Best Behaviour Inc. is committed to protecting personal information and keeping it safe. We collect, use and disclose personal information in order to serve our clients and maintain accurate client and team member records. For our clients, we collect personal health information to provide ABA Therapy and Psychotherapy services as follows:

• to obtain a measure of health/skills so that in providing ongoing therapy, we can identify changes that are occurring over time and assess the need for continued therapy

• to obtain payment for services provided

• to conduct quality improvement and risk management activities

• to comply with external regulators

• to promote our centre, services, special events and professional opportunities that we have available

• to educate our team members and students

• to facilitate the sale of our organization (if applicable)

We will collect, use and disclose only as much personal health information as is needed to achieve these purposes. You can withhold or withdraw your consent to the collection, use or disclosure of your personal health information by contacting us (details below).

You Can Access Your Health Records

You have the right to seek access to your health records that we keep and to ask us to correct a record if you believe it is inaccurate or incomplete. Please contact us for more information.

To access a full copy of our Privacy Policy and Procedures, please visit https://www.bestbehaviour.ca/policies.

Questions or Concerns

• Best Behaviour Inc. welcomes feedback on the Privacy Policy and Procedures. Our Information Officer is Sophia Catania. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

• A formal complaint or inquiry may be submitted in writing to the attention of Sophia Catania. She will acknowledge the complaint/inquiry, investigate it promptly, and send notification in writing of the outcome of the decision and the reasons behind the decision. If the notification does not satisfy the complaint, a complaint may be sent to either 1) the Privacy Commissioner of Canada or 2) our regulatory body, the College of Psychologists and Behaviour Analysts of Ontario. Contact information is as follows:

1.     Office of the Privacy Commissioner of Canada

• 112 Kent Street, Pace de Ville, Tower B, 3rd Floor, Ottawa, Ontario, K1A 1H3

• (613) 947-1698 or (800) 282-1376

• privcom.gc.ca

2.     College of Psychologists and Behaviour Analysts of Ontario

• 500-110 Eglinton Avenue West, Toronto, Ontario, M4R 1A3

• (416) 961-8817

• https://cpo.on.ca/public/complaints-reports-to-the-college/

 Best Behaviour Inc. is committed to protecting personal health information and keeping it safe. The following policies and procedures have been introduced to ensure personal information is handled with care and kept private, according to the rules and regulations enacted in the Province of Ontario and within the professional fields represented by the team members at Best Behaviour Inc.

In 2004, Ontario enacted the Personal Health Information Protection Act, 2004 (“PHIPA”). PHIPA follows the same principles as the federal Personal Information Protection and Electronic Documents Act, 2000(“PIPEDA”), however it provides much more specific guidance about the handling of personal health information. PHIPA applies to any collection, use or disclosure of personal health information by a health information custodian (“HIC”).

Definition of Personal Health Information

• Personal information is defined as any information about an identifiable individual, including information that can be combined with other data to then identify the individual.

• Personal information can be oral or recorded and may relate to an individual’s physical or mental condition (ex. medical or family history), health care (ex. therapy history or details about current therapy services), health care providers (ex. names of other professionals in the client’s circle of care), payment for health services (ex. government funding details or credit card number), and non-health care related information (ex. home address or phone number).

• Personal Information does not include business information (ex. business phone number, business address). Business information is not protected by PHIPA.

Who We Are

• At Best Behaviour Inc., we are a team of dedicated health professionals and therapists that may, in the course of their time providing services, have limited access to the personal health information we hold. These include, but are not limited to, Behaviour Analysts, Registered Psychotherapists, senior clinical team members, clinical support team members, bookkeepers and accountants, lawyers, administrative staff, placement students and volunteers. We restrict their access to any personal health information we hold as much as is reasonably possible. We also have their assurance that they follow the appropriate privacy principles outlined in this policy.

• Best Behaviour Inc. recognizes its responsibility to comply with PHIPA as a health information custodian(“HIC”). As a HIC, Best Behaviour Inc. is ultimately responsible for the personal health information in its care as an organizational custodian. Should Best Behaviour Inc. be unable to uphold its duties as the HIC, another custodian will be appointed, or the personal health information will be returned to the original owner for protection and retention.

• The Information Officer, or contact person, under PHIPA at Best Behaviour Inc. is Sophia Catania. The Information Officer is responsible for ensuring that the HIC puts in place and follows appropriate information practices. The Information Officer must facilitate compliance with PHIPA, educate any agents of the custodian, respond to public inquiries about the custodian’s information practices, oversee access and correction request, and handle privacy complaints. The Information Officer is also responsible for displaying a written public statement about the information practices at Best Behaviour Inc.

Permission to Collect, Use and Disclose Personal Health Information

• PHIPA requires consent for the collection, use and disclosure of personal health information, and provides specific guidance as to what constitutes a valid consent for the collection, use and disclosure of such information.

• Best Behaviour Inc. is committed to obtaining informed and capable consent from all individuals receiving services, prior to the commencement of services and whenever changes are made to the nature of services offered or provided.

