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Statement of Information Practices

Privacy Policy and Statement of Information Practices

Frozen Shoulder Specialists is committed to protecting your personal information and personal health information responsibly, transparently, and in strict compliance with applicable Canadian privacy legislation, including PIPEDA and Ontario’s PHIPA.

PIPEDA & PHIPA Compliant
Current Practice Statement
Ontario, Canada
1

Our Commitment to Privacy

Frozen Shoulder Specialists (“Frozen Shoulder Specialists,” “we,” “us,” or “our”) respects your privacy and is committed to handling personal information and personal health information responsibly and in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and, where applicable, Ontario’s Personal Health Information Protection Act, 2004 (“PHIPA”).

This policy explains how we collect, use, disclose, protect, and retain information obtained through our website, assessment process, communications, and services.

Depending on the service involved, physicians, surgeons, anesthesiologists, imaging providers, facilities, and other regulated healthcare professionals may act as separate health information custodians and may provide their own privacy notices.

2

Information We Collect

We collect personal information and personal health information only to the extent reasonably required to evaluate your situation, coordinate care, operate our digital services, and fulfill clinical and administrative obligations:

Submitted Through Our Website

When you request an assessment, contact us, or subscribe to our newsletter, we may collect:

  • Your full name, email address, and telephone number
  • Preferred method of contact (phone, email)
  • The affected shoulder (left, right, or bilateral)
  • Approximate date your symptoms began
  • Whether you have been formally diagnosed with frozen shoulder
  • Voluntary clinical details regarding symptoms, medical history, imaging, previous treatments, or current condition
  • Newsletter and communication preferences

Assessment & Healthcare Information

If you proceed with an assessment or treatment, we may collect additional information reasonably required to evaluate your circumstances and support your care:

  • Detailed medical history, diagnoses, and imaging reports (X-rays, MRI, Ultrasound)
  • Range-of-motion measurements and physical findings
  • Current medications and prior treatment history (physiotherapy, injections, hydrodilatation)
  • Physician referrals, formal consent documentation, and recovery logs

Technical & Website Information

Certain technical information is collected automatically when you visit:

  • Internet Protocol (IP) address and approximate geographic location
  • Browser type, version, device model, and operating system
  • Pages viewed, scroll depth, time spent, and referral paths
  • Cookie and device identifiers for analytics and interaction tracking

Administrative Information

If you arrange an assessment or treatment, we may also collect:

  • Billing details, payment records, and invoices
  • Appointment scheduling and attendance logs
  • Out-of-town travel coordination and itinerary details
  • Insurance support and policy documentation requested by you
3

How We Use Information

We use personal information and personal health information strictly for legitimate clinical, educational, and operational purposes:

  • Responding to your inquiries and online assessment requests;
  • Contacting you via your preferred communication method (phone or email);
  • Reviewing your symptoms, medical history, and clinical suitability for focused assessment;
  • Arranging physician-led assessments, consultations, procedures, imaging, facility access, and follow-up care;
  • Coordinating multidisciplinary care among authorized healthcare professionals and facility partners;
  • Providing patient instructions, educational resources, and recovery support;
  • Scheduling appointments and facilitating out-of-town patient travel arrangements;
  • Processing payments, issuing itemized receipts, and maintaining administrative records;
  • Sending newsletters or informative communications where you have given explicit consent;
  • Measuring website performance, diagnosing technical issues, and evaluating marketing reach;
  • Maintaining website security, safeguarding systems, and preventing fraudulent misuse; and
  • Meeting regulatory, legal, insurance, professional college, and accounting standards.

Important Clinical Notice

Submitting an online assessment request does not establish a physician-patient relationship and does not guarantee that any particular treatment (such as Advanced Capsular Mobilization) will be recommended. A formal relationship is established only upon physician consultation and clinical examination.

4

Consent

We obtain consent in a manner appropriate to the sensitivity of the information and the reason it is being collected, used, or disclosed.

By submitting an assessment form, you consent to our collection and use of the information you provide for the purpose of responding to your inquiry, reviewing potential next steps, and contacting you using your selected contact method.

Where information is required for an assessment, treatment, legal obligation, or patient-safety purpose, withdrawing consent may limit our ability to provide or coordinate services.

Consent to receive newsletters or promotional communications is entirely optional and is never a condition of receiving an assessment or healthcare service. You may unsubscribe at any time using the link provided in any email or by contacting our office.

5

Cookies, Analytics, Advertising, and Embedded Content

Our website may use cookies and similar technologies necessary for site operation, performance monitoring, analytics, advertising measurement, and saving visitor preferences.

We may use trusted services such as Google Analytics and Google Ads to understand how visitors find and interact with our website and to measure advertising performance. These services may receive technical data such as your IP address, browser or device attributes, referral URLs, pages viewed, cookie identifiers, and conversion events.

Health Information Privacy Safeguard

We do not intentionally provide the contents of assessment forms or identifiable personal health information to advertising or analytics platforms, and we do not use personal health information to create personalized advertising audiences.

Our website may contain embedded content from third parties, including YouTube videos. When embedded content loads or is played, the third-party provider may receive technical information about your device and interaction in accordance with its own privacy policies.

You can control cookies through your browser settings or on-site cookie controls. Disabling certain cookies may impact specific website features.

