Privacy Policy

Effective Date: November 9, 2022

Capitol Physiotherapy is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with our physiotherapy services, website, electronic medical record systems, and communications.

Capitol Physiotherapy operates in British Columbia and is subject to applicable privacy and professional requirements, including the Personal Information Protection Act (BC) (“PIPA”), applicable provisions of the Health Professions and Occupations Act (BC) (“HPOA”), and, where applicable to our services as a WorkSafeBC service provider, the Freedom of Information and Protection of Privacy Act (BC) (“FIPPA”).

Where we provide services to WorkSafeBC claimants, we also comply with the privacy, security, and information-handling requirements applicable to WorkSafeBC service providers.

1. What Is Personal Information?

Personal information means information about an identifiable individual.

For our patients, this may include:

  • Name, address, telephone number, and email address

  • Date of birth and demographic information

  • Health and medical history

  • Information about injuries, illnesses, symptoms, and functional limitations

  • Assessment findings, diagnoses, treatment plans, and treatment records

  • Information relating to referrals and other health-care providers

  • Appointment and attendance information

  • Billing and payment information

  • Insurance information

  • Workers' compensation information, including WorkSafeBC claim information

  • Information provided in connection with communications with our clinic

  • Information contained in electronic medical records

  • Any other information reasonably necessary to provide physiotherapy services

2. Collection of Personal Information

We collect personal information only for purposes that are reasonable and appropriate for operating our clinic and providing physiotherapy and related services.

We may collect information:

  • Directly from patients or their authorized representatives

  • From referring physicians or other health-care providers

  • From insurers, employers, or other authorized parties

  • From WorkSafeBC where authorized or required

  • Through our online booking and patient-management systems

  • Through telephone, email, text message, or other communications

  • Through our website

  • Through payment and billing systems

  • From other sources where permitted or required by law

We generally collect personal information directly from the individual to whom it relates. Where information is collected from another source, we do so only where permitted or required by law or where necessary to provide care and administer services.

3. Purposes for Collecting, Using, and Disclosing Personal Information

We collect, use, and disclose personal information for purposes including:

  • Providing physiotherapy assessment, treatment, rehabilitation, and follow-up care

  • Establishing and maintaining patient records

  • Communicating with patients about their care and appointments

  • Coordinating care with other health-care professionals

  • Processing payments and billing

  • Submitting claims and documentation to insurers and other authorized organizations

  • Administering WorkSafeBC claims where applicable

  • Submitting required WorkSafeBC reports and invoices

  • Managing referrals and authorizations

  • Scheduling appointments

  • Maintaining and improving clinic operations

  • Meeting professional, legal, regulatory, and record-retention requirements

  • Responding to inquiries and complaints

  • Preventing, detecting, or investigating security incidents or other unlawful activity

  • Fulfilling contractual obligations

  • Meeting requirements imposed by public bodies or other authorized organizations

  • Any other purpose permitted or required by applicable law

We do not sell patient personal information for commercial purposes.

4. Consent

Where required by law, we obtain consent before collecting, using, or disclosing personal information.

Consent may be express or implied, depending on the circumstances and applicable law.

By providing personal information to Capitol Physiotherapy and requesting or receiving physiotherapy services, individuals may reasonably expect that we will use their information for purposes directly related to providing and administering those services.

Patients may withdraw consent in circumstances where withdrawal is legally permitted. Withdrawal of consent may affect our ability to provide certain services or fulfill legal, professional, insurance, or contractual requirements.

Where information is collected, used, or disclosed without consent because this is authorized or required by law, we will comply with the applicable legal requirements.

5. FIPPA and WorkSafeBC

When Capitol Physiotherapy provides services to WorkSafeBC or otherwise acts as a service provider to a British Columbia public body, additional privacy and security requirements may apply under FIPPA and our agreement with WorkSafeBC.

WorkSafeBC claimant information will be handled in accordance with applicable WorkSafeBC contractual requirements and privacy and security obligations.

For WorkSafeBC patients:

  • Clinical records will be maintained in our designated electronic medical record system, Jane App.

  • WorkSafeBC clinical reports and other required claimant documentation will be submitted through WorkSafeBC's approved secure Provider Portal, My Provider Services, or document-uploader systems, as applicable.

  • We will not routinely transmit detailed clinical information or WorkSafeBC claimant records through ordinary email.

  • We will not use Jane App SMS appointment reminders for WorkSafeBC patients.

  • We will limit access to WorkSafeBC claimant information to authorized individuals who require access for their duties.

  • We will not intentionally store WorkSafeBC claimant records in personal cloud-storage accounts, personal email accounts, USB drives, or other unauthorized storage locations.

  • We will use reasonable administrative, technical, and physical safeguards to protect WorkSafeBC claimant information from unauthorized access, use, disclosure, loss, or destruction.

Where WorkSafeBC requirements impose more stringent privacy or security obligations than those ordinarily applicable to our private-sector operations, Capitol Physiotherapy will comply with the applicable WorkSafeBC requirements.

6. Minimum Necessary Disclosure

Capitol Physiotherapy seeks to limit the collection, use, and disclosure of personal information to information that is reasonably necessary for the applicable purpose.

