Privacy Policy
Privacy of person information is important. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services I provide. I try to be open and transparent as to how I handle personal information. Following is a description of my privacy policy.
What is personal information?
Personal information is information about an identifiable individual. Personal information includes information that relates to: an individual’s personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status); health (e.g. health history, health conditions, health services received by them); or, activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).
Personal information is different from business information (e.g. an individual’s business address and telephone number). This is not protected by privacy legislation.
Purposes of collecting personal information:
Primary Purposes:
Like all psychotherapists, I collect, use and disclose personal information in order to serve my clients. My primary purpose for collecting personal information is to provide psychotherapy treatment. For example, I collect information about a client’s history, including their family history, health history, emotional state, physical condition and function, and social situation, in order to help me assess what their counselling needs are, to advise them of their options and then to provide the counselling mutually agreed upon. A second primary purpose is to obtain a baseline of psychological functioning so that, as counselling progresses, we can identify changes that occur over time.
It would be rare for me to collect personal information without the client’s express consent, but this might occur in an emergency (e.g. the client is unconscious) or where I believe the client would consent if asked but it is impractical to obtain consent (e.g. a family member passing a message on from a client, when I have no reason to believe that the message is not genuine).
Secondary Purposes:
The most common examples of related or secondary purposes include:
To invoice clients for services that were not paid for at the time, or to collect unpaid accounts.
In the process of supervision by a registered psychologist (which enables me to offer services for which clients can access their health insurance).
To monitor the professional work of therapists, external regulators (in my case, the Ontario Association for Marriage and Family Therapy, and the Canadian Counseling Association) may inspect client records as part of their mandate to serve the interest of the public.
To address reported cases of serious misconduct, incompetence or incapacity of other practitioners by notifying the appropriate regulatory body. Clients will always be asked to give written consent for any disclosure of personal information in this type of situation.
To report information suggestion serious illegal behaviour to the authorities.
To respond to the requirements of government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc) who have the authority to review my records as a part of their mandates. In these circumstances, I may consult with professionals (e.g. lawyers, accountants) who will advise me in situations of conflicting rights and obligations.
To communicate with third-parties who pay for some services (e.g. private insurance companies). These third-party payers often have the client’s consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate entitlement to funding.
Although a client may choose not to be part of some of these related or secondary purposes, I do not have much choice but to comply with many of these secondary or related purposes (e.g. external regulation). However, it has been my experience that such requests for information are rare.
Protecting Personal Information
I understand the importance of protecting personal information. For that reason, I have taken the following steps:
Paper information is secured in a locked or restricted area
Electronic hardware is secured in a locked or restricted area at all times.
Paper information is transmitted through sealed addressed envelopes.
Electronic information is transmitted only through a direct line
Retention and Destruction of Personal Information
I need to retain personal information for some time to ensure that I can answer any questions a client might have about the services provided, and for my own accountability to external regulatory bodies. I keep my client files for a minimum of ten years after the last contact.
However, I do not want to keep personal information too long, in order to protect client privacy. I destroy paper files containing information by shredding. I destroy electronic information by deleting it.
Access to Your Personal Information
With only a few exceptions, clients have the right to access personal information held by me. Often all the client need do is ask. If clients wish to have access to their clinical files, they will need to make a written request, which can then be included in the file. Because there is a possibility that information in clients’ clinical files may be distressing to them, or complex, I will review the file with the client in person. The fee for this service will be agreed beforehand.
If clients believes there is a mistake in the information in their records, they have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions I may have formed. I would ask the client to provide documentation of the specific inaccuracy in the file. Where we have agreed that there is a mistake, I will make the correction, and notify anyone to whom I sent this information. If we do not agree that I have made a mistake, I will still agree to include in the client’s file a brief statement from them on the point and I will forward that statement to anyone else who received the earlier information.
Do You Have a Question?
If you have a concern about my professionalism or competence, I would hope that you would share that concern with me. However, If I cannot satisfy your concerns, you are entitled to complain to the Ontario Association for Marriage and Family Therapists.
This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA) effective January 1, 2004. This is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Information and Privacy Commission of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commission can be reached at:
112 Kent Street
Ottawa, Ontario, K1A 1H3
Phone (613) 995-8210
Fax (613) 947-6850
http://www.privcom.gc.ca (link)
Privacy of person information is important. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services I provide. I try to be open and transparent as to how I handle personal information. Following is a description of my privacy policy.
