Purpose:

• To provide guidance on when, how, and what information may be provided to third parties including professional liability insurance providers, any level of government in Canada, health insurance companies, Canadian law enforcement, hired contractors, other massage or manual osteopathic therapist association(s), other third parties, and members of the public.

Policy:

1. Access to Membership Information on the CMMOTA Find-A-Therapist Information Page

a. Members have the right to have their name and business information listed on the CMMOTA Find-A-Therapist website, however this is not mandatory, and is at the discretion of the therapist.

b. Information posted on the Find-A-Therapist website is available for all members of the public, without restriction.

2. Disclosure to Professional Liability Insurance Coverage Provider(s)

a. The Association shall disclose the following information to Professional Liability Insurance Coverage Providers for the purpose of establishing or maintaining insurance coverage:

i. Member(s) First and Last Name; and

ii. Current Membership Type; and

iii. Current standing with the Association; and

iv. Mailing Address; and

v. Email Address; and

vi. Phone Number; and

vii. Modalities Information; and

viii. Business Name; and

ix. Business Address; and

x. Business Phone Number; and

xi. Copy of Commercial Business General Liability Information; and

xii. Educational Documents; and

xiii. Certificates of Completion.

b. The Association shall disclose a change in a member’s standing, including the first and last name of the member and the current status of their membership (suspended, cancelled not in good standing, cancelled in good standing, or returned to good standing) with the Association where:

i. The member has been suspended because of pending disciplinary action or formal complaint investigation where there is a perceived risk to the public; or

ii. The member has had their membership cancelled because of disciplinary action; or

iii. The member has voluntarily cancelled their membership.

3. Disclosure to Government(s)

a. The Association shall only provide disclosure to Canadian government(s).

b. The Association shall not provide any disclosure of information other than that which is publicly available through the CMMOTA Find-A-Therapist page to any foreign government entities without a Canadian Court Order or the expressed written consent of the member.

c. The Association shall disclose the following information to any level of Government upon written request for those members who reside or practice within their jurisdiction:

i. Member(s) First and Last Name; and

ii. Current Membership Type; and

iii. Current standing with the Association.

d. The Association may verbally, or in writing, confirm upon request for verification to any level of Government the following:

i. That a person named is a member of the Association; and

ii. The membership type of the member; and

iii. The person’s current standing with the Association.

e. Where a request has been made in writing, the Association shall disclose a change in a member’s standing, including the first and last name of the member and the current status of their membership (suspended, cancelled not in good standing, cancelled in good standing, or returned to good standing) with the Association where:

i. The member has been suspended because of pending disciplinary action or formal complaint investigation where there is a perceived risk to the public; or

ii. The member has had their membership removed because of disciplinary action; or

iii. The member has voluntarily cancelled their membership.

f. Except by Court Order, the Association shall not disclose any additional member’s personal information not mentioned above to any level of a Canadian government without the expressed written consent of the member.

4. Health Insurance Companies

a. The Association shall disclose the following information to any Canadian Health Insurance company upon request:

i. Member(s) First and Last Name; and

ii. Current Membership Type; and

iii. The Membership Number of the Member(s); and

iv. Current standing with the Association; and

v. Business Name; and

vi. Business Address; and

vii. Business Phone Number

b. The Association may verbally, or in writing, confirm upon request for verification to any Canadian Health Insurance company the following:

i. That a person named is a member of the Association; and

ii. The membership type of the member; and

iii. The membership number of a member; and

iv. The date of completion/expected date of completion of their formal professional education; and

v. Current standing with the Association.

c. The Association shall disclose a change in a member’s standing, including the first and last name of the member and the current status of their membership (suspended, cancelled not in good standing, cancelled in good standing, or returned to good standing) with the Association where:

i. The member has been suspended because of pending disciplinary action or formal complaint investigation where there is a perceived risk to the public; or

ii. The member has had their membership cancelled because of disciplinary action; or

iii. The member has voluntarily cancelled their membership.

d. Except by Court Order, the Association shall not disclose any additional member’s personal information not mentioned above to any Canadian Health Insurance Company without the expressed written consent of the member.

5. Law Enforcement

a. The Association may verbally, or in writing, confirm upon request for verification to any Canadian Law Enforcement Agency the following:

i. That a person named is a member of the Association; and

ii. The membership type of the member; and

iii. Current standing with the Association.

b. The Association shall not disclose any additional member’s personal information not mentioned above to any Canadian Law Enforcement Agency without the expressed written consent of the member, except where:

i. A Court Order is issued; or

ii. A member is suspected of having committed a criminal act.

6. Hired Contractors

a. Where a confidentiality agreement exists between CMMOTA and a contractor, the Association may provide member’s information to a hired contractor for the purpose(s) of fulfilling the contract. The confidentiality agreement shall state that any member’s information shall not be shared with any other third party accept where deemed necessary as a condition of the contract.

7. Other Massage or Manual Osteopathic Professional Associations

a. The Association may verbally, or in writing, confirm upon request for verification to any other Massage or Manual Osteopathic Professional Associations the following:

i. That the person named is, or was a member of the Association; and

ii. The membership type of the member; and

iii. The current, or last standing which the person has/had with the Association; and

iv. The date(s) when such standing was in force.

b. Where a request has been made in writing, the Association shall disclose a change in a member’s standing, including the first and last name of the member and the current status of their membership (suspended, cancelled not in good standing, cancelled in good standing, or returned to good standing) with the Association where:

i. The member has been suspended because of pending disciplinary action or formal complaint investigation where there is a perceived risk to the public; or

ii. The member has had their membership cancelled because of disciplinary action; or

iii. The member has voluntarily cancelled their membership.

c. The Association shall not disclose any additional member’s personal information not mentioned above to any other massage or manual osteopathic professional association(s) without the expressed written consent of the member.

8. Other Third Parties not previously considered.

a. No member’s personal information shall be sold or lent or rented to any third party not previously considered for any reason.

b. CMMOTA may enter into an information distribution agreement with a third party, where advertising material or product may be distributed to CMMOTA members on behalf of a third party. This shall be done at the discretion of the Executive Director, and all compensation or benefits, monetary or otherwise shall be for the benefit of the Association. Under such an agreement a recipient list shall only include the member’s first and last name.

c. The Association may verbally, or in writing, confirm upon request for verification to any third party the following:

i. That the person named is a member of the Association; and

ii. The membership type of the member; and

iii. The current standing with the Association.

d. Except by Court Order, the Association shall not disclose any additional member’s personal information not mentioned above to other third parties without the expressed written consent of the member.

9. Members of the Public

a. The Association may verbally, or in writing, confirm upon request for verification to any person the following:

i. That the person named is a member of the Association; and

ii. The membership type of the member; and

iii. The current standing with the Association.

Original Date of Policy Adoption: May 30, 2024

Date of Last Policy Revision:

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