Two Row Consulting is committed to respecting privacy, protecting confidential information, and maintaining the trust of the individuals, organizations, communities, and partners with whom we work.

​

We recognize the importance of protecting personal information and, where applicable, personal health information in accordance with Ontario’s Personal Health Information Protection Act, 2004 (PHIPA), and other applicable privacy legislation.

​

This statement describes our approach to protecting personal health information that may be collected, accessed, used, disclosed, or handled in connection with our consulting services.

Where personal health information is handled as part of our services, Two Row Consulting will limit the collection, use, and disclosure of that information to authorized and legitimate purposes, in accordance with applicable law and our contractual obligations.

We will take reasonable steps to ensure that:
 

• Personal health information is handled only for authorized purposes.

• Only the information reasonably necessary for the intended purpose is collected, accessed, or used.

• Information is disclosed only when authorized by the applicable individual, the relevant health information custodian, contractual arrangements, or applicable law.

• Confidential information is not used for unrelated purposes without proper authority.
   

Where Two Row Consulting provides services to a health information custodian, our responsibilities will depend on the nature of the services, the applicable agreements, and the requirements of PHIPA.

Where required by law, appropriate consent or other lawful authority will be obtained before personal health information is collected, used, or disclosed.
 

Individuals may have rights under applicable privacy legislation, including the right to:
 

• Understand how their personal health information is collected, used, and disclosed.

• Access their personal health information, subject to applicable exceptions.

• Request corrections to their personal health information, where permitted by law.

• Withdraw or withhold consent where applicable.

• Raise concerns or submit a privacy complaint.
   

Requests relating to personal health information held by a health information custodian may need to be directed to that custodian.

Two Row Consulting is committed to taking reasonable and appropriate measures to protect confidential information against unauthorized access, collection, use, disclosure, copying, modification, loss, theft, or disposal.
 

Safeguards may include administrative, physical, and technological measures appropriate to the nature and sensitivity of the information and the services being provided.
 

Access to confidential information will be limited to authorized individuals who require it for legitimate business or service-related purposes and who are subject to applicable confidentiality obligations.

Personal health information will not be disclosed to third parties except as authorized by applicable law, valid consent where required, or the relevant contractual and service arrangements.
 

Where third-party service providers are involved in handling confidential information, appropriate measures will be considered to protect that information and support compliance with applicable privacy obligations.

Personal health information and other confidential records will be retained only as permitted or required by applicable law, contractual obligations, and legitimate business or service requirements.
 

When information is no longer required and may lawfully be disposed of, reasonable measures will be taken to ensure its secure destruction or disposal.

Two Row Consulting takes privacy concerns seriously. Any suspected unauthorized access, use, disclosure, loss, or theft of personal health information should be reported promptly to our designated privacy contact.
 

Where required by applicable law or contractual obligations, appropriate steps will be taken to assess, address, document, and report a privacy incident and provide notifications to affected individuals or relevant authorities.

Visitors to www.tworowconsulting.com should avoid submitting personal health information through general website contact forms or ordinary email unless a suitable and authorized process has been established.
 

Information submitted through the website may be used to respond to inquiries, communicate with prospective or existing clients, and provide requested information or services, in accordance with our applicable privacy practices.
 

Website visitors should review any separate website Privacy Policy for additional information about website analytics, cookies, contact forms, and the collection of other personal information.

For questions about this statement, concerns about the handling of personal health information, or requests relating to information held by Two Row Consulting, please contact:
 

Organization: Two Row Consulting
Website: https://www.tworowconsulting.com
Email: inquiries@tworowconsulting.com
Mailing Address: 20 York Rd. Box 47, Shannonville, ON, Canada K0K3A0
 

Where a concern relates to a health information custodian for whom Two Row Consulting provides services, individuals may also contact that custodian directly.
 

Individuals may contact the Information and Privacy Commissioner of Ontario to learn about their rights or raise a concern under PHIPA:
 

Information and Privacy Commissioner of Ontario
Website: https://www.ipc.on.ca
Telephone: 416-326-3333
Toll-free: 1-800-387-0073

Two Row Consulting may review and update this statement periodically to reflect changes in its services, information practices, contractual obligations, or applicable privacy requirements.
 

The current version will be made available through our website.