In particular, when communicating with third parties, including insurers, employers, other health-care providers, and WorkSafeBC, we seek to provide only the information reasonably required for the purpose of the communication.

For WorkSafeBC patients, detailed clinical reporting will be submitted through WorkSafeBC's designated secure reporting systems rather than through ordinary email.

7. Disclosure of Personal Information

We may disclose personal information where reasonably necessary and permitted or required by law, including to:

  • Physicians and other health-care professionals involved in a patient's care

  • Referring practitioners

  • Insurers and extended health benefit providers

  • WorkSafeBC and authorized WorkSafeBC representatives

  • Employers where authorized and appropriate

  • Legal, regulatory, or governmental authorities where required or permitted by law

  • Service providers who assist us in operating our clinic

  • Payment processors and financial institutions

  • Professional advisors, where reasonably necessary

  • Other parties where the patient has provided appropriate consent

We do not disclose personal information for unrelated marketing purposes without appropriate consent.

8. Electronic Medical Records — Jane App

Capitol Physiotherapy uses Jane App as its electronic medical record and practice-management platform.

Jane is used for functions including:

  • Patient registration

  • Appointment scheduling

  • Clinical documentation

  • Treatment records

  • Billing and payment administration

  • Patient communications

  • Record management

Our Canadian Jane account uses Jane's Canadian data-storage environment for core Jane Data. Jane currently identifies Canadian Jane Data storage locations in Montreal, Quebec and Calgary, Alberta.

Jane states that its core data is encrypted in transit and at rest and provides individual user accounts, access controls, activity monitoring, and optional or clinic-enforced two-step verification.

Capitol Physiotherapy controls the personal information contained in our Jane account and is responsible for determining how that information is collected, used, accessed, retained, and disclosed.

Some optional Jane features and integrated services may have different processing or storage arrangements. We configure our systems with applicable privacy and contractual requirements in mind.

WorkSafeBC Patients and Jane SMS

Jane's SMS and certain secure messaging functions use third-party service providers that may process information in the United States.

Because WorkSafeBC claimant information is subject to additional privacy and information-storage requirements, Capitol Physiotherapy will not use Jane App SMS appointment reminders for WorkSafeBC patients.

WorkSafeBC patients will instead receive appointment reminders through other appropriate communication methods selected by the clinic.

This restriction applies specifically to WorkSafeBC patients and does not prevent Capitol Physiotherapy from using Jane's communication features for other patients where appropriate and permitted by applicable privacy requirements.

9. Service Providers and Cloud Technology

Capitol Physiotherapy uses selected third-party technology and service providers to operate the clinic and provide services.

These may include:

  • Jane App

  • Google Workspace / Gmail

  • Jane Payments and its payment-processing partners

  • Squarespace

  • WorkSafeBC online services and Provider Portal systems

  • Other vendors reasonably necessary to operate the clinic

We take reasonable steps to ensure that service providers handling personal information provide appropriate privacy and security safeguards.

We do not authorize service providers to use patient personal information for their own unrelated marketing purposes.

Where a service provider processes information outside Canada, we consider the applicable privacy, contractual, professional, and regulatory requirements before using that service for personal information.

10. Storage and Processing of Personal Information in Canada

Capitol Physiotherapy's primary electronic medical record is maintained through our Canadian Jane account.

We do not intentionally store patient clinical records or WorkSafeBC claimant records in personal cloud-storage services or unauthorized systems outside our approved clinic technology environment.

We do not use Dropbox or Google Drive to store patient clinical records.

Certain third-party services may process limited information outside Canada depending on the service and functionality being used. For example, Jane's current documentation identifies US-based processing for certain communication features.

For WorkSafeBC patients, we configure our processes to avoid using Jane SMS appointment reminders and use WorkSafeBC's designated secure systems for clinical reporting.

11. Website Privacy and Cookies

Our website is hosted using Squarespace.

When you visit our website, certain technical information may be collected automatically, such as:

  • IP address

  • Browser and device information

  • Pages viewed

  • Date and time of access

  • General website usage information

  • Technical information required for website security and operation

We may use this information to operate, maintain, secure, and improve our website.

Capitol Physiotherapy does not use third-party advertising tracking or advertising pixels to build advertising profiles of website visitors.

We do not use Google Ads, Meta Pixel, or similar advertising-tracking technologies on our website unless this Privacy Policy is updated to disclose such use.

Website Contact Forms

If you contact us through a website form, please provide only the information reasonably necessary for us to respond.

Please do not submit detailed medical, clinical, WorkSafeBC claim, or other highly sensitive health information through a general website contact form.

If detailed clinical information is required, we will direct you to an appropriate communication or information-submission method.

Squarespace may process website visitor information as part of providing website-hosting and related services.

12. Email, Text Messaging, and Electronic Communications

Capitol Physiotherapy uses Google Workspace / Gmail for clinic email.

We use email for ordinary administrative and clinic communications, including scheduling, inquiries, and other communications where appropriate.

We recognize that email is not appropriate for every type of sensitive information.

