satisfaction, you have the right to complain to the Information and Privacy Commissioner of Ontario.  The Commissioner can be reached at:

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
1-800-387-0073
1-416-325-9195 (fax)

or visit the IPC website

We value the inherent worth and dignity of every person. It is the commitment of the ByWard Family Health Team (BWFHT) and its leadership team to create a culture of respect and civility that is free from negative, aggressive, and inappropriate behaviors, and to offer an environment aimed at providing high quality of care and services in an atmosphere of respect, collaboration, openness, safety and equality.

BWFHT’s Workplace Respect and Civility Policy outlines clear expectations and the responsibility for civil conduct of all individuals who work and/or receive care/services within any of our locations.

Incivility and disrespect in the workplace can be a barrier to effective communication. It can have a detrimental impact on the quality of patient care, trust and the patient-provider relationship. Uncivil behaviors will not be tolerated.

Everyone is expected to behave in a respectful and civil manner during all interactions with each other. Behaviors that promote respect, positivity and civility in our workplace include:

• Using respectful, supportive, and encouraging language in all interactions, no matter the subject of conversation
• Saying “please” and “thank you”
• Questioning someone’s position on an issue politely rather than asserting your position is the right one; listening to the other person’s position with an open mind
• Giving factual, non-personal feedback focused on the issue of concern
• Apologizing when you do something that offends someone
• Expressing appreciation when a someone does something correctly and in a timely manner
• Understanding that others are acting to the best of their abilities and with the best intentions
• Approaching conflict with a true desire for resolution, rather than as a fight or opportunity to belittle
• Maintaining a positive attitude, even when you are having a bad day

Addressing incidents of incivility as soon as possible is an important preventative measure to reduce the risk of uncivil behaviour escalating in severity to workplace violence and/or harassment. We pledge to address all reported incidents.

Our approach to managing incivility toward patients is part of our process for Patient Feedback. To report an incident, please complete our feedback form: https://bywardfht.ca/contact/feedback/

We appreciate your kindness and willingness to work with us to promote and maintain a healthy environment for everyone.

Sincerely,

The ByWard Family Health Team

Late Arrival

Our providers and staff aim to make your visit a pleasant one.  In our efforts to make your visit more comfortable and to minimize your wait time, our office has implemented a late arrival policy. If a patient is more than 10 minutes late for an appointment, the appointment may need to be rescheduled.  This is to ensure that the patients who arrive on time do not wait longer than necessary to see the provider.  You may be given the option to wait for another appointment time on the same day if one is available.  We will try to accommodate late‐comers as best as possible, but cannot compromise on the quality and timely care provided to our other patients. All patients are encouraged to arrive at the office at least 15 minutes prior to the scheduled appointment to register and complete any required paperwork.  We appreciate your compliance and understanding with this policy so that we can continue to provide excellent medical care as well as excellent customer service.

*May be subject to Missed Appointment fee.

Appointment Cancellation

Your scheduled appointment time is reserved just for you. Our providers make every effort to be on time for scheduled appointments. In return, we ask that you help us by keeping your scheduled appointments and by notifying us in advance when you are unable to do so. When you give us advanced notice we are able to accommodate other patients.  A missed appointment is when you fail to show for a scheduled appointment without notifying the clinic or when you cancel without sufficient notice.

If you are unable to attend your scheduled appointment, contact our clinic immediately. Since appointments are in high demand, your prompt cancellation will give another patient the opportunity to access timely medical care. Appointments that are not cancelled by 12 pm (Noon) one (1) business day prior to your scheduled appointment will be subject to fees. The fees vary depending on the type of appointment that was missed.

See the most up to date list of fees.

There is no charge for rescheduling or cancelling an appointment if we are notified. Fees may be waived due to family or health emergencies at the discretion of the physician.

As a courtesy, the clinic sends appointment reminders via email or telephone for all scheduled appointments. If you do not receive an appointment reminder, you are still responsible for arriving on time to your scheduled appointment. A telephone or email appointment reminder is not guaranteed, nor does a lack of one signify a void in our appointment cancellation policy.

Pay by Credit Card
To help save time, you may pay your invoice here, any time, any day, using your credit card, through a third-party automated bill payment service. Ontario Partners in Health (OPiH), the company that manages ByWard Family Health Team, does not charge an additional fee for using this convenient service.

We accept payments using:

You will need:
• The invoice number
• The balance owed on your invoice
• Your credit card number, expiry date & CVD

OPiH does use the services of Moneris to process your credit card payment. Accordingly, any personal information you provide during the payment process would be covered by the Privacy Policy and Terms and Conditions of Use on Moneris website.

Pay by Phone
You may pay your bill by calling the ByWard FHT at 613-564-3950.

