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Privacy Policy

 

Privacy Policy
 

The privacy of your personal information is very important.  As a regulated health care provider and clinical psychologist, I collect, use and disclose personal information responsibly and only to the extent necessary for the psychological services I provide.   I am open and transparent as to how I deal with personal information.  This document describes my privacy policies.

Your personal privacy is a very important part of our professional relationship.  I will never disclose to anyone that you are my client, nor will I reveal the nature or content of your consultations with me without your express and specific written permission.  However, there are some rare situations in which I may be required to disclose some of your personal information.

These exceptions are:

      1. There is an imminent risk you will seriously harm yourself or someone else.

      2. There is a child who is, or is at risk of, being abused or neglected.

      3. My records are subpoenaed by the court.

      4. I learn that you were sexually abused or harassed by a regulated health care provider.

Also, my clinical records may be reviewed by the Ordre des Psychologues du Québec, the College of Psychologists of Ontario, or the College of Psychologists of British Columbia for quality assurance or by Revenue Canada or Revenue Québec. In these cases, your information would still be kept confidential.


What is personal information?

Personal information is information about an identifiable individual.  It includes information pertaining to a person’s:

a. Individual characteristics - gender, age, income, home address or phone number, ethnic background, family status, etc.
b. Health - health history, health conditions, health services received by them
c. Activities and opinions - religion, politics, expressed opinions and evaluations

Personal information is different from business information such as individual’s business address and telephone number). This information is not protected by privacy legislation.


Why does a psychologist collect personal information?


The primary purpose for collecting, using, and disclosing personal information is to provide you with counselling and psychological services.  In order to provide these professional services, I obtain information about a client’s physical, emotional, family, sexual, social, school, and work history in order to assess what their clinical needs are so that I can inform them of their options and alternatives and then to provide the psychological health care they choose to receive.  A client’s personal information also enables me to assess a starting point or baseline level of their physical and psychological wellbeing so that over the course of providing counselling and psychological services, I can identify progress and changes that occur over time.  Rarely would I collect such information without a person’s consent, but this might occur in an emergency (e.g., the person is unconscious) or where I believe the client would consent if he or she were asked but it is impractical to obtain consent.  For example, a family member may pass on a message on from a client and I have no reason to believe that the message is not authentic.

On my website, with the exception of cookies, I only collect the personal information you send to me and I only use that information for the purpose which you provided it such as responding to your email message).

I also collect, use and disclose information for purposes related to or secondary to these primary purposes. The most common examples of related and secondary purposes are as follows:

  • To invoice clients for psychological services or to collect unpaid accounts.
  • I am regulated by the Ordre des Psychologues du Québec, the College of Psychologists of Ontario, and the College of Psychologists of British Columbia. These regulatory bodies may inspect my records as part of their responsibilities in the public interest.
  • Like all organizations, various government agencies (e.g., Revenue Canada, Information and Privacy Commissioner, Human Rights Commission, etc.) have the legal authority to review my files as a part of their mandates.  In these circumstances, I may consult with professionals (e.g., lawyers, accountants) to seek their advice.
  • The fee for my psychological services may be paid for by third parties (e.g., Blue Cross, Great West Life, SunLife, SAAQ, and other private insurance companies).  These third-party payers often have your consent or legislative authority to direct me to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.  If not, I will only disclose information to these third parties with your explicit written consent.
  • In certain circumstances, I may disclose some information to professionals such as lawyers and accountants.  In these cases, these professionals have their own privacy policies.


Protecting your personal information:

I understand the importance of protecting personal information.  For that reason, I have taken the following steps:

  • Paper information is either under supervision or secured in a locked or restricted area.
  • Electronic hardware is either under supervision or secured in a locked or restricted area at all times.
  • Passwords are used on all my computers.
  • My cell phones are digital as these signals are more difficult to intercept.
  • Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
  • Electronic information is transmitted either through a direct line or has identifiers removed or is encrypted.
  • Any external consultants and agencies with access to clients’ personal information must enter into privacy agreements with me.


Retention and destruction of personal information:

I need to retain personal information for some time to ensure that I can answer any questions you might have about the psychological services I provided and for my own accountability to external regulatory bodies.

I keep my client files for a minimum of ten years.  However, in the case of clients who are minors, I retain their file for at least ten years after they reach the age of majority (19 years of age).  I destroy paper files containing personal information by shredding.  I destroy electronic information by deleting it and, when the hardware is discarded, I ensure that the hard drive is physically destroyed.  Alternatively, I may send some, or all of the client file to a client.


You can review your personal information:

With only a few exceptions, you have the right to see the personal information about you that is in my clinical files – all you have to do is ask me.  I can help you identify what records I might have concerning you, and help you understand any information you do not understand (e.g., short forms, technical language, etc.).

I may ask you to put your request in writing to confirm your identity, before providing you with this access.  If I cannot give you access to certain information, I will tell you within 30 days if at all possible and tell you the reason, as best I can, as to why access cannot be given.  I reserve the right to charge a nominal fee for such requests.

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 I may have formed. Where I agree that a correction is required, I will make the correction and with your written consent, I will notify anyone to whom I sent this information.  If I do not agree a correction is required, I will nevertheless include in my file a brief statement from you regarding this issue and, with your written consent I will forward that statement to anyone else who received the earlier information.


Questions, concerns, or complaints:

Please feel free to discuss any questions, concerns or complaints you may have with me.

If you wish to make a formal complaint about my privacy practices or if you have a concern about the professionalism or competence of my services you are entitled to complain to the following regulatory bodies: the Ordre des Psychologues du Québec, the College of Psychologists of Ontario, or the College of Psychologists of British Columbia.

This policy is made under the Personal Information Protection and Electronic Documents Act.  That 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 Commissioner 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 Commissioner can be reached at: 112 Kent Street, Ottawa, Ontario K1A 1H3. Phone (613) 995-8210 | 800-282-1376 | Fax (613) 947-6850 | TTY (613) 992-9190.
www.privcom.gc.ca