We respect your right to privacy and we are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services provided. We strive to be open and transparent as to how personal information is handled. This document describes the privacy policies of Town Psychological Services, as they relate to collecting, using, and disclosing your personal health information.
Who We Are
Town Psychological Services is a private practice that offers psychological services involving assessment and intervention to adults. At the time of writing, Town Psychological Services includes two clinicians. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information held. These include office supports, computer consultants, website managers, cleaners, bookkeepers and accountants, and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
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 by them); or, activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is different from business information (e.g., an individual’s business address and telephone number). This is not protected by privacy legislation.
Collection of Your Personal Information: Primary Purposes
We collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide appropriate and quality psychological services. For example, we collect information about a client’s health history, including their family history, physical condition and function and social situation in order to help us assess what their health needs are, to advise them of their options and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that occur over time. It would be rare for us to collect such information without the client’s express consent, but this might occur in an emergency (e.g., the client is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our client and we have no reason to believe that the message is not genuine).
About Members of the General Public
For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of our services in general or this practice in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax 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.
On the practice website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a course, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.
About Contract Staff, Volunteers and Students
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts). Examples of the type of personal information collected for those purposes include home addresses and telephone numbers. It is rare for to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work-related performance and provide a report as authorized by them.
Collection of Personal Information: Related & Secondary Purposes
We also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
- To invoice clients for goods or services that were not paid for at the time, 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, arrival of a new product) that we have available.
- Our clinic inspects records and interviews staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or of this practice.
- The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., OHIP, WSIB, private insurance, Assistive Devices Program). 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 goods or services after they have been received, for which our previous records are helpful. We retain client information for a minimum of 10 years after the last contact to enable me to respond to those questions and provide these services.
- If this practice or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Clinic’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
Protecting Personal Information
To protect your personal information, the following steps have been taken:
- 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. All of our cell phones are digital as these signals are more difficult to intercept.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted either through a direct line (i.e., fax)., has identifiers removed or is encrypted. Email is not a secure form of communication and is used only with your consent. Faxing is used to transmit confidential client information only to verified fax numbers. A record of contact (e.g., emails, phone) will be included in your clinical record.
- In administering our practice, we make use of Owl Practice, a secure web-based practice management system to store and manage our client records. This includes information such as client appointments, billing documents, session notes, contact details, and other client-related information and documents. The system we use is encrypted, has servers located in Canada, and access to the system is granted only on an as-needed basis and governed by our strict confidentiality policy. Additionally, all practice data in the system is routinely backed up to ensure the privacy and protection of sensitive client information and to assist us with PHIPA compliance.
- External consultants and agencies with access to personal information must enter into privacy agreements with my practice.
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 services provided and for our own accountability to external regulatory bodies. The College of Psychologists of Ontario, requires client files to be held for at least 10 years after the date of last contact for adults, and 10 years past the date at which the client would turn 18 years old. Paper files containing personal information is destroyed by shredding. Electronic information is destroyed by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.
You Can Look at Your Information
With only a few exceptions, you have the right to access any record of your personal information held about you. We reserve the right to charge a nominal fee for such requests. If there is a problem we may ask you 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. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
Do You Have a Question?
Complaints and general inquiries may also be addressed to:
The College of Psychologists of Ontario
110 Eglinton Avenue West, Suite 500
Toronto, Ontario M4R 1A3
Phone: (416) 961-8817 | (800) 489-8388 | Fax (416) 961-2635
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 ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Phone (416) 326-3333 | 800-387-0073 | Fax (416) 325-9195 | TTY (416) 325-7539