Privacy Policy

Privacy of personal information is important to Dynamic Functional Solutions Inc.  (“DFSI” or “we”, “our”, or “us”). We are committed to safeguarding the personal information entrusted to us by collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide or as otherwise permitted or required by law.  DFSI strives to be open and transparent as to how we handle personal information, and we freely communicate our privacy policies and practices to our claimants and customers.

This privacy policy is current as of the “updated” date which appears at the top of this page.  We may modify this privacy policy from time to time.  When changes are made to this privacy statement they will become immediately effective when published in a revised privacy policy posted on our website, or we may also communicate the changes to you by other means.

Personal information is information about an identifiable individual.  Personal information may include, but is not limited to, an individual’s personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status); or health (e.g., health history, health conditions, health services received, current medical status). 

PRINCIPLES

The purpose of this privacy policy is to inform you about our privacy practices, including how we collect, use and disclose your personal information in connection with our services.

The following principles form the basis of DFSI’s privacy practices:

1. Accountability

DFSI is responsible for the personal information in its possession or control.  DFSI has implemented the following practices with respect to personal information:

• Training is provided to all staff regarding our privacy practices and policies at the beginning of their employment;
• Personal information is only collected, used or disclosed as necessary to provide services or as required or permitted by law; and
• DFSI’s agreements with external consultants, service providers, and agencies with access to personal information require that they ensure a comparable level of protection for personal information.
  

DFSI has appointed a Privacy Officer who is responsible for ensuring that our privacy policies and practices are followed and has implemented procedures to address complaints and inquiries with respect to our collection, use, and disclosure of personal information. 

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2. Purpose

DFSI collects personal information for the purpose of facilitating assessment services with health and/or other professionals.  This includes, but is not limited to, scheduling, arranging secondary services, facilitating communications between customers and assessors, and billing purposes.  Any person collecting personal information on behalf of DFSI will be able to explain why they are collecting the personal information.  If your personal information is to be used for any other purpose, we will ask for your consent prior to any use, unless we are otherwise permitted or required by law to use it for the other purpose.

3. Consent

We collect, use and disclose your personal information with your consent or as permitted or required by Canadian privacy laws.  It is important that individuals are informed about why their personal information is being collected and how it will be used when consent is obtained.  How we obtain your consent (i.e. the form we use) will depend on the circumstances, as well as the sensitivity of the information collected.  Due to the often sensitive nature of the personal information collected and used by DFSI, we obtain expressed written consent whenever possible.  Consent to use or disclose your personal information may be withdrawn at any time; however this may limit our ability to provide the requested assessment or other services.

4. Collection‍

DFSI collects personal information directly or indirectly from clients or through our customers and contracted assessors.  We will only collect the amount and type of personal information that is required to provide services to our claimants and customers or as required for the purposes for which it is being collected.  Personal information will only be collected by fair and lawful means. The personal information that we may collect about you includes, but is not limited to:

• Demographic Information (Age, gender, address, etc.) 
• Insurance related information (Policy number, claim number, accident details, claim forms, etc.)
• Medical Records (Clinical notes and records, diagnostic testing, etc.)  

You will not be misled regarding the purpose of collecting your personal information.

5. Use, Disclosure, and Retention

Your personal information is used for the purpose of facilitating assessment services or as otherwise permitted or required by law.  We limit who has access to this information and they only have access to the information that is needed to complete their tasks or otherwise in connection to the purpose for which it was collected.  

Personal information may be disclosed to assessors contracted by DFSI, and/or referral sources. A limited amount of personal information may be transferred to third party agencies for the purpose of arranging secondary services, such as transportation and translation.  The personal information transferred is limited to only what is necessary to provide the requested services.  Consultants contracted by DFSI to perform business functions, such as lawyers, accountants and IT consultants, may have access to personal information as required to provide DFSI with such services.  Agreements are in place to ensure equivalent protection of personal information.

Additionally, we may use and disclose your personal information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.  In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets, or other business transaction.]

Your personal information may be stored and processed at our offices in Canada or at the offices of our third party service providers, or by our third party service providers in [Canada and the United States].  Other jurisdictions may have different data protection rules than Canada.  While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located.  Those laws may require disclosure of your Personal Information to authorities in that country.  For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Officer using the contact information in the “Inquiries” section below.

Personal information is retained by DFSI according to an internal retention schedule.  This schedule was developed to ensure that personal information is kept long enough that we can answer any questions you may have regarding the services provided.  Electronic data is purged at the end of the retention period and the hardware is physically destroyed by a third party company specialized in records and IT destruction.  Any paper files are also physically destroyed by shredding at the end of use.

6. Accuracy

DFSI will take reasonable measures to ensure that the personal information it holds is accurate.  If there is a discrepancy in the personal information collected, we will contact the source of the information for clarification.  You may request a correction to your own personal information if an error is found.  We may ask you to put your request in writing and provide documentation of the correct information.  It is not necessary for us to update your personal information once the requested assessment services have been completed.

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7. Protection

DFSI understands the importance of protecting personal information and has implemented physical, organizational, contractual and technological security measures with a view to prevent loss, misuse or modification of personal information, as well as, any unauthorized disclosure or access to personal information.  We have implemented the following such measures:

Physical Measures:

• Lock-restricted access to all offices; and
• Security cameras for secure areas.
  

Technical Measures:

• Electronic information is transmitted through an encrypted channel,
• Secure computer networks with digital certificate and TLS connections;
• Redundancy planning; Backups and disaster recovery;
• Data and information is stored on servers in Canada (live and backup information); and
• Cross border service platforms may be used with a peer to peer encrypted link, however no information will be stored by DFSI at rest outside of Canada.
  

Organizational Measures:

• Privacy policies and procedures which are reviewed regularly;
• Internal and external privacy and IT security audits; and
• Business continuity plan which ensures that personal information can be recovered.

8. Access

You may request access to the personal information held by DFSI or information regarding to whom your personal information has been disclosed.  You must make such requests in writing and these must be accompanied by proof of identification.  Please contact our Privacy Officer for more information.

Should you find an error in your personal information held by DFSI, we ask that you put your request for correction in writing.  You may be asked to provide documentation that demonstrates that our records are incorrect.  We shall amend any personal information found to be incorrect and, where appropriate, notify any party that has access to this information.  This applies to factual personal information only and not any professional opinions rendered by independent assessors.

9. Inquiries

You may contact our Privacy Officer in writing with any questions or concerns you may have regarding your personal information, DFSI’s privacy practices, or this policy.  Our Privacy Officer will acknowledge receipt of your questions or concerns to ensure that it is investigated promptly.  Our Privacy Officer may be reached at:

Privacy Officer

Simon Mah

120 Traders Blvd. East, Suite 105

Mississauga, ON L4Z 2H7

Toll-Free: 1-877-897-5515

Email: privacy@dfsiime.com

You may contact the applicable privacy commissioner with respect to our collection, use, and disclosure of your personal information, including, where applicable, the Office of the Privacy Commissioner of Canada.

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec K1A 1H3

Toll-free: 1-800-282-1376

Phone: (819) 994-5444

TTY: (819) 994-6591