  • • Consent is defined as the voluntary agreement of an individual, or his or her authorized representative, who has the legal capacity to give consent and exercise free power of choice, without undue inducement or any other form of constraint or coercion to participate in treatment. The individual must have sufficient knowledge and understanding of the nature of the proposed treatment, the anticipated risks and potential benefits, and the requirements of the treatment to be able to make an informed decision.

      • • • It is important to note that the age of majority in Ontario is eighteen (18) years of age. Written or verbal consent from a parent/guardian is required for individuals under the age of eighteen (18). Individuals over the age of eighteen (18) may provide and revoke their own consent if deemed capable of consenting.

          • However, it is equally important to note that under Section 4 (1) of the Health Care Consent Act, 1996, a person is considered capable with respect to treatment if they are able to understand the information that is relevant to making a decision about the treatment and are able to appreciate the reasonably foreseeable consequences of a decision or lack of decision.  The Health Care Consent Act does not specify a minimum age of consent.

    • Implied consent: Permission is inferred from the actions on the part of the individual.

      • • • Implied consent is generally permitted where it is reasonable to assume that the individual knows the purpose of the collection, use or disclosure and their right to give or withhold consent. For example, if the information was received from the individual directly or if the individual was present during the collection, use or disclosure of the information.

    • Express consent: Permission is given directly and explicitly, either verbally or in writing.

      • • • Express consent (verbal or written) is needed to disclose personal health information to a non-custodian and to disclose personal health information to another custodian for purposes other than the provision of health care. It is also required when providing behavioural assessment and/or intervention.

• Assent: An individual’s willingness to participate in treatment by persons who are by definition too young to give consent but who are old enough to understanding of the nature of the proposed treatment, the anticipated risks and potential benefits, and the requirements of the treatment, to be able to make an informed decision.

  • • Assent is not required by law, but taking a person’s wishes, preferences, best interests and autonomy into account is an ethically defensible practice.

    • It is important to note that minors may be provided with written information regarding the nature of the proposed treatment, the anticipated risks and potential benefits, and the requirements of the treatment, to be able to make an informed decision when assenting. A simple verbal explanation may also be given with reassurances that they do not have to agree if they do not want to. This verbal assent discussion will be documented and retained. Minors are not required to write their name on an official document, rather that the person obtaining assent will note that a discussion occurred, what was discussed, whether the minor agreed to participate, and the date on which the discussion occurred.

• It is important to note that both consent and assent may be revoked at any time.

Why We Collect Personal Health Information

• Best Behaviour Inc. collects, uses and disclose personal information in order to serve our clients and maintain accurate client and team member records. For our clients, the primary purpose for collecting personal health information is to provide ABA Therapy and Psychotherapy services. For example, we collect information about a client’s health history, including their family history or presenting concerns, in order to help us assess what their therapy needs are, to advise them of their options and then to provide the services they choose to register for. A second primary purpose is to obtain a measure of health/skills so that in providing ongoing therapy, we can identify changes that are occurring over time and assess the need for continued therapy. We also collect, use and disclose personal health information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

o   Related Purpose #1: To obtain payment for services provided. Payment may be obtained from the individual, private insurers, or others (ex. Ontario Autism Program).

o   Related Purpose #2: To conduct quality improvement and risk management activities. We review client files to ensure that we provide high quality services, including assessing the performance of our staff. External consultants (ex. auditors, lawyers, practice consultants) may conduct audits and quality improvement reviews on our behalf.

o   Related Purpose #3: To comply with external regulators. Our professionals regulated by a College may be subject to an inspection of our records as a part of regulatory activities in the public interest. Each College has its own strict confidentiality and privacy obligations. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, Best Behaviour Inc. believes that it should report information suggesting illegal behaviour to the authorities. In addition, we may be required by law to disclose personal health information to various government agencies (e.g. Ministry of Health, children’s aid societies, Canada Customs and Revenue Agency, Information and Privacy Commissioner, etc.).

o   Related Purpose #4: To promote our centre, services, special events and professional opportunities that we have available. We will always obtain express consent prior to

to collecting or handling personal health information for this purpose.

o   Related Purpose #5: To educate our team members and students. We value the education and development of future and current professionals. We may review client records in order to educate our team members and students about the provision of ABA Therapy and Psychotherapy.

o   Related Purpose #6: To facilitate the sale of our organization. If the organization or its assets were to be sold, the potential purchaser would want to conduct a “due diligence” review of the organization’s records to ensure that it is a viable business that has been honestly portrayed. The potential purchaser must first enter into an agreement with the organization to keep the information confidential and secure and not to retain any of the information longer than necessary to conduct the due diligence. Once a sale has been finalized, the organization may transfer records to the purchaser, but it will make reasonable efforts to provide notice to the individual before doing so.

·      Best Behaviour Inc. does not collect personal health information for the purpose of regular communication about services or advertising, in compliance with Canada’s anti-spam legislation.

