Privacy Policy

Privacy and confidentiality are the cornerstone of a therapeutic relationship. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services I provide. This document describes my privacy policies.

What is Personal Information?

Personal information is information about an identifiable individual.  Personal information 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 received); or, activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).  

Who I Am? 

I am a registered psychotherapist in Ontario (certificate number 6866).  I am seeing you in a solo private practice capacity (i.e., not as an employee of any other organization).

I Collect Personal Information: Primary Purposes

Like all psychotherapists, I collect, use and disclose personal information in order to serve my clients, for the purposes of counselling. I collect information about a client’s history, including family history, social situation and emotional functioning in order to help assess what clients’ counselling needs are, to advise them of their options and, should they chose, to provide therapy.  

I Collect Personal Information: Related and Secondary Purposes

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

1. I may invoice clients for services that were not paid for at the time, or to collect unpaid accounts.

2. Psychotherapists are regulated by the College of Registered Psychotherapists of Ontario who may inspect my records as a part of their regulatory activities in the public interest. In addition, as a professional, I will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or my own. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about my clients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canda customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review my files as a part of their mandates. In these circumstances, I may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to me. All persons involved in these activities are required by law to maintain the confidentiality of any accessed information.

3. Usually I do not deal directly with insurance companies—clients pay me and file for reimbursement themselves. I will on occasion be called by an insurance company to verify my practice information. As well the cost of some services may be paid for directly by third parties (e.g., private insurance). These third-party payers must have the client’s consent or legislative authority to direct me to collect and disclose to them certain information in order to demonstrate a client’s entitlement to this funding. 

4. Clients may have questions about my services at some point after the services have been received. I may provide intermittent service over a period of months or years for which previous records are helpful. I retain client information for a minimum of ten years after the last contact (or in the case of children 10 years after their 18th birthday) to enable me to respond to those questions and provide these services. (The regulatory College also requires me to retain my client records.)

Protecting Personal Information

I understand the importance of protecting personal information.  Records relating to all clients are confidential. In general this means that no information contained in records is provided to a third party without written consent of the client. There are some specific ethical or legal circumstances when this confidentiality requirement is waived. For example, clinicians shall reveal information when there is a suspicion of child abuse, when clients pose a significant danger to themselves or others, when clients report sexual abuse by a health care professional. In those instances I will inform you who the report was made to and what information I disclosed. I also disclose information when a court order demands records or testimony. In addition, I take the following precautions when storing or moving client information:

1. Paper information is either under supervision or secured in a locked or restricted area.

2. Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. In addition I use a secure electronic records management system (OWL) that is protected by appropriate security measures (e.g., PHIPA-compliant software that includes bank-level encryption)   

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 services provided and for my own accountability to external regulatory bodies. I am required to keep my client files for 10 years.  I destroy paper files containing personal information by shredding.  I destroy electronic information (which is password protected) by deleting it and, before hardware is discarded, I ensure that the hard drive is physically destroyed or completely rewritten (secure/unrecoverable erasure).

You Can Look at Your Information

With only a few exceptions, you have the right to see what personal information I hold about you.  Often all you have to do is ask.   I can help you identify what records I might have about you.  I will also try to help you understand any information you do not understand (e.g., abbreviations, technical language, etc.).  I will need to confirm your identity, if I do not know you, before providing you with this access.  I reserve the right to charge a nominal fee for such requests. If there is a problem, I may ask you to put your request in writing.  If I cannot give you access, I will tell you within 30 days if at all possible and tell you the reason, as best I can, as to why I 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 I may have formed.  I may ask you to provide documentation that my files are wrong.  Where I agree that I made a mistake, I will make the correction and notify anyone to whom I sent this information.  If I do not agree that I have made a mistake, I will agree to include in my file a brief statement from you on the point and I will forward that statement to anyone else who received the earlier information.

Do You Have a Concern?

If you have been a client of mine and have questions about your personal information, you may contact me. I can be reached at:

Sarah Sweeney

Phone 613-285-6206

If you wish to make a formal complaint about my privacy practices, you may make it in writing to me, as my Information Officer. I will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal written decision with reasons.

If you have a concern about the professionalism or competence of my services I would ask you to discuss those concerns with me.  However, if I cannot satisfy your concerns, you are entitled to complain to my clinical supervisors or/and to my regulatory body:

The College of Registered Psychotherapists of Ontario
www.crpo.ca

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:

Information and Privacy Commissioner
112 Kent Street
Ottawa, Ontario  K1A 1H3
Phone: (613) 995-8210 | (800) 282-1376 | TTY (613) 922-9190 | Fax (613) 947-6850
www.privcom.gc.ca

This policy is made under the Personal Information Protection and Electronic Documents Act. This is a living document that is changed as regulations are changed.