(September 24, 2015) The College of Naturopaths of Ontario, as a regulator and as an employer, must comply with a number of requirements in order to ensure the security of the information we hold and the staff who work for us. This advisory outlines these obligations and explains procedures we have put in place to meet them.
Confidentiality and the RHPA
The Regulated Health Professions Act, 1991 places a statutory duty on the College (Section 36) to maintain confidentiality except in a very limited number of situations. The College collects and stores a great deal of confidential personal information about (but not limited to) members, complaints and patients affected by complaints. The legislative requirements are such that we have to take every reasonable measure to protect this information.
Bill 168 amended the Occupational Health and Safety Act, mandating employers to take reasonable and necessary measures to protect workers from violence. In this context, this means:
- the exercise of physical force by a person against a worker, in a workplace, that causes or could cause physical injury to the worker;
- an attempt to exercise physical force against a worker, in a workplace, that could cause physical injury to the worker;
- a statement or behaviour that it is reasonable for a worker to interpret as a threat to exercise physical force against the worker, in a workplace, that could cause physical injury to the worker;
- Unwanted physical acts against another person (e.g. hitting, shoving, pushing,kicking, sexual assault);
- Any threat, behavior or action which is interpreted to carry the potential to harm or endanger the safety or others, result in an act of aggression, or destroy or damageproperty; and
- Disruptive behavior, in the workplace, that is not appropriate to the work environment (e.g. yelling, swearing).
In addition to dealing with workplace violence, Bill 168 addresses cases of workplace harassment. Employers are mandated to implement preventative measures and responses to harassment complaints. Harassment may include (but is not limited to):
- unwelcome, offensive or objectionable conduct based on race, colour, religion, national origin, age or disability;
- making remarks, jokes or innuendos that demean, ridicule, intimidate or offend;
- displaying or circulating offensive pictures or materials in print or electronic form;
- repeated offensive or intimidating phone calls or emails; and
- sexual harassment.
Actions by the College
In order to meet its obligations, the College has taken a number of steps in order to:
- establish our offices as a secure environment, free from violence and harassment; and
- ensure that all information provided to the College is kept confidential.
Among the steps we have taken is a set of procedures for visitors and deliveries. Since proclamation of the Naturopathy Act, 2007, the College has seen a dramatic increase in the number of people who arrive to ask questions, seek support or provide information.
Please be advised of the following:
1. Office security
The College’s suite, on the 10th floor of 150 John St. in Toronto, is a secure location. It is protected by locking systems that require an access card or an escort to gain access.
Members of the profession and the public are welcome to come to the College. However, only individuals who have arranged a meeting with personnel at the College will be permitted to access the suite. Individuals who drop by unannounced and unplanned will be required to leave the premises and arrange an appointment.
Individuals who are dropping materials off at the College may do so in the unsecure section of the 10th floor by using the newly installed drop box. Only known and reputable courier companies will be permitted to access personnel for the purposes of signing for packages. Members are asked not to request signatures on materials being delivered to the College.
Violence, harassment and security breaches are more prevalent than ever in society. Securing our assets, our information, our systems and, most of all, our human resources is a critical responsibility for the College.
The measures we have taken are intended to protect you and your information, as well as the staff of the College from any real or potential harm.