Disclosing Personal Health Information Without Consent

• Additional examples of situations when personal health information may be shared without consent include:

  • An individual suspects or confirms instances of occurrences where a child/youth is or may be in need of protection (as per section 125 of the Child, Youth and Family Services Act, 2017).

    • These reports are made to the local Children's Aid Society, and are based on reasonable grounds. 'Reasonable grounds' is defined as the information that an average person, using normal and honest judgment, would need in order to decide to report. In most cases, a report will not be submitted without advance notice and communication with the Parent/Guardian. Best Behaviour Inc. may also engage a confidential consultation with a local CAS before making the decision to report, and prefers to include parents in the process of reporting when possible.

  • An individual expresses intent to seriously harm themselves or others.

  • An individual shares information about a child, currently under the age of sixteen (16), who has been abused or neglected, or is at risk of being abused or neglected.

  • An individual indicates that they or a child has been sexually abused by a Regulated Health Professional.

  • A court of law subpoenas files that contain personal information.

• It is also important to note that therapy is most effective when a trusting relationship exists between the therapist and learner. Privacy is especially important in securing and maintaining that trust. It is necessary for the learner to establish a 'zone of privacy' with their therapist that allows them to feel free to discuss personal matters. To achieve this, confidentiality is ensured between the learner and therapist unless otherwise discussed with the learner or in the case of circumstances described above.

Protecting Personal Health Information

• We understand the importance of protecting personal health information. For that reason, we have taken the following steps:

o   Paper information is either under supervision or secured in a locked or restricted area when not in use. This may be at the primary office of 15 Willow Street, or the client’s home. Clients are informed of how to store their personal health information in accordance with these professional standards.

o   Electronic hardware is either under supervision or secured in a locked or restricted area after hours. In addition, strong passwords are used on all computers and mobile devices.

o   Personal health information is only stored on mobile devices if necessary. All personal health information stored on mobile devices is protected by strong passwords, and deleted when it is no longer needed or moved to a more secure form of electronic cloud-based storage. The cloud-based storage of choice at Best Behaviour Inc. is Google Drive.

o   When transporting personal information, team members have been instructed to ensure the information is secured, and under supervision at all times.

o   All efforts will be made to ensure personal health information isn’t overheard or overseen when personal health information is being transported or accessed in a public location.

o   Paper information is transferred through sealed, addressed envelopes or boxes by reputable companies with strong privacy policies.

o   Electronic information is either anonymized or encrypted before being transmitted, and accompanied by a privacy clause.

o   When telehealth services are being provided, only secure platforms will be used. Google Meet and Jane App are the platforms of choice, however any platform that is compliant with the Health Insurance Portability and Accountability Act ("HIPAA") is acceptable.

o   Our team members are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this privacy policy.

o   We do not post any personal information about our clients or identifiable photos on social media sites, and our team members are trained on the appropriate use of social media sites.

o   External consultants and agencies with access to personal information must also agree to fulfill their duties in accordance with this privacy policy.

Retention and Destruction of Personal Health Information

• We need to retain personal health information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, in order to protect your privacy, we do not want to keep personal information for too long.

• We keep our client files for at least ten (10) years from the date of the last client interaction or from the date the client turns 18 (whichever is longer).

  • It is important to note that the decision about whether to retain a document within a client file might be answered by the following question: “Could the reliability of my conclusions or the reasonableness of my actions be confirmed without reference to the information in the document?”

• We destroy paper files containing personal health information, such that the records cannot be reconstructed.

• We destroy electronic information by deleting it in a manner that it cannot be restored. When hardware is discarded, we ensure that the hardware is physically destroyed or the data is erased or overwritten in a manner that the information cannot be recovered.

You Can Look at Your Records

• With only a few exceptions, you have the right to see what personal information we hold about you, by contacting the Information Officer. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (ex. short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge $30.00 for the first twenty pages of records and 25 cents for each additional page. We may ask you to put your request in writing. We will respond to your request as soon as possible and generally within 30 days. If we cannot give you access, we will tell you the reason, as best we can, as to why.

• If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake we will make the correction. At your request and where it is reasonably possible, we will notify anyone to whom we sent this information (but we may deny your request if it would not reasonably have an effect on the ongoing provision of health care). If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point.

How We Respond to a Privacy Breach

• While we will take precautions to avoid any breach of your privacy, if there is a loss, theft or unauthorized access of personal health information we will notify the person whose information has been compromised.

• Upon learning of a possible or known breach, we will take the following steps:

  • • We will contain the breach to the best of our ability, including by taking the following steps if applicable:

      • • • Retrieving hard copies of personal health information that have been disclosed.

          • Ensuring no copies have been made.

          • Taking steps to prevent unauthorized access to electronic information (ex. change passwords, restrict access, temporarily shut down system).

    • We will notify the affected individual(s).

      • • • We will provide our contact information in case the individual has further questions.

