Privacy Policy — Atlas North Rehabilitation Services
Effective date: September 4, 2026 Last updated: September 4, 2026
This policy explains how Atlas North Rehabilitation Services ("Atlas North," "I," "me," or "my") collects, uses, discloses, and protects personal information, including personal health information, in connection with my occupational therapy practice and this website (atlasnorthrehab.ca).
This policy has two parts, because two different laws apply depending on the type of information involved:
Part A covers personal health information about clients/patients, governed by Ontario's Personal Health Information Protection Act, 2004 (PHIPA).
Part B covers general business and website information — such as information from referral sources, visitors, and organizations — governed by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).
Who I Am
Atlas North Rehabilitation Services is a sole-practitioner occupational therapy practice operated by Aiden Huynh, OT Reg. (Ont.), providing community-based and mobile occupational therapy services across Southwestern Ontario.
For the purposes of this policy, and under PHIPA, I act as a health information custodian with respect to personal health information collected in the course of providing occupational therapy services. For general business and website information, I act as an organization under PIPEDA.
Privacy contact: Aiden Huynh Email: Aiden@atlasnorthrehab.ca Phone: 519-804-9222
Important: This Website Is Not Where Clinical Information Is Handled
This website is a professional information portal for Atlas North Rehabilitation. It is not intended for the transmission or storage of personal health information (PHI) or sensitive clinical documentation, and the sections below explain why that distinction matters and how each type of information is actually handled.
1. Data Collection via Contact Forms The contact and referral forms on this website are designed to collect basic professional contact information only — for example, name, firm/organization, phone number, and email address. Please do not include sensitive clinical information, health card numbers, or details about a client's medical condition in these forms.
2. Website Hosting This website is hosted by Hostinger. Industry-standard security measures, including SSL encryption, protect data in transit, but this web hosting environment is not used to store clinical records. Web hosting servers may be located outside of Canada. By using the contact or referral form on this website, you acknowledge that the basic contact information submitted may be processed on servers located outside Canada, including potentially in the United States, depending on Hostinger's infrastructure.
3. Where Clinical Data Actually Goes Once a referral is received, all subsequent clinical documentation and communication involving personal health information is managed through Embodia, a secure clinical practice management system used for storing and managing client records. Embodia's data is stored on servers located in Canada.
4. Your Responsibility as a Referrer If you are a lawyer, adjuster, case manager, or other referral source, please do not submit personal health information through the website's contact or referral form. Once your referral is received, I will follow up directly to arrange a secure method for exchanging any clinical or file-specific information.
PART A — Personal Health Information (PHIPA)
This part applies to information collected about clients referred to or receiving occupational therapy services from Atlas North, and is managed through Embodia rather than this website.
1. What Personal Health Information I Collect
Depending on the nature of the referral and services provided, this may include:
Contact and identifying information (name, date of birth, address, phone, email)
Referral details (referring party, reason for referral, relevant deadlines)
Health history and information relevant to the assessment or treatment, including injury details, functional status, and relevant medical, legal, or insurance file information provided as part of the referral
Assessment findings, clinical notes, and treatment records
Information exchanged with other involved parties (e.g., physicians, insurers, legal representatives, case managers) in the course of coordinating care or completing a referral
2. Why I Collect, Use, and Disclose This Information
Personal health information is collected, used, and disclosed only for purposes related to providing occupational therapy services, including:
Conducting assessments and providing treatment
Preparing reports, clinical letters, and documentation requested as part of a referral (e.g., Form 1, CAT assessments, GOS-E, medico-legal reports)
Communicating with other health care providers involved in a client's care
Communicating with the referring party (lawyer, insurer, case manager, physician, or other referral source) about the file, as required to fulfill the referral
Billing and administrative purposes related to the services provided
Complying with legal, regulatory, and professional obligations, including those of the College of Occupational Therapists of Ontario (COTO)
3. Consent
Consent to collect, use, and disclose personal health information for the purpose of providing care is generally implied when a client (or their substitute decision-maker) is referred for or receives services, consistent with PHIPA's provisions for implied consent among those involved in a client's circle of care.
Where personal health information is used or disclosed for a purpose not related to providing care (for example, disclosure to a party outside the client's circle of care), express consent will be obtained first, unless the disclosure is otherwise permitted or required by law.
Withdrawing or restricting consent: Clients have the right to withdraw consent, or to instruct that specific information not be shared with a particular person or organization (a "lock-box" instruction), subject to legal and professional limitations. Please contact me directly to discuss this. Note that restricting information relevant to a medico-legal or insurance-related referral may affect Atlas North's ability to complete that referral, and this will be discussed with you directly if it applies.
4. Disclosure Without Consent
In limited circumstances, PHIPA permits or requires disclosure of personal health information without consent — for example, where required by law (such as a court order or subpoena), where necessary to eliminate or reduce a significant risk of serious harm, or as otherwise permitted under PHIPA. Any such disclosure is limited to what is permitted or required in the circumstances.
