Privacy Policy

Purpose

Audiology and Speech-Language Pathology are regulated professions in Ontario under the Regulated Health Professions Act, 1991 (RHPA) and the Audiology and Speech-Language Pathology Act (ASLPA). It is the responsibility of the College of Audiologists and Speech-Language Pathologists of Ontario (CASLPO) to regulate audiologists and speech-language pathologists in the public’s interest.

CASLPO takes full responsibility for the protection of information it collects. 

CASLPO has a Privacy Officer who is responsible for ensuring compliance with privacy obligations, including this Privacy Policy, with respect to the collection, use, disclosure and handling of personal information by CASLPO representatives (including staff, contractors and authorized agents). Grace Maharaj (she/her) is CASLPO’s Privacy Officer. Complaints or questions regarding privacy or confidentiality should be directed to her at [email protected].

The Privacy Officer’s duties include: 

• Developing and reviewing internal procedures to protect information;
• Ensuring all staff are trained on privacy practices and are aware of the importance of safeguarding any personal information that they are privy to;
• Providing training to the Board of Directors from time to time regarding the importance of maintaining confidentiality with respect to Committee materials; and
• Ensuring all inquiries and complaints relating to privacy are addressed in a timely manner

Information and Collection Process

The policy applies to personal information, which is any factual or subjective information, recorded or not, about an identifiable individual. This can include, but is not limited to, a person’s name, contact information, birth date, educational background, health card number, personal health information (PHI), work history or financial data. 

The purposes for which personal information is collected shall be identified by CASLPO at or before the time the information is collected.

CASLPO collects personal information in several ways, for example: 

• The public: when a person informs CASLPO of concerns about a registrant’s practice or submits a formal complaint; and
• Registrants and applicants: through application and renewal forms for registration with CASLPO, participation in the Quality Assurance Program, and through the investigative process. 

There are instances where CASLPO has the legal authority to obtain records and collect, use, and disclose personal information. In certain circumstances, disclosure may occur without consent¹. The circumstances in which this may occur are outlined later in this policy.

General Use of Information

To fulfill our mandate and duties under the RHPA, CASLPO uses personal information in several ways. For example²: 

• To maintain the public register: available to the public at CASLPO Public Register; 
• To assess eligibility for registration, license renewal or reinstatement³; 
  • Canadian Entry-to-Practice Exam 
    • CASLPO shall provide Speech-Language & Audiology Canada with the names of eligible applicants where required
• To assess registrants’ entry to practice competence through CASLPO’s Mentorship Program⁴; 
• To assess registrants’ continued competence through CASLPO’s Quality Assurance Program including⁵; 
  • Peer Assessments
    • Personal information, including PHI such as patient records, provided by the registrant in a peer assessment will be shared with the peer assessor and CASLPO;
    • Results of a peer assessment are shared with the registrant and the peer assessor; and
    • Registrants may disclose the peer assessment results to their employers.
  • Self-Assessment Tool (SAT)
    • Registrants may choose to upload PHI, such as patient records, to their SAT
• To administer the Sexual Abuse Prevention Program established by CASLPO and to provide funding for therapy and counselling for persons who, while patients, were sexually abused by registrants of CASLPO⁶;
• To inform registrants and the public about CASLPO initiatives or important updates, including the collection of demographic data (which is anonymized and collected in aggregate); 
• For data analytics and to compile aggregate statistics for internal reporting purposes; and
• To meet auditing, legal, and regulatory processes and requirements.

Sharing Information

CASLPO does not sell, rent or lease its registrant lists to third parties. 

In limited circumstances, CASLPO may share personal information with trusted partners to fulfil regulatory requirements. This is done to help CASLPO provide a service, send you emails or postal mail, provide support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to CASLPO, and they are required to maintain the confidentiality of your personal information. CASLPO takes reasonable steps to ensure that any third-party service providers entrusted with personal information are reputable and have safeguards in place to protect this information.

CASLPO does not use or disclose sensitive personal information, such as race or religion, without an individual’s explicit consent.

CASLPO takes all reasonable steps to protect the interests of the registrant and the public when disclosing personal information. 