          • We will provide the Commissioner’s contact information and advise the affected individual(s) of their right to complain to the Commissioner.

    • We will investigate and remediate the problem, by:

      • • • Conducting an internal investigation.

          • Determining what steps should be taken to prevent future breaches (ex. changes to policies, additional safeguards).

          • Ensuring team members are appropriately trained and conduct further training if required.

• Depending on the circumstances of the breach, Best Behaviour Inc. may notify and work with the Information and Privacy Commissioner of Ontario. If Best Behaviour Inc. takes disciplinary action against one of our team members, or revokes or restricts the privileges or affiliation of one of our team members, for a privacy breach, this will be reported to the team member’s regulatory College. Best Behaviour Inc. may also report the breach to the relevant regulatory College if it was the result of professional misconduct, incompetence or incapacity.

• Questions or Concerns

  • Best Behaviour Inc. welcomes feedback on the Privacy Policy and Procedures. Our Information Officer is Sophia Catania. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

  • A formal complaint or inquiry may be submitted in writing to the attention of Sophia Catania. She will acknowledge the complaint/inquiry, investigate it promptly, and send notification in writing of the outcome of the decision and the reasons behind the decision. If the notification does not satisfy the complaint, a complaint may be sent to either 1) the Privacy Commissioner of Canada or 2) our regulatory body, the College of Psychologists and Behaviour Analysts of Ontario. Contact information is as follows:

1.     Office of the Privacy Commissioner of Canada

• 112 Kent Street, Pace de Ville, Tower B, 3rd Floor, Ottawa, Ontario, K1A 1H3

• (613) 947-1698 or (800) 282-1376

• privcom.gc.ca

2.     College of Psychologists and Behaviour Analysts of Ontario

• 500-110 Eglinton Avenue West, Toronto, Ontario, M4R 1A3

• (416) 961-8817

• https://cpo.on.ca/public/complaints-reports-to-the-college/

 Best Behaviour Inc. follows a conflict resolution process to address conflicts that arise. This policy applies to both team members and parents/caregivers. Having a policy ensures that all stakeholders know what is expected and that they are treated fairly in the event of a conflict.

Raising a Concern

Should a team member or parent/caregiver have a concern or experience a conflict, they are encouraged to communicate that concern directly to a supervisor. Communication may occur in-person, over the phone, or via email.

Conflict Resolution Process

The supervisor will initiate the conflict resolution process outlined below. Please note that Best Behaviour Inc. reserves the right to combine or skip steps, depending on the situation.

1.     Data Collection

·      The supervisor will provide acknowledgement of the problem to the person who raised the concern within 5 days of it being raised.

·      At this time, the supervisor will fill out a Conflict Resolution Log to note the primary concern and begin the data collection process.

·      Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded. 

2.     First Warning

·      At any point during the initial reporting or data collection phase, a first warning may be given as an acknowledgement of the problem to the individual.

·      The supervisor will discuss with them the nature of the problem or how their behaviour was in conflict with company policies, procedures and/or values. The supervisor will clearly describe the expectations and the steps the individual must take to improve their performance or resolve the problem.

·      Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded. 

3.     Second Warning

·      Should the problem continue, the supervisor may provide a second verbal warning.

·      The supervisor will re-describe the expectations and the steps the individual must take to improve their performance or resolve the problem, and notify their supervisor(s) for additional support as needed.

·      Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded.

4.     Final Written Warning

·      If the problem continues after 2 warnings, the supervisor will provide a third verbal warning.

·      The supervisor will re-describe the expectations and the steps the individual must take to improve their performance or resolve the problem.

·      Notify the individual that they will be provided with a final written warning, and that failure to improve performance or resolve the problem may result in termination.

·      Subsequent behaviours/incidents related to the original behaviour/incident that warranted the conflict resolution process will be monitored and recorded.

5.     Termination

·      This step is taken when all others have been exhausted.

·      The supervisor will meet with the Director to review all of the documentation related to the problem. The Director will outline the steps that will be taken should termination be required.

Documenting Conflict Resolution

Supervisors will document each step in the conflict resolution process using the Conflict Resolution Log. This document will be filed in the individual’s team member or client folder when the conflict is resolved. When an individual is named in a Conflict Resolution Log, they must be informed of the conflict that involves them (starting with Step 2), what stage in the conflict resolution process they are in, the consequences of further conflict, and the actions they can take to resolve it.

Behaviours Warranting Conflict Resolution for Team Members

Behaviours that warrant conflict resolution may include, but are not limited to, the following:

·      Failure to perform roles and responsibilities outlined in one’s job description

·      Dress code violations

·      Inappropriate behaviour with co-workers or clients

·      Attendance issues/frequent cancellations

·      Discrimination

·      Theft of physical and/or intellectual property

·      Theft of clients or staff

·      Complaints filed by other co-workers or clients

·      Complaints regarding company policies/procedures

Behaviours Warranting Conflict Resolution for Parents/Caregivers 

Behaviours that warrant conflict resolution may include, but are not limited to, the following:

·      Inability to provide the supports and/or resources needed to work towards important goals

·      Inappropriate behaviour with therapists

·      Attendance issues/frequent cancellations

·      Discrimination

·      Theft of physical and/or intellectual property

·      Theft of staff

·      Complaints filed by therapists

·      Complaints regarding company policies/procedures

Appeals Process

Individuals have the right to present evidence to refute the information that was used as the basis for the conflict. The supervisor will evaluate the evidence presented and decide on next steps.

