Privacy Policy for dhpsychotherapy

At dhpsychotherapy we respect your privacy and are committed to protecting it through our compliance with this policy.

Your personal privacy is a very important part of our professional relationship. We will never disclose to anyone that you are a client, nor will we reveal the nature of content of your consultations without your consent/permission. There are however some rare situations in which we may be required to disclose some personal information. These exceptions are:

            There is an imminent risk to you or to someone else

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

            Our records are subpoenaed by the court

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

            Our clinical records may be reviewed by the College of Psychotherapist of Ontario for quality assurance or by Revenue Canada. In these cases, your information will be still kept confidential.

What is personal information?

Personal information is information that can be used to identify a specific individual. This includes individual characteristics such as gender, age, income, home address, phone number, family status, ethic background etc. In addition to this health conditions, health history, services received as well as an individual’s activities and opinions such as religion, expressed opinions and evaluations.

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

Why 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, we 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 we 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 us 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, we can identify progress and changes that occur over time.  Rarely would we collect such information without a person’s consent, but this might occur in an emergency (e.g., the person is unconscious) or where we 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 we have no reason to believe that the message is not authentic.

On the dhpsychotherapy website, with the exception of cookies, we only collect the personal information you send to us and we only use that information for the purpose which you provided it such as responding to your email messages.

We 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.
• We are regulated by the College of Psychotherapists of Ontario. These regulatory bodies may inspect our 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 our files as a part of their mandates.  In these circumstances, we may consult with professionals (e.g., lawyers, accountants) to seek their advice.
• The fee for our psychological services may be paid for by third parties (e.g., Trust Life, RBC Insurance, SunLife and other private insurance companies).  These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.  If not, we will only disclose information to these third parties with your explicit written consent.
• In certain circumstances, we 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:

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

• The internet connection is private and trusted.
• Wireless internet connections are private and password-protected.
• Devices (computers, smartphones, laptops, tablets, etc.) are password protected and encrypted.
• Software security updates are performed regularly.
• Security scans are performed routinely to identify and eliminate viruses, malware, spyware, etc.
• Video Conferencing – we only use platforms that encrypt transmitted information and provide unique access codes for each client.
• 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.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Written Communications transmit information using secure methods (e.g. password protected or 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:

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

We keep client files for a minimum of ten years.  However, in the case of clients who are minors, we retain their file for at least ten years after they reach the age of majority (19 years of age).  We destroy paper files containing personal information by shredding.  We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.  Alternatively, we 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 our clinical files – all you have to do is ask.  We can help you identify what records we might have concerning you, and help you understand any information you do not understand (e.g., short forms, technical language, etc.).

We may ask you to put your request in writing to confirm your identity, before providing you with this access.  If we cannot give you access to certain information, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why access cannot be given.  We 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 we may have formed. Where the Psychotherapist agrees that a correction is required, they will make the correction and with your written consent, the therapist will notify anyone to whom we sent this information.  If the Psychotherapist does not agree a correction is required, the therapist will nevertheless include in your file a brief statement from you regarding this issue and, with your written consent we 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 dhpsychotherapy.

If you wish to make a formal complaint about dhpsychotheapy privacy practices or if you have a concern about the professionalism or competence of dhpsychotherapy services you are entitled to complain to the College of Psychotherapists of Ontario.

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 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 Privacy Commissioner can be reached at:  Place de Ville, Tower B, 7th Floor – 112 Kent Street, Ottawa, Ontario K1A 1H3. Phone (613) 995-8210 | 800-282-1376 | Fax (613) 947-6850 | TTY (613) 992-9190. www.priv.gc.ca