The protection of personal information is very important to me. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary in the context of the services I provide to you. I strive to be open and transparent about how I handle personal information. This document, which has been drafted to comply with Quebec’s Act respecting the protection of personal information in the private sector and Canada’s Personal Health Information Protection Act, describes my privacy policies regarding the protection of your personal information.
What is personal information?
Personal information is information about an identifiable individual, either directly or indirectly. It includes information relating to: personal characteristics (e.g., gender, age, income, home address or telephone number, ethnic origin, family status); health (e.g., medical history, health conditions, health services received by the individual); or, activities or opinions (e.g., values, beliefs, political aspirations, opinions expressed by an individual, current or past relationships). Personal information is different from business-related information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
Collection of personal health information
In order to serve my clients, I collect health-related information including their personal and family history, physical condition and functioning, as well as their social, personal and professional situation. The collection of personal information is done 1) to enable me to make informed clinical decisions regarding assessment and/or treatment; and 2) may include the monitoring of symptoms and/or distress levels to examine changes in psychosocial functioning during treatment.
I collect your personal health information directly from you, except: a) when you have given me your consent to obtain this information from another person (e.g., reports from previous assessments or other services); and b) where the law requires or permits me to collect this information without your consent (e.g., in an emergency situation, when the information is necessary to prevent potential harm or injury).
I only collect information from you that you believe is reasonably necessary to provide you with services. If you decide that you do not want to provide me with additional information that is not necessary for your services, you may decline and there will be no impact on the services you receive.
In addition, I collect, use and disclose personal information for certain secondary purposes in the following examples:
- To issue receipts for services received or to bill for services that have not been paid on time, or to collect unpaid invoices.
- As I am regulated by the College of Psychologists of Ontario (CPO) and the Ordre des Psychologues du Québec (OPQ) as a registered psychologist, these professional associations may audit certain files as part of my regulatory activities in the public interest. These professional orders have their own strict privacy protection obligations.
- The costs of the services (or part of the services) provided are sometimes paid by a third party (e.g., motor vehicle accident insurance, lawyers, private rehabilitation companies, disability insurance companies). Third-party payers often have your consent or legislative authority to compel me to disclose certain information to them for the purpose of demonstrating the client’s entitlement to compensation funds.
Website navigation
When you browse this website, your IP address and certain related information (such as Internet browser or operating system used, time spent on the website, usage patterns) are automatically collected on my hosting platform (WordPress). This personal information is collected by means of cookies, pixels, server logs and other similar technologies, and is used to enable me to evaluate and improve your browsing experience, as well as to produce relevant content. When you complete the contact form available on the home page, I will collect your full name and e-mail address to enable me to communicate with you and respond to your inquiry. At any time, you can use the private browsing option to avoid receiving cookies. You can also reset your browsing history, which will remove cookies associated with this site.
Protection of personal information
I value the protection of personal information and consider my role in meeting this obligation to be essential to preserving your trust. The following safeguards are in place to protect personal health information:
- Paper-based information is either supervised, secured in a locked area with restricted access, or securely destroyed after use.
- Electronic equipment is either supervised or secured in a locked area with restricted access at all times. In addition, passwords are used on computers.
Information on paper is sent in sealed, addressed envelopes or in boxes from reputable companies. - Electronic information is either transmitted over a direct line or encrypted.
- I use a secure and encrypted electronic record system powered by OWL Practice Inc. to manage and store your personal (e.g., name, date of birth, address and email) and health information (e.g., session notes, reports and other documents associated with your care), as well as to optimize the coordination of my services (e.g., billing, payment, telepsychology, messaging). The OWL Practice Inc. platform complies with the Personal Health Information Protection Act (PHIPA). All personal information contained in your electronic file is encrypted at bank level (SSL) and multiple layers of security are used to ensure the protection of your personal information. To view OWL Practice’s privacy policy, please visit: https://owlpractice.ca/privacy-policy/
- Following the opening of your electronic file, you will have access to your client portal through the OWL Practice Inc. platform. The client portal will allow you to securely view your invoices and receipts, participate in teletherapy, and communicate with me via e-mail. Please limit the use of e-mail, whether through the OWL platform or not, to the exchange of logistical information (e.g., scheduling appointments and/or sending invoices or payment receipts) and omit the transmission of personal and clinical information, as e-mail is not a safe and secure means of correspondence.