Questions or Concerns

·      Best Behaviour Inc. welcomes feedback on the Conflict Resolution Policy. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

March-June 2022 Update

The Province of Ontario released new guidelines on March 9, 2022 regarding the lifting of various COVID-19 emergency orders. The mandatory vaccination policies were revoked on March 14, most masking mandates were removed on March 21, the Reopening Ontario Act expired on March 28, and all remaining emergency orders were expected to be removed on April 27. A full description of this media release from the Ministry of Health can be found here.

Individual organizations were encouraged to keep their own requirements in place. After reviewing the responses from related ministries and services/programs (ex. Ministry of Education, child care, high risk settings, other ABA providers), we decided to continue to follow Public Health’s COVID-19 recommendations, prior to the March 9 announcement. This meant that all current protocols in place would continue to be followed regarding vaccinations, masks, and using the school screener.

On April 22, 2022, the Province of Ontario released an update that included continued masking requirements in select indoor settings until June 11. A full description of this media release from the Ministry of Health can be found here.

On June 8, 2022, the Province of Ontario confirmed that all remaining directives would be revoked and replaced with Ministry of Health guidance for health care workers and organizations, including guidance on when masks should be worn in hospitals and other health care settings. The full media release can be found here. Ontarians are encouraged to continue to wear a mask if they feel it is right for them, are at high risk for severe illness, recovering from COVID-19, have symptoms of the virus, or are a close contact of someone with COVID-19. Organizations may also choose to implement their own policies as applicable.

Based on this most recent update from the Chief Medical Officer of Health, and after evaluating the various COVID-19 policies that are being implemented across services similar to ABA services (ex. childcare, schools, regulated health care professionals, public health services etc.), we have decided to follow the direction of Public Health and lift any mandatory masking requirements. Team members and parents are encouraged to keep the discussion open, to ensure everyone feels comfortable with this transition. Some team members may choose to still wear a mask, and some parents may feel more comfortable with masks being worn during sessions. We will continue to work together to provide a service that is not only effective and meaningful for the families we support, but also that maintains the health and safety of everyone involved. The vaccination policy written below will shift to a recommendation vs. requirement, for all team members. Rapid antigen screening is no longer provided by Best Behaviour Inc. If rapid antigen screening is available in your community, we encourage everyone to take advantage of this resource.

No other changes will be made; meaning that we will continue to use the school screener to conduct daily self-assessments and follow best practices when it comes to hygiene and symptom management.

Best Behaviour Inc. has been working very hard to adjust services and provide meaningful accommodations during the COVID-19 pandemic, and will continue to do so. Our services have been deemed essential, according to the most recent guidelines introduced on January 12, 2021. See page 27 under ‘Health care and social services’.

We have been able to safely provide in-person services (in home and in centre) by following all of the recommendations outlined by Public Health. We will also continue to provide various virtual accommodations, at both the service and supervisory levels.

• Virtual service options will be made available when clinically appropriate. This includes occasional shifts between virtual and in-person services, as needed in response to directions given by Public Health.

• Observations will continue to be provided in-person and virtually, depending on the needs of the learner and family preferences. Virtual observations and direct service will be delivered via secure platforms (ex. Ring security system, Google Meet). When planning for in-person observations, new and existing close contacts will be considered.

Self Assessments

The Government of Ontario has created a variety of self-assessment tools for individuals to use to screen and monitor COVID-19 symptoms.

We are asking all families to complete the school screener daily for their learner and other members of the household. Team members will also need to complete the school screener daily for themselves and members of their household. They may also complete a screener for the learner and/or family members upon arrival to session.

If everyone passes the screener, in-person services are deemed safe. If anyone does not, then the rest of the team should be notified and the recommendations listed on the screener will be followed.

Best Practices

The following precautions will be taken, in order to minimize everyone’s risk of exposure to COVID-19:

• If you or someone in your household is identified as a close contact of someone who has tested positive for COVID-19, please follow all necessary protocols outlined by Public Health re: confirmed and potential exposures to COVID-19.

• Complete regular daily self-assessments of all team members and clients (adults and children), home safety risk assessments, and point-of-care risk assessments.

• Encourage physical distancing whenever possible. Maintain a 2-metre distance and avoid unnecessary close contacts, and make use of outdoor space whenever possible. Arrange for pick-ups and drop-offs to happen outdoors, and stagger start/end times to avoid overcrowding. During times when individuals may become unmasked (ex. snack time), please keep these activities within a 10-15 minute time limit.

