Privacy Policy
At HOPESTONE THERAPY, we take the privacy of your personal information and our responsibilities regarding the collection, use, disclosure and retention of personal information very seriously. This document describes our Privacy Policy and our commitment to you. The purpose of this policy is to ensure that we have your informed consent the collection, use, disclosure and retention of your personal information for the purposes of delivering our services to you. Please read it carefully and feel free to contact us if you have any questions.
About HOPESTONE THERAPY
HOPESTONE THERAPY provides bilingual (French and English) virtual mental health support services to individuals in Ontario. We offer evidence-based mental health services for individuals, youth and parents in a professional, warm and caring atmosphere in support of a variety of mental health challenges. We deliver services through a secure, privacy-protected online video platform or by telephone. HOPESTONE THERAPY is a sole proprietorship operated by Josée McKenzie, doing business as HOPESTONE THERAPY. With respect to the collection, use, disclosure and retention of personal information, we are governed by the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and the Personal Health Information Protection Act (Ontario) (“PHIPA”).
HOPESTONE THERAPY includes Ms. Josée McKenzie only, without in-office assistance. However, we use several consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. We have taken steps with these organizations to ensure confidentiality of the information provided. We deal with an accounting firm, administrative advisers, banks and computer support services. For your wellbeing and with your consent, we may also use health professionals, such as psychologists, psychiatrists, neuropsychologists and doctors. If ever necessary to reveal your name or personal information to these specialists, you will be consulted, and your prior consent will be sought.
What is Personal Information?
Personal information is information about an identifiable individual and includes information that relates to an individual’s personal characteristics (e.g., gender, age, 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), which is not protected by privacy legislation; however, at HOPESTONE THERAPY we treat all client information confidentially.
Personal Information, Personal Health Information and Other Confidential Information
In order to serve you, we will collect, use and retain personal information from you such as your name and/or your child/dependent’s name, your telephone number, your date of birth and/or your child/dependent’s date of birth and address. In some circumstances there may also be a need for collection of your family doctor, family description and history, ethnic origin or country of origin, education, marital or partnership status, health history, health conditions, occupation, religion, presenting problems, medication history, past events, thinking patterns, behaviours, emotions, physiological reactions, etc. We will also take session notes during each session which may contain your personal health information and other information. All of this information will be securely retained in a third-party software system called “Owl Practice” that is designed to securely protect and maintain client confidentiality. This information will not be shared with others (other than Owl Practice for purposes of secure protection and retention) without your written informed consent unless required by law as set out below. The collection, handling, use and retention of your personal information will be governed by this Privacy Policy and by the Privacy Policy of our third-party electronic platform provider, Owl Practice (available at owlpractice.ca), as such policies may be amended from time to time.
Our Purposes for Collecting Personal Information
We may collect your personal information for the following purposes:
to deliver efficient client care;
- to assess and treat;
- to appropriately train or supervise;
- to identify and to ensure continuous high-quality services;
- to assess your psychological needs;
- to provide health care;
- to advise you of treatment options;
- to establish and maintain communication with you and to enable us to contact you;
- to offer and provide treatment, care and services relating to psychotherapy and specific care;
- when referring, to communicate with specialists or other care providers, with consent provided by you;
- to allow us to book and confirm appointments;
- to allow us to efficiently follow up for treatment, care and billing;
- for teaching and demonstrating purposes on an anonymous basis;
- to complete and submit claims for third-party adjudication and payment;
- to comply with legal and regulatory requirements;
- to prepare reports to insurance companies (when agreed upon by the client);
- to prepare materials for the review boards;
- to collect unpaid accounts; and
- to comply generally with the law.
Protection of Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Personal and health information is stored on the Owl Practice platform. Owl Practice servers are located exclusively in Canada across multiple data centres in Toronto and Montréal. Though the Owl Practice service is accessed via a browser, the data is encrypted in transit using SSL encryption, a trusted online security protocol.
If ever paper is used, it is secured in a locked and restricted area.
Electronic hardware is always in a restricted area. In addition, passwords are used on computers.
Our cell phones are digital as these signals are more difficult to intercept.
Electronic information is transmitted either through encrypted messaging or fax.
External consultants and agencies with access to personal information must enter into privacy agreements with us.
Record Keeping and Retention and Destruction of Personal Information
A record of our interactions is kept. Prior to or after the first interaction or session, an electronic file is opened in your name. This file is harboured on the secure Owl platform (see above). Furthermore, no audio or video devices will be used without your signed consent. 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. We do not want to keep personal information any longer than required to protect your privacy. Our client records are stored and preserved in a secure location for approximately seven (7) years from the date of the last appointment or, if the client was less than eighteen years of age at the date of the last appointment, approximately seven years from the day the client became or would have become eighteen years of age. Different periods of storage time may be required by law. However, if you ask, we will remove such contact information right away. 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.
Statement of Confidentiality
We will respect your confidentiality at all times. Our electronic platform, office management system, computer programs, phone services, office space, etc. have been set up to maintain the highest level of confidentiality possible. None of the personal information, including personal health information, that you disclose will be communicated to a third party without your informed consent unless we have a legal obligation to do so to:
Inform a potential victim of violence and law enforcement of a client’s intention to inflict harm or otherwise commit a criminal offence
Inform an appropriate resource person of a client’s intention to end his/her life
Release a client’s file if it is subpoenaed by a court of law
Inform the Children’s Aid Society if a client discloses physical, emotional and/or sexual abuse or neglect of a child under 18 years of age, or of a risk of such abuse
Inform a healthcare provider’s professional association if a client discloses sexual abuse of a patient (disclosure of the client’s identity is not necessary)
Inform the Director of the Ministry of Health and Long-Term Care if a client discloses that a resident of a long-term care home or retirement home is being abused, neglected, or maltreated
abuse by a certified member of a health profession (the name of the client would only be given to the professional’s regulatory body with the client’s consent)
audit by the Ontario College of Social Workers (auditors are bound to confidentiality)
case consultations (without names given) with other social work or psychologist professionals
in the event that a court of law subpoenas your records
upon request of law enforcement when required to do so under the Missing Persons Act, 2018, when law enforcement requires the release of information about a missing person after reasonable efforts have not enabled them to locate the person. Under these circumstances, we will comply with a Court Order, Search Warrant or Urgent Demand from law enforcement and, as soon as reasonably possible, provide copies of the records or verbal equivalent as specified in the Order or Urgent Demand.
If you are not directly paying for your sessions (whether your place of work or an insurance company is paying), confidentiality is still maintained; however, this third party is entitled to certain information. Be sure to ask your social worker about the limits of confidentiality in this case.
You have a Right to your Personal Information
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you need to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language). 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 let you know within 30 days, if 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, where appropriate, notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will agree to include in our file a brief statement from you on the point and, as appropriate, we will forward that statement to anyone else who received the earlier information.
If you have a Concern
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy Officer. Our Privacy Officer can be reached at:
Ms. Josée McKenzie, Privacy Officer
HOPESTONE THERAPY
josee@hopestonetherapy.com
T: 613.762.2070
hopestonetherapy.com