What is personal information?
Personal information is information about an identifiable individual. Personal information includes information that relates to: an individual’s personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status); health (e.g. health history, health conditions, health services received by them); or, activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).
Personal information is different from business information (e.g. an individual’s business address and telephone number). This is not protected by privacy legislation.
Purposes of collecting personal information:
Primary Purposes:
Like all psychotherapists, I collect, use and disclose personal information in order to serve my clients. My primary purpose for collecting personal information is to provide psychotherapy treatment. For example, I collect information about a client’s history, including their family history, health history, emotional state, physical condition and function, and social situation, in order to help me assess what their counselling needs are, to advise them of their options and then to provide the counselling mutually agreed upon. A second primary purpose is to obtain a baseline of psychological functioning so that, as counselling progresses, we can identify changes that occur over time.
It would be rare for me to collect personal information without the client’s express consent, but this might occur in an emergency (e.g. the client is unconscious) or where I believe the client would consent if asked but it is impractical to obtain consent (e.g. a family member passing a message on from a client, when I have no reason to believe that the message is not genuine).
Secondary Purposes:
The most common examples of related or secondary purposes include:
To invoice clients for services that were not paid for at the time, or to collect unpaid accounts.
In the process of supervision by a registered psychologist (which enables me to offer services for which clients can access their health insurance).
To monitor the professional work of therapists, external regulators (in my case, the Ontario Association for Marriage and Family Therapy, and the Canadian Counseling Association) may inspect client records as part of their mandate to serve the interest of the public.
To address reported cases of serious misconduct, incompetence or incapacity of other practitioners by notifying the appropriate regulatory body. Clients will always be asked to give written consent for any disclosure of personal information in this type of situation.
To report information suggestion serious illegal behaviour to the authorities.
To respond to the requirements of government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc) who have the authority to review my records as a part of their mandates. In these circumstances, I may consult with professionals (e.g. lawyers, accountants) who will advise me in situations of conflicting rights and obligations.
To communicate with third-parties who pay for some services (e.g. private insurance companies). These third-party payers often have the client’s consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate entitlement to funding.
Although a client may choose not to be part of some of these related or secondary purposes, I do not have much choice but to comply with many of these secondary or related purposes (e.g. external regulation). However, it has been my experience that such requests for information are rare.
Protecting Personal Information
I understand the importance of protecting personal information. For that reason, I have taken the following steps:
Paper information is secured in a locked or restricted area
Electronic hardware is secured in a locked or restricted area at all times.
Paper information is transmitted through sealed addressed envelopes.
Electronic information is transmitted only through a direct line
Retention and Destruction of Personal Information
I need to retain personal information for some time to ensure that I can answer any questions a client might have about the services provided, and for my own accountability to external regulatory bodies. I keep my client files for a minimum of ten years after the last contact.
However, I do not want to keep personal information too long, in order to protect client privacy. I destroy paper files containing information by shredding. I destroy electronic information by deleting it.
Access to Your Personal Information
With only a few exceptions, clients have the right to access personal information held by me. Often all the client need do is ask. If clients wish to have access to their clinical files, they will need to make a written request, which can then be included in the file. Because there is a possibility that information in clients’ clinical files may be distressing to them, or complex, I will review the file with the client in person. The fee for this service will be agreed beforehand.
If clients believes there is a mistake in the information in their records, they have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions I may have formed. I would ask the client to provide documentation of the specific inaccuracy in the file. Where we have agreed that there is a mistake, I will make the correction, and notify anyone to whom I sent this information. If we do not agree that I have made a mistake, I will still agree to include in the client’s file a brief statement from them on the point and I will forward that statement to anyone else who received the earlier information.
Do You Have a Question?
If you have a concern about my professionalism or competence, I would hope that you would share that concern with me. However, If I cannot satisfy your concerns, you are entitled to complain to the Ontario Association for Marriage and Family Therapists.
This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA) effective January 1, 2004. This is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Information and Privacy Commission of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commission can be reached at:
112 Kent Street
Ottawa, Ontario, K1A 1H3
Phone (613) 995-8210
Fax (613) 947-6850
http://www.privcom.gc.ca (link)