• If physical distancing is not possible, personal protective equipment (PPE) in the form of a mask or face covering is recommended, particularly for individuals 6 years of age and older. When interacting with individuals without a mask or face covering, additional protections such as eye protection is also recommended. PPE must be put on outdoors or while physically distancing, and replaced after each visit. Perform hand hygiene before PPE is put on, and before/after removal.

• For those who are unable to wear a mask due to individual challenges, working on mask desensitization or teaching appropriate mask use is a goal that should be introduced to the learner’s programming.

• Perform proper respiratory hygiene. Cover coughs with a tissue or cough into your elbow, followed by proper hand hygiene.

• Perform proper hand hygiene (including assisting children with hand hygiene) and incorporate additional hand hygiene opportunities. Wash hands upon entry and exit, before food is prepared/administered, and any other time hands are potentially contaminated or after other personal hygiene practices.

• Increase the frequency of cleaning and disinfecting objects, toys, and frequently touched surfaces (twice per day). Limit shared materials to only those that are essential. Ensure all toys used are made of material that can be cleaned and disinfected. Do not use water or sensory tables. Label personal items to discourage accidental sharing. Check expiry dates of cleaning products used and always follow manufacturer instructions.

• Do not share eating/drinking utensils or food. If food items are being shared with learners or team members (ex. bringing in a treat to celebrate a birthday), please ensure team members and parent/guardians are notified ahead of time. Please only bring in food items that have been prepared in regulated facilities (ex. store-bought or restaurant-prepared food items). Packaged/sealed food items are also preferred, since they can be sent home with learners if parents would feel more comfortable inspecting the food item before allowing the learner to consume it.

Vaccinations

The Province of Ontario has issued a directive that requires hospital and home/community care service providers to have a COVID-19 vaccination policy for employees, staff, contractors, students, and volunteers. The vaccination policy must be effective no later than September 7, 2021, and at a minimum will require these individuals to provide proof of one of three things:

• Full vaccination against COVID-19

• A medical reason for not being vaccinated against COVID-19

• Completion of a COVID-19 vaccination educational session, and regular antigen testing

In response to this directive, Best Behaviour Inc. has implemented the following vaccination policy, effective September 7, 2021:

• All employees, staff, contractors, students and volunteers must provide proof of immunization against COVID-19 by October 17, 2021. Public Health currently considers anyone who has received 2 doses of a COVID-19 vaccination for a minimum of 14 days as fully immunized. A copy of proof of vaccination can be sent to sophiacatania@bestbehaviour.ca to be kept on file. Only the enhanced vaccine certificate with QR code can be used as proof of vaccination at this time. Individuals can download their enhanced certificate with QR code by visiting covid-19.ontario.ca/get-proof.

• Anyone who cannot receive a vaccination due to a medical reason will have the option to submit a request for accommodation to sophiacatania@bestbehaviour.ca. This request must include a provincially-issued exemption QR code for verification. For more information about the exemption QR code process, please see the Province’s announcement on December 10, 2021.

• If a team member is unsuccessful after seeking a medical accommodation, proof of a first COVID-19 vaccination will be required within 72 hours of being notified or by October 17, 2021 (whichever comes first).

• Anyone granted accommodation or who is not yet fully vaccinated must test negative on a rapid antigen test no more than 72 hours prior to each scheduled day of work.

We will continue to monitor any updates regarding vaccinations, that would be relevant to our field of work and the learners we support.

At this time, full vaccination against COVID-19 is not mandatory for learners or families. The COVID-19 booster shots are also not required for team members, learners, or families.

Rapid Antigen Screening

Best Behaviour Inc. is enrolled in the Provincial Antigen Screening Program. This provides us with rapid antigen screening kits to be used for team members who work in-centre*. The Province of Ontario released new instructions around the use of rapid antigen tests on December 30, 2021. Due to the current shortage test availability, it is recommended that rapid antigen tests be used for “test-to-work” purposes. Asymptomatic team members can use them to return to work when they would otherwise be in isolation. Symptomatic team members can also use them to confirm if they have COVID-19 (with no requirement for a confirmatory PCR or rapid molecular test).

The results of all rapid antigen tests completed in-centre must be reported using the Google Form provided. Best Behaviour Inc. is required to report all rapid test results completed. Training on how to complete the screening and report results will be provided.

Team members who are not fully vaccinated and are required to complete a rapid antigen test every 72 hours may not use the tests provided at the centre. Please obtain tests from a community distributer. Personal rapid antigen test results do not need to be reported to Best Behaviour Inc. at this time. 

In the event that a team member receives a ‘positive’ result, they will be required to immediately cancel their sessions for the day and follow the subsequent recommendations from Public Health. We recognize the inconvenience this may cause families, however this is one of the ways we can help slow the spread of COVID-19 in our community and workplace.

