Policies and Procedures

We are committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information ("Personal Information"). As part of this commitment, our privacy policy governs our actions as they relate to the collection, use and disclosure of Personal Information.

Our privacy policy is based upon the values set by the Canadian Standards Association's Model Code for the Protection of Personal Information and Canada's Personal Information Protection and Electronic Documents Act.

1. Introduction

We are responsible for maintaining and protecting the Personal Information under our control. We have designated an individual or individuals who is/are responsible for compliance with our privacy policy.

2. Identifying Purposes

We collect, use and disclose Personal Information to provide you with the product or service you have requested and to offer you additional products and services we believe you might be interested in. The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address and payment information is provided as part of the order process.

3. Consent

Knowledge and consent are required for the collection use or disclosure of Personal Information except where required or permitted by law. Providing us with your Personal Information is always your choice. However, your decision not to provide certain information may limit our ability to provide you with our products or services. We will not require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except as required to be able to supply the product or service.

4. Limiting Collection

The Personal Information collected will be limited to those details necessary for the purposes identified by us. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, or the Internet.

5. Limiting Use, Disclosure and Retention

Personal Information may only be used or disclosed for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by law. Personal Information will only be retained for the period of time required to fulfill the purpose for which we collected it or as may be required by law.

6. Accuracy

Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfil the purposes for which it is to be used.

7. Safeguarding Customer Information

Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information. We take all reasonable precautions to protect your Personal Information from any loss or unauthorized use, access or disclosure.

8. Openness

We will make information available to you about our policies and practices with respect to the management of your Personal Information.

9. Customer Access

Upon request, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to it. You may verify the accuracy and completeness of your Personal Information, and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.

November 27, 2015

The Occupational Health Clinics for Ontario Workers Inc. (OHCOW) collects personal health information about workers directly from the worker and/or, where applicable, from the person acting on the worker’s behalf.

The personal health information that OHCOW collects includes, but is not limited to, the worker’s name, date of birth, home and email address, health history, OHIP number, SIN and the records of visits to health care professionals along with treatments and care provided.

Occasionally, OHCOW collects personal health information about workers from other sources if it has obtained the worker’s consent to do so or if the law permits.

Uses and Disclosures of Personal Health Information

OHCOW may collect, use and disclose the personal health information of a worker in the following contexts and/or for the following purposes:

  • To plan, administer and manage OHCOW’s internal operations;
  •  To share personal health information with personnel at other OHCOW locations where doing so is consistent with the other purposes set out herein;
  • To conduct risk management and quality improvement activities (such as sending patient/client satisfaction surveys);
  • To teach (omitting any personal identifying information);
  • To compile statistics, analyze trends and manage OHCOW’s database (omitting any personal identifying information);
  • To participate in particular research initiatives OHCOW believes will benefit itsclients. Consents for each individual research project are obtained separately.
  • To provide medical reports and/or assessments to the Workplace Safety and Insurance Board (WSIB), including the Operations Branch and/or Appeals Branch and the Workplace Safety & Insurance Appeals Tribunal, which include personal identifying information. These reports may be relied upon in the context of the worker’s WSIB claim and may assist the adjudicator(s) to determine entitlement.

Be advised that:

    • While OHCOW endeavours to allow workers and/or their representatives to review a given report before it is forwarded to the WSIB, in certain circumstances, a report and/or assessment OHCOW prepares may be disclosed to the WSIB without the worker’s or worker’s representative’s advance review.
    • Workers should understand that in certain circumstances, OHCOW may provide information to the WSIB regarding a worker regardless of the worker’s consent.
  • To submit reports to the WSIB and/or the Ministry of Labour (MOL) regarding OHCOW’s operations. These reports are necessary for the funding arrangements with the WSIB and/or MOL. Personal identifying information of workers is not included in these reports; and
  • To comply with legal and regulatory requirements and fulfill other purposes permitted or required by law.
    • This includes producing and disclosing personal health information where required to do so, for example, by order or summons of a competent tribunal, including but not limited to the WSIB and its various branches.
  • To give effect to any instructions, requests and further consents OHCOW receives from the workers to whom it provides services.
  • If there is a reasonable basis to believe that disclosing a worker’s personal health information is necessary to avoid harm to a person, OHCOW may disclose a worker’s personal health information, but will strive to do so only to the extent required in order to address the risk of harm.

Workers’ Rights

  • OHCOW takes steps to protect personal health information from theft, loss and unauthorized access, copying, modification, use, disclosure and disposal.
  • OHCOW conducts audits and completes investigations to monitor and manage our privacy compliance. OHCOW ensures that every person who performs services for OHCOW protects privacy and only uses workers’ personal health information for the purposes for which OHCOW has the worker’s consent.
  • OHCOW’s clients may refuse to give consent and have the right to withdraw consent at any time. This includes the right to give or withdraw consent in part or to limit the collection, disclosure and/or use of their personal health information to certain purposes where possible. In such circumstances, OHCOW’s ability to provide services may be limited or extinguished.

OHCOW’s clients have the right to complain to the Information and Privacy Commissioner/Ontario at any time. The Commissioner can be reached at:

Information & Privacy Commissioner/Ontario 2 Bloor Street East, Suite 1400 Toronto, ON M4W 1A8
Phone: 1-800-387-0073
Fax: 1-416-325-9195

How to Contact Us

For more information about our privacy protection practices, or to raise a concern, contact us at:

Dave Wilken, Privacy Officer
1090 Don Mills Road, Suite 606
Toronto, ON, M3C 3R6
eMail: dwilken@ohcow.on.ca
Phone: 416-510-8713
Fax: 416-443-9132


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Other Websites

Our website may contain links to other third party sites that are not governed by this privacy policy. Although we endeavour to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave our website. Additionally, we are not responsible for the privacy practices employed by third party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

If you have questions or comments regarding our policies or procedures, contact OHCOW’s Chief Operating Officer Dave Wilken at dwilken@ohcow.on.ca