Limits to the protection of personal information
Limits to the protection of personal information include, as stipulated in the limits to confidentiality to which you consented in the consent form at the beginning of our collaboration:
- Legally mandated disclosure to the Children’s Aid Society (Ontario) or the Direction de la protection de la jeunesse (Québec); Mandatory reporting of a health care professional who has sexually abused his or her patients or clients to his or her regulatory College; and Legally mandated reporting to the Director of the Ministry of Health and Long-Term Care or Registrar of the Office of retirement homes’ regulation.
- Mandates to disclose information required by the College of Psychologists of Ontario, the Ordre des Psychologues du Québec or the courts, search warrants for criminal or legal cases, and subpoenas.
By consenting to the disclosure of your personal health information, you may restrict me from sharing all or part of your personal information. However, if, in my opinion, the information is reasonably necessary for another health service provider to provide you with appropriate services, I am required by law to inform that other provider that you have refused to consent to the disclosure of certain essential information.
While the law permits access to personally identifiable health information for research purposes under strict conditions, my policy does not permit outside researchers to have access to information that can be identified as belonging to you, unless you consent to such access.
Disclosure of personal information
Credit card payments are handled by Stripe’s secure platform, integrated into the secure portal of your electronic file, powered by OWL Practice Inc. When you select this payment method, your financial information is shared with Stripe in order to process and administer your payment. Once the financial information is in your file, it is kept there (without making the credit card number accessible) to enable me to process and administer your future payments or refunds. Stripe operates under the regulations known as PCI Compliance (Payment Card Industry Compliance) to securely protect your credit information. For more information, please consult the following link: https://faq.owlpractice.ca/integrated-payments/pci-compliance
Your right to access your personal health information
With very few exceptions, you have the right to access any of your personal health information files, and to request copies of this information (note: administration fees may apply). If you believe the information in your file is inaccurate or incomplete, you can make a written request to have your file corrected. If I do not agree with the corrections requested, you may complete a notice of disagreement, which will be added to your file.
Retention and destruction of personal information
I am required to retain personal information for a period of time to ensure that I can respond to any questions you may have regarding the services I have provided and for my own accountability to external regulatory bodies. To protect your confidentiality, I do not retain personal information longer than is required by the College of Psychologists of Ontario and the Ordre des psychologues du Québec. Thus, my clients’ files are kept for ten (10) years following the end of services. Paper files containing personal information are destroyed by shredding while electronic information is deleted and, where I have computer equipment, I ensure that the hard drive is physically destroyed.
Do you have any concerns?
At any time, if you would like more detailed information, if you would like to access or request a correction to your file, if you have a question or concern about my privacy policies and procedures, or if you would like to express a complaint about the way your privacy has been handled, please feel free to talk or write to me.
If I am unable to reassure you or address your concerns, you have the right to contact my regulatory body as well as the competent authorities for the protection of personal information:
College of Psychologists of Ontario
Tel: 416.961.8817 | 1.800.489.8388 |
Fax: 416.961.2635
L’Ordre des Psychologues du Québec
Tel: 514.738.1881 | 1.800.363.2644 |
Fax: 514.738.8838
For general privacy inquiries, please contact:
Privacy Commissioner of Canada
Tel: 613.947.1698 | 1.800.282.1376 | ATS: 613.922.9190 | Fax: 613.947.6850
Privacy Commissioner of Ontario
Tel: 416.326.3333 | 1.800.387.0073 | ATS: 416.325.7539 | Fax: 416.325.9195
