Privacy Policy

Privacy of personal information is an important principle to JM Nutrition. The trust placed in us by our clients is absolutely essential to our success. We understand that and do all we can to earn and protect that trust.

We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We are open and transparent about how we handle personal information. This document 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, nutritional or mental health of the individual (including family health history); 
  • the provision of health care to the individual;
  • payments or eligibility for health care or coverage for health care


Our Organization: JM Nutrition

We use a number of support workers and consultants that may, in the course of their duties, have limited access to personal health information we hold. These include but are not limited to computer consultants, office security and maintenance, bookkeepers and accountants, lawyers, contractors, credit card companies, website managers and custodial staff. 

We restrict their access to any personal information we hold. All your personal health information is private, confidential and secure. We also have their assurance that the support workers and consultants follow appropriate privacy principles.


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 nutritional counselling service. 

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 nutrition care needs are, to advise them of their options and then to provide the nutrition 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 other purposes.

The most common examples of these purposes are as follows:

  • To provide you with care and assistance based on your needs
  • To make sure your service providers have the most up-to-date and complete record of your health history and needs
  • To help us see where there might be gaps or overlaps so we can ensure you are getting the proper support and services
  • For general administration and management of our programs and services
  • To comply with our regulatory obligations to The College of Dietitians of Ontario
  • To obtain payment for services provided
  • To advise clients about special events or opportunities (e.g., email newsletter)


Protecting Personal Information 

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

  •  Paper information is either under supervision or secured in a locked or restricted area. 
  •  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.
  • Personal health information is only stored on mobile devices if necessary. All personal health information stored on mobile devices is protected by strong encryption. 
  • We try to avoid taking personal health information home to work on there. However, when we do so, we transport, use and store the personal health information securely. 
  • Paper information is transferred through sealed, addressed envelopes or boxes by reputable companies with strong privacy policies. 
  • 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.


Openness About the Personal Information Process 

The organization must make its personal information Privacy Policy available to the public. Individuals must be able to obtain and understand this Privacy Policy without unreasonable effort. 

  1. Staff are trained to provide the Privacy Policy document to anyone who requests it. 
  2. The Privacy Policy document will be accessible and visible at our place of business. 
  3. The Privacy Policy will be posted on our organization’s website, where applicable. 


Right to Access Personal Information

Individuals have the right (with some exceptions) to access personal information about themselves held by the organization and to know what the organization has done with it. This ensures that the personal information is adequate, correct and up to date. 


Correction Requests 

Clients have the right to request a correction of erroneous information held by the organization. The purpose is to maintain appropriate and accurate information on clients.


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 or from the date the client turns 18. 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. When hardware is discarded, we ensure that the hardware is physically destroyed or the data is erased or overwritten in a manner that the information cannot be recovered.


Complaints System 

The organization develops and maintains an internal complaint system and makes external recourse publicly available in order to be able to receive, investigate and respond to complaints. Every effort is made to investigate and decide a simple complaint within 30 days. For more complex complaints, the person investigating or deciding the complaint will advise the person making the complaint within 30 days of how long it will likely take to investigate and decide it.

While we will take 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, as applicable:

Step 1: Respond immediately by implementing the organization’s privacy breach protocol. 

Step 2: Containment: Identify the scope of the potential breach and take steps to contain it. 

Step 3: Notification: Identify those individuals whose privacy was breached and notify them of the breach. 

Step 4: Investigation and Remediation 

Depending on the circumstances of the breach, we may notify and work with the Information and Privacy Commissioner of Ontario. If we take disciplinary action against one of our practitioners (or revoke or restrict the privileges or affiliation of one of our practitioners) for a privacy breach, we are required to report that to the practitioner’s regulatory College. 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.