Sharing Information under section 36 of the RHPA⁷  

While there is a general obligation to maintain the confidentiality of information that CASLPO has collected, there are circumstances in which information can be shared without notice or consent as may be required by law or in the good faith belief that such action is required. For example, section 36(1) of the RHPA sets out a list of exceptions to the College’s confidentiality obligations. These include: 

• Sharing information that is made available to the public by the RHPA (e.g. names of registrants who have been referred to the Discipline Committee)
• To a body that governs a profession inside or outside of Ontario (e.g. sending a Verification of Registration to other regulatory body upon request)
• To a public hospital or another party, where CASLPO is investigating the conduct of a registrant
• To a police officer to aid an investigation where there is a possibility of a formal legal proceeding
• To confirm whether CASLPO is investigating a registrant, if there is a compelling public interest in the disclosure of that information
• If there are reasonable grounds to believe that the disclosure is necessary for the purpose of eliminating or reducing a significant risk of serious bodily harm to a person or group of persons
• With the written consent of the person to whom the information relates

For a complete list of exceptions, please refer to section 36 of the RHPA.

CASLPO may disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is legally required 

Sharing or Collecting Information During Investigation 

CASLPO may collect personal information regarding a complainant or patients, such as patient records, from parties such as registrants, employers and medical facilities during an investigation and in keeping with legislative requirements⁸.

CASLPO may be required to share personal information, such as patient records, with registrants during an investigation and in keeping with legislative requirements⁹. 

Website Use

CASLPO utilizes Google Analytics to monitor website usage. This data helps us identify the most popular pages and topics, allowing us to tailor content and advertising within CASLPO to visitors whose browsing behavior suggests interest in specific subject areas. All information collected is anonymous and does not include any personally identifiable details about our visitors.

Use of Cookies

CASLPO’s website uses "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize CASLPO pages, or register with CASLPO site or services, a cookie helps CASLPO to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses or shipping addresses. When you return to the same CASLPO website, the information you previously provided can be retrieved, so you can easily use the CASLPO features that you customized.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the CASLPO services or websites you visit.

Linking to Other Websites

Each website has its own online privacy policy. If you access other sites through links on CASLPO’s web pages, please be aware that CASLPO’s privacy policy does not apply to other sites. CASLPO encourages you to review the privacy policies of websites you choose to link to from CASLPO so that you can understand how those websites collect, use and share your information. CASLPO is not responsible for the privacy policy or other content on websites outside of the CASLPO website.

Keeping Your Information Safe

CASLPO has implemented physical, organizational, and technical security measures to guard against unauthorized or unlawful access to the personal information we manage and store. CASLPO has taken steps to avoid accidental loss, destruction of, or damage to personal information. While no system is completely secure, the measures implemented by CASLPO significantly reduce the likelihood of a personal information breach.

To keep information safe, CASLPO has in place:

• Secure office premises with key card;
• CASLPO’s servers are hosted, so no staff can access the physical servers;
• Use of VPN and Multi-Factor Authentication (MFA);
• Use of secure filing sharing services (MFA protected);
• The use of encryption for sensitive documents; 
• Comprehensive infrastructure monitoring and security solutions, integrating both hardware and software, to ensure secure access and usage; and
• CASLPO conducts cyber security training with Board and staff regarding:
  • Data usage and protection;
  • Online account protection;
  • Authentication methods;
  • Other areas of online safety, including Phishing awareness.

CASLPO is not liable for any unauthorized access to personal information that is beyond our reasonable control.

Retaining Your Information

CASLPO retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with our retention policies. Once your information is no longer required by CASLPO to meet legal or regulatory requirements, it is securely destroyed, erased or made anonymous. Keep in mind however that information may be retained for a lengthier period of time due to an on-going investigation or legal proceeding, and that residual information may remain in back-ups for a period of time after its destruction date. 

Changes to this Statement

CASLPO will from time to time update this policy as may be required by law or based on circumstances or occurrences. CASLPO encourages you to periodically review this Privacy Policy to be informed of how CASLPO is protecting your information.

Contact Information

CASLPO welcomes comments regarding the Privacy Policy. If you believe that CASLPO has not adhered to the Privacy Policy, please contact the Privacy Officer at [email protected]. CASLPO will use reasonable efforts to promptly address your concerns.

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References

1. Regulated Health Professions Act, SO 1991, c 18, s 36(1) [RHPA]
2. RHPA, supra note 1.
3. NOTE: An applicant can request a review of the Registration Committee’s decision. CASLPO must disclose a copy of the order and reasons of the Registration Committee and the documents upon which the decision was based.
4. O. Reg 21/12 under the Audiology and Speech-Language Pathology Act, 1991
5. O. Reg 373/12 under the Audiology and Speech-Language Pathology Act, 1991
6. Sexual Abuse Prevention Program
7. RHPA, supranote 1.
8. Section 76 of the Health Professions Procedural Code (being Schedule 2 of the RHPA)
9. Section 25(6) of the Health Professions Procedural Code (being Schedule 2 of the RHPA)