Google Privacy Controls & Information:

6

When We Share Information

We may disclose information when reasonably necessary to:

  • Authorized Staff: Authorized employees and contractors who require access to perform clinical coordination and administrative duties;
  • Care Providers: Physicians, orthopedic surgeons, anesthesiologists, rehabilitation providers, diagnostic imaging centers, surgical suites, and other healthcare practitioners involved in your assessment or care;
  • Technology Vendors: Trusted service providers assisting with secure website hosting, encrypted form processing, clinical communications, appointment scheduling, billing, and technical analytics;
  • Professional Advisers: Accountants, legal counsel, auditors, and professional liability insurers bound by strict confidentiality;
  • Legal & Regulatory Authorities: Government, regulatory, or law enforcement bodies when specifically required or permitted under Canadian law;
  • Business Reorganization: A successor entity in connection with a corporate reorganization, financing, or transfer, subject to strict statutory confidentiality protections; or
  • Your Authorized Representatives: Another person or organization with your explicit written consent.

Service providers are authorized to handle information only as necessary to perform contracted services or as otherwise permitted by law.

We do not sell or rent personal information or patient health data for monetary consideration.
7

Healthcare Professionals and Facilities

Regulated healthcare professionals and treatment facilities involved in your assessment or care may maintain separate clinical records and may be independently responsible for those records under Ontario’s PHIPA or other applicable legislation.

We may exchange relevant clinical information with these professionals and facilities where you have consented, where the exchange is reasonably necessary to provide or coordinate healthcare, or where otherwise permitted or required by law.

Requests concerning records held by an independent physician, anesthesiologist, or surgical facility may need to be directed directly to that physician or facility.

8

Information Processed Outside Canada

Some service providers, including cloud technology, email servers, analytics, advertising, or embedded-content providers, may process or store information outside Canada, including within the United States.

When information is processed in another jurisdiction, it may be subject to the laws of that foreign jurisdiction and may become accessible to courts, governments, or law-enforcement authorities in accordance with those legal frameworks.

9

Safeguards

We use reasonable administrative, technical, contractual, and physical safeguards appropriate to the sensitivity of the information in our custody or control. These safeguards may include:

  • Role-based access controls and authentication protocols;
  • Secure encrypted transmission standards for web interactions;
  • Contractual confidentiality obligations with staff and third-party vendors; and
  • Ongoing training and defined procedures for incident prevention and response.

Electronic Transmission Limitations

No website, email transmission, or electronic storage method can ever be guaranteed to be 100% impenetrable. Please provide only the information requested through the website and do not use standard unencrypted email or general web forms to send detailed, unnecessary personal or financial records.

10

Retention and Disposal

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected and to meet applicable legal, regulatory, insurance, accounting, and professional record-retention obligations.

Clinical records are retained for minimum statutory periods mandated by applicable healthcare regulations and professional college standards (such as CPSO requirements).

When personal information is no longer required, we take reasonable steps to securely delete, destroy, or de-identify and anonymize it.

11

Access, Correction, and Other Privacy Choices

Subject to applicable legal exceptions, you hold the right to:

  • Access: Request access to personal information in our custody or control;
  • Correct: Request corrections to records that are inaccurate or incomplete;
  • Withdraw Consent: Withdraw consent to certain future uses or disclosures of your information;
  • Ask Questions: Seek clarification regarding our data management and storage practices;
  • Disclosure Records: Request details on relevant service providers or third-party disclosures; or
  • Submit Inquiries: File a formal privacy concern or complaint.

We may verify your identity prior to fulfilling access or correction requests. Requests may be restricted where information must be maintained for patient safety, professional liability, or statutory mandates.

You may unsubscribe from marketing or newsletter emails at any time. Doing so will not affect essential clinical, appointment, assessment, or transactional communications.

12

Privacy Concerns and Complaints

We encourage you to contact us first so that we can promptly review, address, and resolve any privacy concern or question.

If your inquiry is not resolved to your satisfaction, you may also have the right to contact relevant regulatory oversight bodies:

Office of the Privacy Commissioner of Canada

Responsible for compliance under the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Visit priv.gc.ca →

Information and Privacy Commissioner of Ontario

Oversees compliance under Ontario's Personal Health Information Protection Act, 2004 (PHIPA).

Visit ipc.on.ca →

13

Emergencies

Website is Not for Emergency Medical Care

The website, email addresses, and online forms are not emergency services and are not continuously monitored. Do not use this website to request urgent or emergency medical assistance. If you are experiencing severe sudden pain, numbness, signs of cardiovascular crisis, or any medical emergency, immediately call 911 or attend the nearest hospital emergency department.

14

Changes to This Policy

We may update this Privacy Policy and Statement of Information Practices from time to time to reflect modifications in our clinical operations, technology infrastructure, legal obligations, or administrative practices.

The current, operative version will always be posted on this website with its effective date displayed. We encourage patients and visitors to review this page periodically.

15

Contact Our Privacy Officer

Questions, formal access requests, correction submissions, withdrawals of consent, or privacy complaints should be directed to our Privacy Officer:

Privacy Officer — Frozen Shoulder Specialists

Guidance for Initial Privacy Inquiries

When contacting us by telephone or web inquiry, please ask specifically to be connected with the Privacy Officer.

Please do not include detailed medical diagnoses or sensitive personal health records in an initial voicemail or unencrypted email message.

Patient Guidance

Have Questions About Your Shoulder or Our Care?

Learn whether focused physician-led assessment and Advanced Capsular Mobilization are appropriate for your condition.

Start Your Free Clinical Assessment

Explore ACM, a non-surgical frozen shoulder treatment option. Begin with a free video assessment. Submitting this form does not commit you to treatment.