Pay by Mail
Mail your payment to:
Ontario Partners in Health
Billing Department
2310 St-Laurent Blvd, Suite 319
Ottawa, ON
K1G 5H9

*** Please include the invoice number and name of patient (if other than yourself) on the cheque.***

The ByWard FHT, which includes its providers and staff, uses a mix of different electronic communication Services to contact patients, depending on the sensitivity, importance, and nature of the message. The electronic communication Services include:

• Email and text messaging
• Online Appointment Scheduling Portal
• Online forms
• Virtual visits (video and phone)
• Patient Portal

E-MAIL & Text Messaging

Unfortunately, while extremely convenient, e-mail and text messaging are not technically secure communication mediums. These communication Services will not be used for therapeutic purposes or to communicate clinical information. Where applicable, the use of these Services will be limited to education, information, and administrative purposes such as appointment reminders.

SECURE ONLINE APPOINTMENT SCHEDULING PORTAL

ByWard FHT uses the TELUS Collaborative Health Record (CHR) e-booking system. This Service is one of three patient-focused applications that are included with the TELUS Collaborative Health Record (CHR). All available appointments can be scheduled and managed online 24 hours a day, 7 days a week via the patient portal or the appointment link on the ByWard FHT website. To access this secure Service, patients must enter their demographic information. Note that the Information entered must match the information the clinic has on record.

SECURE ONLINE FORMS

In certain situations, we believe a secure web-based form (OceanMD) is the most effective way for you to communicate with us, such as if you wish to notify us of updated contact or OHIP information. To ensure that the information you are entering on these forms is being managed and transferred in the most secure methods, ByWard FHT uses a 256-bit data encryption, Secure Socket Layer, and Hyper Text Transfer Protocol Secure. As an additional layer of security, all transmitted patient data is encrypted using a client encryption key, defined by and known only by the health information custodian and their chosen agents. OceanMD system administrators do not have access to this key. Since the key is required to decrypt PHI, this policy ensures that even trusted OceanMD administrators cannot view PHI.

Qnaires

ByWard FHT providers and staff also use digital forms (known as Qnaires) which are sent via sms or email to collect patient health data.  You can complete Qnaires while at the clinic on a tablet or they can be completed in the privacy of your home using your cell phone, tablet, or personal computer. Responses are securely sent to your provider’s CHR inbox and are saved in your patient chart. CHR data is fully encrypted at rest and in transit. Data in transit is encrypted using TLS. Encryption at rest is performed with multiple layers of AES.

Virtual Visits

ByWard FHT providers offer virtual care for some patient visits. These visits are conducted from the patient’s chart using TELUS CHR’s integrated video/audio solution. This service is an Ontario Health Verified video solution that meets provincial privacy, security, interoperability, and technical requirements. All existing laws regarding your access to medical information and copies of your medical records apply to this telemedicine consultation. Your telemedicine appointment is private and confidential, and it is only seen and heard by the healthcare provider involved.  Please note that NOT ALL conditions can be looked at through telemedicine. In some cases, your doctor may ask you to come to the clinic if necessary, for a physical examination.

Patient Portal

The patient portal is a patient-focused secure application that is integrated with the TELUS Collaborative Health Record (CHR). Through the Patient Portal, patients can:

• View new and existing messages from the clinic
• Respond to messages, if enabled
• Receive PDF copies of labs, forms, handouts, and other chart information sent from the clinic
• Book, change and cancel appointments
• View past and future appointments
• View and update demographic information

To access this secure Service, patients must go to a link, located on the ByWard website and enter their demographic information. Note that the Information entered must match the information the clinic has on record.

Risks of using electronic communication

• The use of electronic communications to discuss sensitive information can increase the risk of such information being disclosed to third parties.
• Despite reasonable efforts to protect the privacy and security of electronic communication, it is not possible to completely secure the information.
• Employers and online services may have a legal right to inspect and keep electronic communications that pass through their system.
• Understand that a virtual visit is not secure in the same way as a private appointment in an exam room.
• Electronic communications can introduce malware into a computer system, and potentially damage or disrupt the computer, networks, and security settings.
• Electronic communications can be forwarded, intercepted, circulated, stored, or even changed without the knowledge or permission of the provider or the patient.
• Even after the sender and recipient have deleted copies of electronic communications, backup copies may exist on a computer system.
• Electronic communications may be disclosed in accordance with a duty to report or a court order.

If email or text is used as an e-communication tool, the following are additional risks:

• Email and text messages can more easily be misdirected, resulting in an increased risk of being received by unintended and unknown recipients.
• Email and text messages can be easier to falsify than handwritten or signed hard copies. It is not feasible to verify the true identity of the sender or to ensure that only the recipient can read the message once it has been sent.