*Screening provided by Best Behaviour Inc. is not currently available for team members working in-home, clients, or families. However, if a team member working in-home requires a rapid antigen test for a ‘test-to-work’ purpose or to confirm if they have COVID-19, please contact Sophia Catania to confirm if a rapid antigen test can be made available.

If rapid antigen screening becomes available in your community, we encourage everyone to take advantage of this resource.

In-Centre Reminders

Here's what you can do to help us maintain a safe work environment at the centre:

• No walk-ins. Please do not enter the unit unless you have been instructed to do so. Please call 226-755-0015 if you are unsure how to proceed upon arrival.

• Call before entering the unit for your scheduled appointment, if no one is there to meet you. You will be met in the hallway, outside, or at your designated meeting point.

• Before entering the unit, please complete a self-assessment. Contactless temperature checks may also be conducted.

• Wash or sanitize your hands upon entering the unit.

• Cough or sneeze into your elbow and avoid touching surfaces/materials when possible.

• Maintain a 2-metre distance between yourself and others when possible.

• If this is not possible, personal protective equipment (PPE) in the form of a mask or face covering is recommended for adults. It is also recommended for children over the age of 2 years old, particularly for individuals 6 years of age and older. PPE must be put on outdoors or while physically distancing, and replaced after each visit. When interacting with individuals without a mask or face covering, additional protections such as eye protection are required for adults only.

Cancellation Policy Clarification

In light of Public Health recommendations that may result in an increased number of cancelled sessions, it is also important to review our 24-hour cancellation policy. For one-to-one sessions (as stated in the One-to-One Registration Form) …

• In the event of a cancellation, I must notify the ABA Therapist(s), Senior Therapist, and Clinical Supervisor. Sessions cancelled twenty-four (24) hours in advance will not be billed. Cancelled sessions can be rescheduled at the discretion of the Parent/Guardian and Therapist, but it is not required.

• Sessions cancelled within twenty-four (24) hours notice will be billed in full, as a Late Parent Cancellation. If possible, these hours will be used to benefit the learner’s programming.

• If the learner is sick and the session is not cancelled, the Therapist may cancel upon arrival or end session early at their discretion, and it will be considered a Late Parent Cancellation.

• If the Therapist cancels a session for any reason, all parties will be notified as soon as possible. If the session cannot be covered by another team member, the session will be cancelled and will not be billed. Cancelled sessions can be rescheduled at the discretion of the Parent/Guardian and Therapist, but it is not required.

Team members, please record the date/time you received notification of a cancelled session when tagging it as a Late Parent Cancellation on Clockify, in the description.

This applies to the first instance of a cancellation, not subsequent cancellations. For example, if SC is exhibiting symptoms and the self-assessment indicates that sessions will need to be cancelled until the learner is symptom free for 24 hours, that first cancelled session may be billed in full if it was cancelled less than 24 hours before the expected start of session. However, it is understood that all subsequent sessions are cancelled until further notice, so there would be no ‘Late Parent Cancellation’ charges for subsequent sessions. In this example, a parent would notify their therapy team when the learner has been symptom free for 24 hours and sessions would resume at the therapists’ earliest available start date.

Financial Benefit Programs

There are many financial benefit programs available to help families and workers facing hardship as a result of the COVID-19 pandemic. These programs include benefits geared towards caregivers, employees, and independent contractors, who may be required to stay home and self-isolate or who experience a significant drop in income due to someone else’s self-isolation.

Here is a list of the most up-to-date financial benefit programs.

Employees were eligible for the Ontario COVID-19 Worker Income Protection Benefit, however this program ended as of April 1, 2023.

Updated: September 12, 2023

Best Behaviour Inc. is committed to meeting its current and ongoing obligations under the Ontario Human Rights Code (“OHRC”) and the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”). Best Behaviour Inc. understands that the AODA does not substitute or limit its obligations under the OHRC or obligations to people with disabilities under any other law.

Best Behaviour Inc. is committed to excellence in serving all clients and team members, including people with disabilities. The following policy is consistent with the principles of independence, dignity, integration, and equal opportunity for people with disabilities.

Assistive Devices

• People with disabilities may use personal assistive devices when accessing or providing services at Best Behaviour Inc. In cases where the assistive device presents a significant and unavoidable health or safety concern or may not be permitted for other reasons, other measures will be used to ensure the person with a disability can access or provide services.

• Best Behaviour Inc. will ensure that team members are trained and familiar with various assistive devices within their place of work.

Communication

• Best Behaviour Inc. will communicate with people with disabilities in ways that consider their disability, and work collaboratively to determine what method of communication works for them.

Service Animals

• Best Behaviour Inc. welcomes people with disabilities and their service animals. Service animals are allowed in places of work that are open to the public.