WorkSafeBC Email Policy

For WorkSafeBC patients, Capitol Physiotherapy will not routinely send detailed clinical information, treatment reports, or WorkSafeBC claimant records through ordinary email.

Instead:

  • Clinical reports will be submitted through WorkSafeBC's secure Provider Portal, My Provider Services, or designated document-uploader system, as applicable.

  • Detailed claimant information will remain within approved clinic systems or WorkSafeBC's secure submission systems.

  • Gmail may be used for general administrative or program-related communications where those communications do not contain unnecessary WorkSafeBC personal or clinical information.

  • Where an email containing WorkSafeBC personal information is necessary and permitted, Capitol Physiotherapy will use an appropriate secure/encrypted method consistent with applicable WorkSafeBC requirements.

Appointment Reminders

For patients who are not receiving services under a WorkSafeBC claim, Capitol Physiotherapy may use appointment reminders through available clinic communication systems, including Jane App, where appropriate.

For WorkSafeBC patients, Capitol Physiotherapy will not use Jane App SMS appointment reminders.

Other appropriate reminder methods may be used instead.

13. Privacy Breaches and Security Incidents

Capitol Physiotherapy takes reasonable measures to protect personal information against:

  • Unauthorized access

  • Unauthorized use

  • Unauthorized disclosure

  • Theft

  • Loss

  • Alteration

  • Destruction

Security measures may include:

  • Individual user accounts

  • Strong passwords

  • Two-step verification where available

  • Role-based access controls

  • Secure cloud platforms

  • Encryption

  • Physical safeguards

  • Staff privacy training

  • Activity monitoring

  • Regular review of access permissions

If we become aware of a privacy breach or suspected privacy incident, we will assess the incident and take reasonable steps to contain, investigate, and address it.

Where required by law, professional obligations, contractual requirements, or the circumstances of the incident, we will notify affected individuals, WorkSafeBC, regulators, or other appropriate parties.

14. Retention of Records

Capitol Physiotherapy retains patient records for the periods required by applicable law, professional standards, regulatory requirements, contractual obligations, and legitimate business needs.

For patients who were 19 years of age or older when first seen, clinical records are generally retained for at least 16 years after the patient's last visit, subject to applicable professional requirements.

For patients who were under 19 years of age when first seen, records are generally retained until the patient reaches 35 years of age, subject to applicable professional requirements.

WorkSafeBC records and information may also be subject to WorkSafeBC-specific retention and record-management requirements.

We securely dispose of personal information when it is no longer required to be retained.

15. Access to Personal Information

Individuals may request access to personal information held by Capitol Physiotherapy, subject to applicable legal exceptions.

Requests should be made in writing to our Privacy Officer.

We will generally:

  1. Confirm receipt of the request.

  2. Identify the information reasonably responsive to the request.

  3. Review the information for applicable legal restrictions.

  4. Provide access where required or permitted.

  5. Explain any information that cannot be provided where legally appropriate.

We may require sufficient information to verify the identity of the person making the request.

16. Correction of Personal Information

Individuals may request correction of inaccurate or incomplete personal information held by Capitol Physiotherapy.

If information is found to be inaccurate or incomplete, we will take reasonable steps to correct it where appropriate.

Requests for correction should be directed to our Privacy Officer.

Where appropriate, we may also notify relevant third parties of a correction.

17. Privacy Officer

Capitol Physiotherapy has designated a Privacy Officer responsible for overseeing our privacy practices and responding to privacy-related questions and requests.

Privacy Officer: Alexi A Bergeron

Mailing Address: 851 Yates St, Victoria BC V8W 1M1

Email: alexi@capitolphysio.com

Telephone: 778-378-7087

18. Privacy Complaints

If you have a question or concern about how Capitol Physiotherapy has handled your personal information, we encourage you to contact our Privacy Officer first.

We will investigate privacy complaints and respond within a reasonable period.

If you remain dissatisfied, you may have the right to contact the applicable privacy oversight body, including the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC), depending on the circumstances and legislation applicable to your complaint.

19. Professional Obligations

Capitol Physiotherapy and its physiotherapists are subject to professional, ethical, privacy, and record-management requirements established by applicable legislation and the regulatory body governing physiotherapy practice in British Columbia, the College of Health and Care Professionals of BC.

Our privacy practices are intended to operate consistently with these professional obligations.

Where professional, legal, regulatory, WorkSafeBC, or contractual requirements impose specific obligations regarding personal information, those requirements will be followed.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • Changes in legislation

  • Regulatory requirements

  • Changes to our services

  • Changes to our technology systems

  • Changes to our privacy practices

  • Changes to WorkSafeBC requirements

  • Other operational or legal developments

The current version of this Privacy Policy will be made available on our website.

21. Contact Us

If you have questions about this Privacy Policy or how Capitol Physiotherapy handles personal information, please contact our Privacy Officer:

Capitol Physiotherapy
Privacy Officer: Alexi A Bergeron
Address: 851 Yates St, Victoria BC V8W 1M1
Email: alexi@capitolphysio.com
Phone: 778-378-7087

Effective Date: November 9, 2022

Last Updated: September 17, 2026