You and the BYWARD FHT will not use email or text to communicate sensitive medical information about matters specified below:

• Sexually transmitted disease
• AIDS/HIV
• Mental health
• Developmental disability
• Substance abuse
• You agree to inform the BYWARD FHT provider of any types of information you do not want sent via these Services, in addition to those set out above. You can add to or modify the above list at any time by notifying your provider in writing.

BYWARD FHT RESPONSIBILITIES

• Electronic communications concerning diagnosis or treatment are part of your medical record. Other individuals authorized to access the medical record, such as staff and billing personnel, may have access to those communications. Providers may forward electronic communications to staff and those involved in the delivery and administration of your care. BYWARD FHT providers and staff will not forward electronic communications to third parties, including family members, without your prior written consent, except as authorized or required by law.
• As an organization, we are committed to respecting the guidelines set out by Personal Health Information Privacy Act (PHIPA). All ByWard FHT employees and providers have signed and are bound by the clinic’s privacy policy which outlines the absolute confidentiality of patient information.
• In practice, the clinic requires that patients verify their demographic information, which includes email addresses, at every visit to confirm accuracy.
• All patient PHI is stored on our EMR solution (TELUS Collaborative Health Record) which is securely password-protected with two-factor authentication. Communication between all electronic devices, used at the clinic, and the clinic’s server are encrypted using “Secure Socket Layer” (SSL) protocols. Firewalls are also used on our systems to prevent unauthorized access to our networks and to stop Spam, viruses, and other unwanted content before they reach our infrastructure.
• BYWARD FHT providers or staff are not responsible for information loss due to technical failures associated with your software or internet service provider.

Patient Responsibilities:

• While ByWard FHT providers and staff will attempt to review and respond in a timely fashion to your electronic communication sent via the patient portal, they cannot guarantee that all electronic communications will be reviewed and responded to within any specific period. The Services will not be used for medical emergencies or other time-sensitive matters.
• If your electronic communication requires or invites a response from a provider and you have not received a response within a reasonable time, it is your responsibility to follow up to determine whether the intended recipient received the electronic communication and when the recipient will respond.
• Electronic communication is not an appropriate substitute for in-person communication or clinical examinations, where appropriate, or for attending the Emergency Department when needed. You are responsible for following up on the provider’s electronic communication and for scheduling appointments where warranted.
• Reasonably limit or avoid using an employer’s or other third party’s computer.
• Inform ByWard FHT of any changes in your email address, mobile phone number, or other account information necessary to communicate via the Services.
• Remember to add no-reply@opih.ca and bywardfht.ca to your “safe sender” list when setting up your junk email options.
• Review all electronic communications to ensure they are clear, and that all relevant information is provided before sending to the provider.
• Take precautions to preserve the confidentiality of electronic communications, such as using screen savers and safeguarding computer passwords.
• Withdraw consent only by email or written communication to ByWard FHT.
• If you require immediate assistance, or if your condition appears serious or rapidly worsens, you should not rely on the Services. Rather, you should call the clinic at 613-564-3950 or take other measures as appropriate, such as going to the nearest Emergency Department or urgent care clinic.
• During a virtual visit, use a private computer/device (i.e., not an employer’s or third party’s computer/device) and a secure internet connection. For example, using a personal computer or tablet is more secure than at a library, and your access to the Internet on your home network will generally be more secure than an open guest Wi-Fi connection.

With limited exceptions, you have the right to access your record of personal health information. BWFHT is required under the Personal Health Information Privacy Act (PHIPA) to respond to requests for access within 30 days. Here are some of the options for requesting a copy of all or part of your health record. Please note that this is an uninsured service and fees may apply.

Informal Access during an Appointment

During an appointment with a BWFHT health care provider you can ask for a copy of a simple documentation from your own health record. For example, you may need a list of your current medications, a copy of your or your child’s immunization record, or a copy of a particular test result. The health care provider can print a copy of the report for you before you leave the clinic. Please note that there may be documents the health care provider is not able to release to you, for example, a test result or consultation note that has not yet been reviewed by the ordering provider.

