Privacy Statement

We are committed to respecting and protecting your privacy.

This statement outlines our policies and procedures with respect to collecting, using, and disclosing your personal health information. It also provides information about how you can access records of your personal health information and request correction of recorded information.

      1. Definition of “Personal Health Information”

The practice of psychology and psychotherapy in Ontario is regulated under the provincial Regulated Health Professions Act (RHPA).

All identifiable information collected by our clinicians about an individual, in the course of practicing psychology / psychotherapy, is considered personal health information under the Personal Health Information Protection Act (PHIPA, 2004).

This includes your name and contact information, as well as any information collected/recorded in the course of providing services to you.

      2. Collection of Your Personal Health Information

We collect your personal health information directly from you only, except:

  • when you have provided consent to obtain such information from other (e.g., reports of previous assessments or of other services); or
  • where the law requires or allows us to collect information without your consent (e.g., in an urgent situation, when information is needed to prevent potential harm).

We collect only information from you that we believe is needed:

  • to provide you with the services you have requested and/or for which you have been referred;
  • to maintain contact with you for service-related or future consent purposes;
  • to prevent or offset harm (e.g., asking for an emergency contact).

If we collect information from you for research, it will be done only with your informed consent (see separate consent for this purpose). The collection of your information is in accordance with the PHIPA regulations.

By law and in accordance with professional standards, we are required to keep a record of services provided to you and of contacts with you. Your record includes information you provide or authorize us to receive, results for any assessments, your service plan, consent forms, contact notes, progress summaries, billing information, and correspondence that we have sent or received related to your service. You have the rights regarding access to your record and regarding disclosure of information from your record (see below), regardless of the form in which the information is recorded.

      3. Use of Your Personal Health Information

Your personal health information is used to provide services to you. This includes all activities reasonably necessary for that purpose, such as treatment planning, services monitoring, maintaining your record, billing, etc.

Other individuals may have limited access to your personal health information in the course of their duties. These may include interns, IT consultants, bookkeepers, accountants, and credit card companies or banks. All such individuals are trained in privacy and confidentiality requirements and are allowed access only to the information necessary to perform their role (“need-to-know” basis).
Paper files and electronic hardware are either supervised or secured in restricted areas at all times. Computers are password-protected, encrypted, and stored in secure, access-controlled environments. Electronic records are backed up regularly and stored on secure Canadian servers.

      4. Disclosure of Your Personal Health Information

With limited exceptions, your personal health information will not be disclosed to persons outside this office without your knowledge and express consent.
The exceptions—referred to as limits of confidentiality—are circumstances where disclosure is required or permitted by law, such as:

  • When there is a clear and imminent risk of serious bodily harm to someone, including the possibility of self-harm.
  • When disclosure is needed to receive professional or legal consultation.
  • For mandatory reporting of a child who might be in need of protection.
  • For mandatory reporting of a regulated health professional who has sexually abused a client.
  • In compliance with a court order to release information from a record.
  • To fulfill obligations under the Regulate Health Professions Act (RHPA) for quality assurance or regulatory review by:
    • The College of Psychologists and Behaviour Analysts of Ontario (CPBAO), or
    • The College of Registered Psychotherapists of Ontario (CRPO)who may inspect records and interview staff as a part of their regulatory activities (e.g. quality assurance) in the public interest.
  • To support a legal defense if required.

5. Disclosure to Insurers, Assistance Programs, and Third-Party Payers

Clients — or the parents or guardians of clients — agree to provide permission, when applicable, for us to communicate with insurance companies, employee assistance programs, credit card companies, or other third-party payers only as needed to confirm payment or reimbursement details.
The information disclosed will be strictly limited to:

  • the date and time of sessions,
  • the amount paid or invoiced,
  • the names and number of participants (if applicable), and
  • the name of the clinician providing the service.

No clinical details, assessment results, diagnoses, or other personal health information will be released without explicit written consent, unless required by law.

All persons involved in these activities are required by law to maintain the confidentiality of any accessed information. The above exceptions are called “limits of confidentiality”. If there are other limits of confidentiality in your situation, we will identify and discuss them with you before proceeding with your service.

Please note that the law requires any disclosure of your personal health information to be limited to information that is reasonably necessary for the purposes of the disclosure, and not to include private information provided by a third party, unless you are involved in an open mediation or custody/access assessment. Professional ethical standards additionally require that any information that might cause serious harm to someone not be disclosed, unless the law requires disclosure.

When consenting to the disclosure of your personal health information to another healthcare professional, who is providing services to you, you may restrict us from sharing all or any part of your personal information. However, if in our opinion the information is reasonably necessary for an-other health service provider to provide appropriate service, we are required by law to inform the other provider that you have refused consent to provide some needed information.

      6. Retention and Destruction of Personal Information

In accordance with professional standards, clinical records are retained for at least ten (10) years after the date of the last contact, or for ten (10) years after a minor client reaches the age of 18, whichever is later.
Records may be retained longer if required for legal or administrative purposes (e.g., ongoing litigation or pending access requests). When records are destroyed, they are securely shredded (for paper) or permanently deleted (for electronic data) in a manner that prevents recovery.

      7. Your Right of Access to Your Personal Health Information Record

With few exceptions, you have the right to access any record of your personal health information, and to request copies of the information. If the record contains personal health information about another individual, that individual’s information must be able to be severed from the record before you may access the record. Because of the nature of certain services, severing information in some, not all places of the record can be difficult and at times impossible.

Exceptions may apply to:

  • copyrighted psychological test materials,
  • information provided in confidence by a third party, and
  •  information that could cause serious harm to someone’s treatment, recovery, or safety.

If you are custodial parent or guardian of a child receiving service, you may not access that child’s record without their consent, who was deemed competent and who consented to the service on his/her own. In addition, there are restrictions on custodial parents/guardians’ access to individual therapy notes regarding their children.

When you request access to your record:

  • We may need to verify your identity if significant time has passed since your last service..
  • We reserve the right to charge a nominal fee for such requests, including the cost of retrieving your file from a storage and separating out your information from those of other affected parties.
  • If we cannot give you access, we will tell you within 30 days, explaining the reason.

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 there is an error, we will make the correction and notify anyone to whom we have sent the incorrect information. If we do not agree that we have made an error, you may provide a notice of disagreement that will be included in the file and we will forward that notice to anyone else who received the earlier information.

      8. Concerns and Further Information

If you have questions, wish to access or correct your record, or have a concern about how your personal health information has been handled, please contact your clinician or our Privacy Officer.
If your concern is not resolved, you may contact the Information and Privacy Commissioner of Ontario:
Information and Privacy Commissioner of Ontario
80 Bloor Street West, Suite 1700
Toronto, Ontario M5S 2V1
Phone: (416) 326-3333
Website: www.ipc.on.ca
Email: commissioner@ipc.on.ca

9. Legal and Professional References

This Privacy Policy has been developed in accordance with.

Further information about Ontario health privacy laws is available from the Ontario Ministry of Health and Long-Term Care at www.health.gov.on.ca.