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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. 1. There is an imminent risk you will seriously harm
yourself or someone else.
2. 2. There is a child who is, or is at risk of, being
abused or neglected.
3. 3. My records are subpoenaed by the court.
4. 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:
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To invoice
clients for psychological services or to collect unpaid
accounts.
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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.
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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.
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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.
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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:
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Paper
information is either under supervision or secured in a
locked or restricted area.
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Electronic
hardware is either under supervision or secured in a
locked or restricted area at all times.
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Passwords
are used on all my computers.
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My cell
phones are digital as these signals are more difficult
to intercept.
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Paper
information is transmitted through sealed, addressed
envelopes or boxes by reputable companies.
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Electronic
information is transmitted either through a direct line
or has identifiers removed or is encrypted.
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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 |