All Other Patient Access to Information Requests

1. All other requests for access to your own personal health information (PHI) must be made in writing (as per section 53 of PHIPA).
2. Written access requests should be made using the BWFHT Consent to Release Personal Health Information form. The form is available online or from a BWFHT staff member or provider.
3. Although use of the BWFHT request form is preferred because it outlines all information required to process an access request, a formal form is not required. Your request must contain:
   1. Sufficient details to enable BWFHT staff to accurately identify and locate the requested information with reasonable efforts. For example, title or type of document, type of test result, date of test, etc.; and
   2. A minimum of 3 demographic information elements to allow BWFHT staff to accurately confirm the identity of the requestor. Examples of demographic elements include: first and last name (considered 1 element), date of birth, health card number, email address, telephone number, and mailing address. This is in accordance with section 54(9) of PHIPA, custodians must “first take reasonable steps to be satisfied as to the individual’s identity” before making a health record available to them.
4. Requests for PHI should be faxed to 613-564-6627 to the attention of the Correspondence Clerk. Requests can also be mailed to BWFHT, 100 Marie Curie Private, Suite 300, Ottawa, Ontario, K1N 6H5 or emailed to Records@opih.ca.
   PLEASE NOTE: Due to the unsecure nature of email this mode of communication is not recommended.
5. In some circumstances you may be asked to make an appointment with your primary care provider or their designate (i.e. the Privacy Officer) to review the record so information can be explained.

Please note that there are other ways you can access your test results or other info. These include DynacarePlus, TOH My Chart, CHEO My Chart, etc.

As of May 11th 2023, the Byward FHT clinic has changed our masking policy. Masks will no longer be mandatory to all staff and visitors. We do however ask any patients with COVID like symptoms to mask before entering the clinic. If you do not have one, please ask our receptionist and one will be provided.

Pets are not allowed in BWFHT locations including offices, waiting rooms and clinical spaces. However, BWFHT complies with the Accessibility for Ontarians with Disabilities Act (AODA):

“ If a person with a disability is accompanied by a guide dog or other service animal, the provider of goods or services shall ensure that the person is permitted to enter the premises with the animal and to keep the animal with him or her unless the animal is otherwise excluded by law from the premises ”.

Guide Dogs and Service Animals

A client, employee or staff member with a disability who is accompanied by guide dog or service animal will be allowed access to premises that are open to the public unless otherwise excluded by law. BWFHT’s “No pet” policy does not apply to guide dogs or service animals. BWFHT complies with all Federal, Provincial, Local and University of Ottawa regulations with respect to service animals.

Definitions:

Guide dog:

Is a working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety, and increased independence for people who are blind or are visually disabled.

BWFHT acknowledges that there are other recognized disabilities which are covered for the use of a service animal; BWFHT will accept these service animal as long as the conditions below have been satisfactorily fulfilled.

Service animal:

An animal is a service animal for a person with a disability if:

1. The animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
2. The person provides documentation from a member of one of the following regulated health professional colleges confirming that the person requires the animal for reasons relating to the disability:

• • College of Audiologists and Speech-Language Pathologists of Ontario;
  • College of Chiropractors of Ontario;
  • College of Nurses of Ontario;
  • College of Occupational Therapists of Ontario;
  • College of Optometrists of Ontario;
  • College of Physicians and Surgeons of Ontario;
  • College of Physiotherapists of Ontario;
  • College of Psychologists of Ontario; or
  • College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

As per the Accessibility Standards for Customer Service, Ontario Regulation 429/07, subsection 9:

“For the purposes of this section, an animal is a service animal for a person with a disability:

(a) if it is readily apparent that the animal is used by the person for reasons relating to his or her disability;

or

(b) if the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.”

Other Considerations

The care or supervision of a service animal is solely the responsibility of his or her owner.  The service animal must be leashed or harnessed and under the control of their owner at all times. All animal excrement must be picked up by the owner and discarded in a waste container.

For BWFHT clinics located on campus, no pet may be tied up outside buildings or left unattended. Protection services will be alerted for animals left unattended. Any costs incurred in the removal or retrieval of a pet shall be the owner’s responsibility.

If a guide dog or service animal is growling, barking or otherwise threatening to harm other patients in the clinic, the supervisor or manager should be called to address the situation.

Derogations and exceptions

The Medical Director, or his or her designate, may authorize exceptions or derogations to this policy upon written request. Such exceptions may be rescinded at any time and without prior notice.

References

Accessibility for Ontarians with Disabilities Act (AODA)

Patients will not be allowed to transfer from their current primary care provider to another one in the clinic unless there are extenuating circumstances.  An example of an extenuating circumstance would be where a patient is receiving palliative care from one primary care provider and their spouse has a different primary care provider.  In this case, it would make sense for both spouses to receive care from the same doctor.

Research suggests that a long-term relationship between a patient and their primary care provider promotes health and well-being.  As with every long-term relationship, however, there will be some bumps in the road so we encourage patients to speak to their primary care provider directly about any concerns they have.  If a patient is not comfortable speaking to their primary care provider, or if there has been an irretrievable breakdown in the patient-provider relationship and the patient has been discharged from the practice, a request to transfer to another BWFHT primary care provider will be denied. S/he is urged to find another primary care provider elsewhere.