Privacy Policy
Privacy of personal information is an important principle to the Centre for Treatment of Sexual Abuse and Childhood Trauma. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our 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 by them); or, activities and views (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.
Who are we?
Our organization, the Centre for Treatment of Sexual Abuse and Childhood Trauma, includes at the time of writing a number of therapists with different professional qualifications and affiliations, in addition to students completing internships. We use a number of consultants who may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, and accountants. We restrict their access to any personal information we hold, as much as is reasonably possible. We also have their assurance that they have their own privacy policies in accordance with the new laws. We enter into privacy agreements with office maintenance workers and cleaners.
Collection of Personal Information: Primary Purposes
Clients
Like all psychotherapists, 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 psychotherapy treatment. For example, we collect information about a client’s history, including their family history, health history, emotional state, physical condition and function and social situation in order to help us assess what their psychological needs are, to advise them of their options and then to provide the psychological care mutually agreed upon. A second primary purpose is to obtain a baseline of psychological functioning so that in providing ongoing psychological services we can identify changes that occur over time. It would be rare for us to collect personal 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 but 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).
Members of the General Public
For members of the general public, our primary purpose for collecting personal information is to provide notice of special events (e.g., a seminar, workshop or conference) or to make them aware of psychotherapy services in general or our Centre 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 will, upon request, immediately remove any personal information about an individual from our distribution list.
Contract Staff, Volunteers and Students
For people who are contracted to work with us (e.g. office coordinator, board members, accountant, interns, students, renters, former associates and employees, cleaners) our primary purpose for collecting personal information is to ensure that we can contact them in the future and for necessary work-related communication (e.g., notification of events, paychecks, tax receipts). Examples of the type of personal information we collect for these purposes include home addresses and telephone numbers. In the case of the office coordinator, board members, potential new associates and students, we also collect curriculum vitae. It is rare for us to collect or use such personal 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 at the Centre). 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: Secondary Purposes
Like most organizations, 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 services that were not paid for at the time or to collect unpaid accounts.
- To advise clients and others of special events or opportunities (e.g. a workshop, a group therapy opportunity).
- To ensure that a high quality of service is provided by therapists under supervision.
- To this end, supervising psychologists are required to review client files so as to monitor and assess the performance of supervisees.
- To monitor the professional work of therapists, external regulators (e.g. the College of Psychologists of Ontario) may inspect client records and interview our staff as part of their mandate to serve the interest of the public.
- To address reported cases of serious misconduct, incompetence or incapacity of other practitioners by notifying the appropriate regulatory body. Clients will always be asked to give written consent for any disclosure of personal information in this type of situation.
- To report information suggesting serious illegal behavior to the authorities.
- To respond to the requirements of government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc) who have the authority to review our records and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals, (e.g. lawyers, accountants) who will advise us in situations of conflicting rights and obligations.
- To communicate with third-parties who pay for some services provided by the Centre (e.g. 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 entitlement to funding.
Although you may choose not to be part of some of these related or secondary purposes (e.g. by declining to receive notice of special events or opportunities), we do not have much choice but to comply with many of these secondary or related purposes (e.g. external regulation).
Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- 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.
- Electronic information is transmitted either through direct line or has identifiers removed.
- Staff are specifically trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
- Workshops are conducted by our Privacy Officer to ensure that therapists associated with the Centre are informed as to how to safeguard personal information about clients which they keep in their homes or transport in their travels to and from the Centre.
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. However, we do not want to keep personal information too long in order to protect your privacy.
We keep our client files for a minimum of ten years after the last contact (or ten years after the client turns 18 in the case of children). Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away.
We destroy paper files containing 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.
Should the Centre for Treatment cease to exist as an organization, all contact lists for our newsletter and workshops will be destroyed.
Access to Your Personal Information
With only a few exceptions, you have the right to access personal information held by your therapist or the Centre administration. Often all you have to do is ask. We can help you identify what records we might hold about you. If you wish to have access to your clinical file, you will need to make a written request to your therapist. Because information in your clinical file may be complex or distressing to read, your therapist or the Clinical Director of the Centre will review your file with you in person. The fee for this service will be set by your therapist.
If there is a problem in meeting your request to access and review your file we will tell you within 30 days of your initial request and tell you the reason why we cannot give you access.
If you believe there is a mistake in the information in your records, 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 would ask you to provide documentation of the specific inaccuracy in the file. 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 your file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
Questions, Comments or Concerns?
Our Privacy Information Officer, Dr. Mary Hogan-Finlay, can be reached at: (613) 233-4929
Our privacy officer will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy Information Officer. She 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 our services or the mental or physical capacity of any of our therapists we would ask you to share those concerns with your therapist, or our Clinical Director. However, if we cannot satisfy your concerns, you are entitled to complain to the therapist’s regulatory body.
This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA) effective January 1, 2004. This 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 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:
112 Kent Street
Ottawa, Ontario, K1A 1H3
Phone (613) 995-8210
Fax (613) 947-6850