Privacy of personal information is an important principle to Liberty Square Psychology Clinic. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services that we provide. We strive to be open and transparent regarding how we handle personal information. This document describes our current privacy policy.
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.
WHO WE ARE
Our organization, Liberty Square Psychology Clinic, includes at the time of writing, one psychologist and two support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include bookkeepers and accountants, credit card companies, website managers, 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.
WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES
Like all psychology practices, we collect, use and disclose personal information in order to serve our clients.
For our clients, the primary purposes for collecting personal information are to conduct psychological and/or psychoeducational assessments to determine treatment. For example, we collect information about a client’s health history, including their family history, physical condition, and their emotional and social situation to determine what their health related needs are, to advise them of their treatment options, and to provide them with the treatment they decide to pursue.
WE COLLECT PERSONAL INFORMATION: RELATED AND 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:
- The cost of certain services that are paid for by third parties (e.g. insurance providers, WSIB). 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.
- 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.
- Psychologists are regulated by the College of Psychologists of Ontario who may inspect our records and interview our 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 our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. 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 our files and interview our staff 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.
- Clients or other individuals we deal with may have questions about our goods or services after they have been received. We also provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful. We retain our client information for a minimum of ten years after the last contact or ten years from their 18th birthday to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our client records).
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. All Clinic associated 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 or has identifiers removed or is encrypted.
- Staff are trained to collect, use and disclose personal information only as necessary to fulfil their duties and in accordance with our privacy policy.
- External consultants and agencies with access to personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
In order to protect your privacy, we do not want to keep personal information for too long. We keep our client files for ten years. 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 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. Alternatively, we may send the client file to our client.
YOU CAN LOOK AT YOUR 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 to identify what records we might have about you. We will also try to help you understand any information that you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. 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 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, will forward that statement to anyone else who received the earlier information.
DO YOU HAVE A CONCERN?
We can be reached at:
3601 Highway 7 East | Markham, ON | L3R 0M3
PHONE: 905-258-0800
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer (Dr. Marjan Saghatoleslami). She will acknowledge receipt of your complaint and 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 of any of our professional staff or about the competence of our services, we would ask you to discuss those concerns with us. If we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
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
www.cpo.on.ca
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
www.ipc.on.ca