We are committed to protecting and respecting your privacy, which means that we collect, use, and disclose your personal information responsibly and only to the extent necessary for the services we provide. This document describes our policies, as well as how you can access your records and request correction of recorded personal information.
What is Personal Information?
Personal information is information about an identifiable individual. It includes information that relates to an individual’s personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status); health (e.g., health history, health conditions, health services delivered to them), activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information and specifically personal health information is protected by privacy legislation (i.e., the Personal Health Information Protection Act [PHIPA]), and is different from business information (e.g., an individual’s business address and phone number), which is not protected by privacy legislation.
Who We Are
We are a group of mental health professionals with various designations (including psychologists, psychotherapists, and social workers) in private practice. We use third party agencies and consultants that may, in the course of their duties, have minimal access to personal information. We have professional relationships with third party service providers to provide the following services: practice management software, credit card billing, accounting, and legal services. We restrict their access to any personal information as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
Collection of Your Personal Health Information
The primary purpose of collecting your personal and health information is to deliver appropriate psychological services, contact you for service-related reasons, and prevent harm (such as reaching an emergency contact). Information from you will not be collected for any other purpose (such as conducting research) without first obtaining your informed consent. If you do not want to provide consent for the collection of this latter kind of information, you are free to refuse and there will be no impact on your services.
Personal health information will be collected directly from you, except when you have provided consent to collect such information from others (such as a spouse, family physician, or mental health professional with whom you have previously worked), when others provide this information permitted under the Personal Health Information Protection Act (2004), or when the law requires the collection of such information without your consent (such as emergency situations where the purpose of collecting information is to prevent potential harm).
By law and in accordance with professional standards, we are required to keep a record of contact with and services to you. Your record includes information that you have provided to us or have authorized us to receive, such as consent forms, session notes, results of any assessments, billing information, contact records, and correspondence that we have sent to or received relating to your services. The records are the property of Bloor West Therapy; however, you have rights regarding access to and disclosure from your record, regardless of the form in which information is recorded. In this office, information is recorded in both written and electronic form.
Members of the general public
For members of the general public, the primary purpose for collecting personal information is to communicate about services provided. For example, we might collect phone numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.
Use of Your Personal Health Information
Like most organizations, we also obtain, collect, and disclose personal information for purposes related to or secondary to the primary purpose of providing psychological services. The following are some examples:
- To invoice for services, to process credit card payments, or to collect unpaid accounts.
- To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service) that are available.
- The College of Psychologists of Ontario may inspect records and interview practitioners as part of their regulatory activities in the public interest. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review files and interview practitioners as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
- The cost of some services provided to clients is paid for by third parties (e.g., WSIB, private insurance). 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.
- Clients may have questions about services after they have been received.
Clients can choose to opt out from some of these related or secondary purposes (e.g. declining to receive notice of special events, paying for services in advance, etc.). They do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
Disclosure of Your Personal Health Information
With few exceptions, your personal health information will not be disclosed to people outside of this practice without your knowledge and express consent. Written consent is always preferred; however in time-sensitive situations if you provide verbal consent to share information, written consent can be obtained in our next meeting. The exceptions are:
- Situations where disclosure without consent is allowed by law (e.g., clear and imminent risk of serious bodily harm to someone, or professional or legal consultation).
- Situations where disclosure is required by law (such as the mandatory reporting of a child who may be in need of protection, mandatory reporting of a regulated health professional who has sexually abused a client, or a court order to release information from a record).
If other limits of confidentiality apply to your situation, they will be identified and discussed with you before proceeding with your service.
When providing consent to the disclosure of your personal health information, you may restrict the information that we do share (with the exceptions noted above). If, however, it is our opinion that the information you wish to restrict is reasonably necessary for another health service provider to provide appropriate services, we are required by law to inform the other provider that you have refused consent to provide some needed information.
The law requires that any disclosure of your personal health information is limited to information that is reasonably necessary for the purpose of that disclosure and does not include private information provided by a third party. Professional ethical standards governing our practice also require that we not disclose any information that might cause serious harm to someone, unless the law requires disclosure.
Protection of Your Personal Health Information
Please be advised that all personal information is kept confidential through the use of established protocols. The following steps are taken to ensure confidentiality of clients:
- 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. In addition, passwords are used on computers.
- 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.
Retention of Your Personal Health Information
We are required by our professional regulatory bodies to retain clients’ records for at least 10 years beyond the date of last contact. We also need to retain personal health information to ensure that we can answer any queries that clients may have about services provided. However, clients may request to remove certain contact information upon termination of services. We ensure that all paper records are destroyed by cross-cut shredding. Electronic information is destroyed by deleting it and, when hardware is discarded, the hard drive is physically destroyed. Alternatively, we may send some or all of the client file to the client.
Your Access to Your Personal Health Information
With only a few exceptions, you have the right to see your personal information in our records by contacting Bloor West Therapy. We can help you identify what records we might have about you, and will also try to assist you in understanding any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity prior to providing you accesses of any personal information. We reserve the right to charge a nominal fee for such requests. If the record contains personal health information about another individual, that person’s information must be removed before you access the record. Other exceptions include access to raw data from psychological assessments, information provided in confidence by a third party, and information that could result in serious harm to someone’s treatment or recovery (including your own) or in serious bodily harm to someone (including yourself).
If you are the custodial parent or guardian of an adolescent under the age of 18 years who has received or is receiving service, you may not access the personal health information of that adolescent unless (a) s/he has provided written consent for you to access such information, or (b) s/he has been deemed incompetent to consent to the service on her or his own.
You may be asked to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
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. You may be asked to provide documentation that files are wrong. Where we agree that a mistake was made, we will make the correction and notify anyone to whom we sent this information. If we do not agree that a mistake was made, we will still agree to include in the file a brief statement from you and will forward that statement to anyone else who received the earlier information.
Do You Have Questions or Concerns?
These privacy policies and procedures have been developed in accordance with the laws of Ontario, as well as professional regulations and ethical standards. Further details regarding the applicable laws, regulations, and ethical standards may be found at the websites of the Ontario Ministry of Health and Long Term Care (www.health.gov.on.ca), The College of Psychologists of Ontario (www.cpo.on.ca), and the Canadian Psychological Association (www.cpa.ca).
Bloor West Therapy’s Privacy Officer, Dr. Katerina Malat, will answer any questions or concerns you may have regarding privacy practices or limits of confidentiality. If you have a concern about these privacy policies or have a complaint about how your privacy has been handled, please speak or write to us.
If you have a concern about the professionalism or competence of our services, we would ask you to discuss these concerns with us. However, if we cannot satisfy your concerns, you are entitled to contact the regulatory body that oversees our practice:
The College of Psychologists of Ontario, at:
110 Eglinton Avenue West, Suite 500
Toronto, Ontario M4R 1A3
Tel: (416) 961-8817 | (800) 489-8388 | Fax (416) 961-2635
This policy is made under the Personal Information Protection and Electronic Documents Act
(PIPEDA) and the Personal Health Information Protection Act (PHIPA).
For more general inquiries, the Information and Privacy Commissioner of Ontario oversees the administration of the privacy legislation. The Commissioner also acts as a kind of ombudsperson for privacy disputes. The Information and Privacy Commissioner can be reached at:
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
416-326-3333 or 800-387-0073| Fax: 416-325-9195| TTY: 416-325-7539 | www.ipc.on.ca