5. Safeguards
Reasonable administrative, technical, and physical safeguards are used to protect personal health information against theft, loss, and unauthorized access, use, disclosure, copying, or modification, including:
Password-protected devices used to access client information
Encrypted storage of clinical records within Embodia
Two-factor authentication on clinical practice management accounts
Locked, secure storage for any physical/paper records
6. Where Information Is Stored
Clinical and assessment records are stored in Embodia, a clinical practice management system, on servers located in Canada.
7. Retention and Destruction
Clinical records are retained in accordance with the College of Occupational Therapists of Ontario's (COTO) record-keeping requirements: at least 10 years from the date of the last entry in the record, or, for a client who was a minor at the time of the record, until 10 years after the date they reached or would have reached 18 years of age — whichever is later. Records may be retained longer than this minimum where reasonably known to be required for a valid reason, such as a pending legal proceeding. When no longer required, records are securely destroyed.
8. Your Right to Access and Correct Your Records
Under PHIPA, clients (or their authorized substitute decision-maker) have the right to request access to their own personal health information held by Atlas North, and to request correction of that information if they believe it is inaccurate or incomplete. Requests can be made using the contact information above. A response will be provided within the timelines required by PHIPA. A reasonable fee may apply to access requests, as permitted under PHIPA.
9. Concerns or Complaints About Personal Health Information
If you have a concern about how your personal health information has been handled, please contact me directly first using the information above, so I can attempt to resolve it. You also have the right to file a complaint with Ontario's Information and Privacy Commissioner (IPC):
Information and Privacy Commissioner of Ontario 2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8 Phone: 416-326-3333 · Toll-free: 1-800-387-0073 · TTY: 416-325-7539 Email: info@ipc.on.ca · Website: www.ipc.on.ca
PART B — General Business & Website Information (PIPEDA)
This part applies to information from referral sources, general website visitors, and business contacts — information that is not personal health information about a client.
1. What This Includes
Information submitted through the referral or contact form on this website (e.g., name, organization, phone number, email address, and any message provided) by lawyers, adjusters, case managers, physicians, or other referral sources
General technical/device information automatically collected when visiting the site (e.g., browser type, general location/region, pages viewed, referring website)
Any information voluntarily provided by email or phone in the course of a professional inquiry
Important note for referral sources: please do not include sensitive clinical or health information about a specific client in the general contact form (see the note above on how clinical information is actually handled).
2. Why This Information Is Collected
To respond to inquiries and referral submissions
To coordinate and manage referrals from professional partners
To maintain and improve the functioning of the website
To meet legal and administrative recordkeeping obligations
3. Consent
By submitting information through the website's contact or referral form, you consent to its collection and use for the purposes described above. You may withdraw consent or request that your business contact information be removed from my records at any time by contacting me directly, subject to any legal or professional obligation to retain referral records.
4. Cookies and Website Analytics
This website uses Hostinger's built-in website analytics to understand general website usage, such as which pages are visited and general traffic patterns. This may involve cookies that collect non-identifying technical information about your visit. You can control or disable cookies through your browser settings; doing so may affect some website functionality.
5. Forms and Hosting
The contact and referral forms on this website use Hostinger's built-in form tool. This website is hosted by Hostinger. See the note above regarding where information submitted through these forms may be processed.
6. Disclosure to Third Parties
Business and website information is not sold. It is shared only with the service providers necessary to operate the website and referral process (Hostinger, for website hosting, form submissions, and analytics), solely for that purpose.
7. Retention
Business contact and referral-related information is retained only as long as reasonably necessary for the purposes described above, or as required by professional or legal obligations, after which it is securely deleted or destroyed.
8. Your Rights and How to Exercise Them
Under PIPEDA, you have the right to access the business/contact information held about you and to request correction if it is inaccurate. To make a request, contact me using the information above.
If you have an unresolved concern about how your general business or website information has been handled, you may also contact the Office of the Privacy Commissioner of Canada: 30 Victoria Street, Gatineau, QC K1A 1H3 Toll-free: 1-800-282-1376 · Website: priv.gc.ca
Security of Information (General)
No method of transmission over the internet or electronic storage is 100% secure. While reasonable safeguards are used to protect all information collected through this website and in the course of providing services, I cannot guarantee absolute security, and visitors and clients should be aware of this inherent limitation when transmitting information electronically.
Links to Other Websites
This website may contain links to third-party websites. I am not responsible for the privacy practices or content of those external sites, and encourage you to review their privacy policies separately.
Changes to This Policy
This Privacy Policy may be updated from time to time to reflect changes in practice, technology, or legal requirements. The "Last updated" date at the top of this page will reflect the most recent revision. Material changes will be reflected here before taking effect.
Contact
Questions about this Privacy Policy, or requests relating to your personal information, can be directed to:
Aiden Huynh Atlas North Rehabilitation Services Email: Aiden@atlasnorthrehab.ca Phone: 519-804-9222