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DISCLAIMER & PRIVACY POLICY
The information provided on this website (Intuition Nutrition) serves as an educational tool and is for informational purposes only.
The information provided here is not designed or intended to constitute medical or mental health advice or used for diagnosis. It should not replace medical assessments or treatment from your health care provider.
Please consult with your primary health care provider before making any changes to your diet or lifestyle. If you have a question pertaining to nutrition, please contact me to schedule a free 15 min discovery call. During this call, we can find out if I am able to support you with your unique goals and questions & if so, then proceed to book an initial assessment.
Thank you for your understanding!
Privacy Policy for Intuition Nutrition:
Privacy of personal information is of the utmost importance to Intuition Nutrition. We are committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the services we provide. We aim to be open and transparent about how we handle personal information. This document/webpage describes our privacy policies.
What is Personal Health Information?
Personal health information is information about an identifiable individual. Personal health information includes information that relates to:
• the physical or mental health of the individual (including family health history).
• the provision of health care to the individual (including identifying the individual’s health care provider).
• community and home care services.
• payments or eligibility for health care or coverage for health care.
• the donation or testing of an individual’s body part or bodily substance.
• the individual’s health number; or
• the identification of the individual’s substitute decision-maker.
Who are we?
Our organization, Intuition Nutrition, includes at the time of writing 1 staff member – Jenna Zaika, Registered Dietitian, Founder of Intuition Nutrition and Health Information Custodian for all of Intuition Nutrition’s client files.
Why we collect Personal Health Information:
We collect, use, and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal health information is to provide nutrition counselling through way of conducting nutrition assessments and developing corresponding treatment plans.
For example, we collect information about a client’s health history, including their family history, physical condition and function and social situation in order to help us assess what their health needs are, to advise them of their options and then to provide the health care they 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.
We also collect, use, and disclose personal health information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
Related Purpose #1: To obtain payment for services or goods provided. Payment is obtained from the individual receiving the service.
Related Purpose #2: To promote our clinic, new services, special events and opportunities (e.g. a seminar or conference) that we have available. We will always obtain expressed consent from the client prior to collecting or handling personal health information for this purpose.
Related Purpose #3: To comply with external regulators. Our professionals are regulated by the College of Dietitians of Ontario and the Ordre professionnel des diététistes du Québec who may inspect our records and interview our staff as a part of its regulatory activities in the public interest. The College of Dietitians of Ontario has their own strict confidentiality and privacy obligations. In addition, as professionals, we will report serious misconduct, incompetence, or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting illegal behaviour tothe authorities. In addition, we may be required by law to disclose personal health information to various government agencies (e.g., the Ministry of Health and Long-Term Care, Children’s Aid Societies (CAS), Canada Customs and Revenue Agency, Information and Privacy Commissioner, Ontario, etc.).
Related Purpose #4: To educate our staff and students. We value the education and development of future and current professionals. We will review client records in order to educate our staff and students about the provision of health care.
Protecting Personal Information:
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
• All client information is documented and stored solely on Practice Better, which is fully compliant with HIPAA, PIPEDA, PHIPA, and GDPR regulations.
https://help.practicebetter.io/hc/en-us/articles/234814027-Privacy-and-Security-on-Practice-Better
• Paper information is scanned into our secure EMR platform Practice Better and then shredded and discarded.
• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, strong passwords are used on all computers and mobile devices.
• We try to avoid taking personal health information home to work on there. However, when we do so, personal health information is only accessed via the secure Practice Better app and viewed only in confidential spaces.
• Paper information is transferred through sealed, addressed envelopes or boxes by reputable companies with strong privacy policies. No paper documentation is kept or stored as all is stored on our EMR software Practice Better.
• Electronic information is either anonymized or encrypted before being transmitted.
• Our staff members are trained to collect, use, and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• We do not post any personal information about our clients on social media sites and our staff members are trained on the appropriate use of social media sites.
• External consultants and agencies with access to personal information must enter into privacy agreements with us.
Retention and Destruction of Personal Information:
We 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.
We keep our client files for at least ten years from the date of the last client interaction if the client was younger than 18 at the date of the last visit, at least 10 years after the date that the client turns, or would have turned, 18 years of age.
We destroy paper files containing personal health information by cross-cut shredding. We destroy electronic information by deleting it in a manner that it cannot be restored.
You Can Look at Your Records.
With only a few exceptions, you have the right to see what personal information we hold about you, by contacting Jenna Zaika (Health Information Custodian) at 226-702-0734 or info@intuitionnutrition.ca. Jenna is the only person who accesses this email account. Jenna 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 $30.00 for the first twenty pages of records and 25 cents for each additional page. We may ask you to put your request in writing. We will respond to your request as soon as possible and generally within 30 days, if at all possible. If we cannot give you access, we will tell you the reason, as best we can, as to why.
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. At your request and where it is reasonably possible, we will notify anyone to whom we sent this information (but we may deny your request if it would not reasonably have an effect on the ongoing provision of health care). 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.
If there is a privacy breach:
While we take many precautions to avoid any breach of your privacy, if there is a loss, theft, or unauthorized access of your personal health information we will notify you.
Upon learning of a possible or known breach, we will take the following steps:
• We will contain the breach to the best of our ability, including by taking the following steps if applicable
o Retrieving hard copies of personal health information that have been disclosed
o Ensuring no copies have been made
o Taking steps to prevent unauthorized access to electronic information (e.g., change passwords, restrict access, temporarily shut down system)
• We will notify affected individuals
o We will provide our contact information in case the individual has further questions
o We will provide the Commissioner’s contact information and advise the affected individual of their right to complain to the Commissioner
• We will investigate and remediate the problem, by:
o Conducting an internal investigation
o Determining what steps should be taken to prevent future breaches (e.g. changes to policies, additional safeguards)
o Ensuring staff is appropriately trained and conduct further training if required
Depending on the circumstances of the breach, we may notify and work with the Information and Privacy Commissioner of Ontario. We may also report the breach to the relevant regulatory College if we believe that it was the result of professional misconduct, incompetence, or incapacity.
Do you have questions or concerns?
Our Information Officer and Health Information Custodian, Jenna Zaika, Registered Dietitian, can be reached at: 226-702-0734 or info@intuitionnutrition.ca.
She will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. 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.
You also have the right to complain to the Information and Privacy Commissioner of Ontario if you have concerns about our privacy practices or how your personal health information has been handled, by contacting:
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Telephone: Toronto Area (416/local 905): (416) 326-3333
Long Distance: 1 (800) 387-0073 (within Ontario)
TDD/TTY: (416) 325-7539
FAX: (416) 325-9195
This policy is made under the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3. It is a complex statute and provides some additional exceptions to the privacy principles that are too detailed to set out here.
For more information on your health privacy rights, please view the following resources:
https://www.ipc.on.ca/access-individuals/access-and-correction/
https://www.ontario.ca/laws/statute/90f31
https://www.ontario.ca/laws/statute/90m56
https://www.ontario.ca/laws/statute/04p03
https://www.ontario.ca/laws/statute/17c14
https://www.cai.gouv.qc.ca/english/