• A service animal can be identified through visual indicators, such as wearing a harness or vest, or helping the person perform certain tasks for reasons relating to their disability. If an animal is not easily identified as a service animal, Best Behaviour Inc. may ask the person with a disability to provide documentation from a regulated health professional. A regulated health professional is defined as a member of one of the following colleges: College of Audiologists and Speech-Language Pathologists of Ontario, College of Chiropractors of Ontario, College of Nurses of Ontario, College of Occupational Therapists of Ontario, College of Optometrists of Ontario, College of Physicians and Surgeons of Ontario, College of Physiotherapists of Ontario, College of Psychologists and Behaviour Analysts of Ontario, College of Registered Psychotherapists, and Registered Mental Health Therapists of Ontario.

• If service animals are prohibited by another law, or due to other environmental constraints, Best Behaviour Inc. will explain why the animal is excluded and discuss with the person another way of accessing or providing services.

Support Persons

• A person with a disability who is accompanied by a support person will be allowed to have that person accompany them to the place of work. Fee/fare will not be charged for support persons.

• In certain cases, Best Behaviour Inc. may require a person with a disability to be accompanied by a support person for the health or safety of the person with a disability or others. Before deciding, Best Behaviour Inc. will consult with the person with a disability to understand their needs, consider the health or safety reasons based on available evidence, and determine if there is no other reasonable way to protect the health or safety of the person or others.

Notice of Temporary Disruption

• In the event of a planned or unexpected disruption to services for persons with disabilities, Best Behaviour Inc. will notify the affected individual(s) promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated length of time, and a description of alternative arrangements if available. The notice will be distributed electronically, and via paper copies upon request, to the affected individual(s).

Training

• Best Behaviour Inc. will provide accessible service training to all team members, anyone involved in developing policies, and anyone who provides services or facilities to clients and team members on Best Behaviour’s behalf. Training on accessible service will be provided for those entering into any contractual agreement. Training will include the purpose of the AODA, service standards, policies related to service standards at Best Behaviour Inc., how to interact and communicate with people with various types of disabilities, how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person, how to use the equipment or devices available that may help with providing services to people with disabilities, and what to do if a person with a disability is having difficulty in accessing services at Best Behaviour Inc. Training will also be provided when changes are made to accessible service policies.

Notice of Availability of Documents

• Best Behaviour Inc. will notify the public that documents related to accessible service are available upon request by posting a notice at www.bestbehaviour.ca. Documents will be made available electronically, and via paper copies upon request. Best Behaviour Inc. will provide this document in an accessible format or with communication support upon request. The person making the request will be consulted to determine the suitability of the format or communication support. The accessible format will be provided in a timely manner, at no additional cost.

Modifications to This or Other Accessibility Policies

• Policies at Best Behaviour Inc. that do not respect and promote the principles of dignity, independence, integration, and equal opportunity for people with disabilities will be modified or removed.

Questions or Concerns

• Best Behaviour Inc. welcomes feedback on the Accessibility Policy and Procedures. Our Accessibility Officer is Sophia Catania. Sophia would be happy to discuss any concerns about this policy. She can be reached at (226) 755-0015 or sophiacatania@bestbehaviour.ca.

• A formal complaint or inquiry may be submitted in writing to the attention of Sophia Catania. She will acknowledge the complaint/inquiry, investigate it promptly, and send notification in writing of the outcome of the decision and the reasons behind the decision. If the notification does not satisfy the complaint, a complaint may be sent to the Government of Ontario. Contact information is as follows:

1.     Government of Ontario

• 1-866-515-2025 or by TTY: 1-800-268-7095

1. Terms

By accessing this website, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.

2. Use License

Permission is granted to temporarily download one copy of the materials (information or software) on Best Behaviour Inc.'s website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not: modify or copy the materials, use the materials for any commercial purpose, or for any public display (commercial or non-commercial), attempt to decompile or reverse engineer any software contained on Best Behaviour Inc.'s website, remove any copyright or other proprietary notations from the materials, transfer the materials to another person or "mirror" the materials on any other server. This license shall automatically terminate if you violate any of these restrictions and may be terminated by Best Behaviour Inc. at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer

The materials on Best Behaviour Inc.'s website are provided on an 'as is' basis. Best Behaviour Inc. makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, Best Behaviour Inc. does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site.

4. Limitations

In no event shall Best Behaviour Inc. or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on Best Behaviour Inc.'s website, even if Best Behaviour Inc. or a Best Behaviour Inc. authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

5. Accuracy of Materials

The materials appearing on Best Behaviour Inc.'s website could include technical, typographical, or photographic errors. Best Behaviour Inc. does not warrant that any of the materials on its website are accurate, complete or current. Best Behaviour Inc. may make changes to the materials contained on its website at any time without notice. However, Best Behaviour Inc. does not make any commitment to update the materials.

6. Links

Best Behaviour Inc. has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by Best Behaviour Inc. of the site. Use of any such linked website is at the user's own risk.

7. Modifications

Best Behaviour Inc. may revise these terms of service for its website at any time without notice. By using this website, you are agreeing to be bound by the then current version of these terms of service.

8. Governing Law

These terms and conditions are governed by and construed in accordance with the laws of Ontario and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location.

Updated: November 2021