PRIVACY POLICY

Collection of your personal health information

We are committed to respecting and protecting your privacy. This statement outlines our policies and procedures with respect to collecting, using, and disclosing your personal health information. It also provides information about how you can access records of your personal health information and request correction of recorded information.

The practice of psychology in Ontario is regulated under the provincial Regulated Health Professions Act. As such, all identifiable information collected by a psychologist or psychological associate about an individual, in the course of practicing psychology, is considered “personal health information” under the Personal Health Information Protection Act, 2004 (PHIPA). This includes your name and contact information, as well as any information collected/recorded in the course of providing services to you.

Secondary purposes for collecting information pertain to billing. For billing purposes, no information regarding the content of our sessions is provided. We share only your name, identification, dates and type of treatment (e.g., individual or couple psychotherapy, psychodiagnostics assessment), and costs of services.

We collect your personal health information only directly from you, except: a) when you have provided consent to obtain such information from others (e.g., reports of previous assessments or of other services); and b) where the law requires or allows us to collect information without your consent (e.g., in an urgent situation, when information is needed to prevent potential harm).

We collect only information from you that we believe is needed: a) to provide you with the services you have requested and/or for which you have been referred; b) to maintain contact with you for service-related or future consent purposes; c) to prevent or offset harm (e.g., asking for an emergency contact). If we collect information from you for any other purpose (e.g., research), it will be done only with your informed consent. If you decide that you do not want to provide this latter type of information, you are completely free to refuse. There will be no impact on your services.

By law and in accordance with professional standards, we are required to keep a record of services provided to and contacts with you. Your record includes information you provide or authorize us to receive, results of any assessments, your service plan, consent forms, contact notes, progress summaries, billing information, and correspondence that we have sent or received related to your service. The physical records are the property of our practice. However, you have rights regarding access to your record and regarding disclosure of information from your record (see below), regardless of the form in which the information is recorded.

Use of your personal health information

At Park Hill Psychology, the primary use of your personal health information is to provide services to you. This includes carrying out all of the functions reasonably necessary to provide those services (e.g., service planning and monitoring, maintaining your record, billing, etc.).

We may involve other individuals who may, in the course of their duties, have limited access to your personal information. These include interns, computer consultants, bookkeepers and accountants, and credit card companies/banks. All staff who come in contact with your personal information are trained in the need for privacy and confidentiality, as well as in our practice’s privacy policies and procedures, including prevention of record loss and unauthorized access. Staff members are allowed to access only that information they have a “need-to-know.” This means that staff members involved in billing, for example, are allowed to access only the information needed to carry out their billing function. They are not allowed to access other information. Personnel who know a client personally are required to declare this and to remove themselves from access to that client’s record unless there is an emergency or unless the client has given express consent for access.

Paper information and electronic hardware are either under supervision or secured in a restricted area at all times. In addition, passwords are used or computers are in secure places.

With few exceptions, the personal information you share in session or in between sessions (in person, in writing, by phone, or by video) will be held in complete confidence.

However, there are the following limits to confidentiality:

1. In situations where there is a court order, the therapist is legally required to submit the requested information or documents.

2. In situations where a client intends to cause serious physical harm to their person or to another person, steps would be taken to offset the consequences of such action.

3. The Regulated Health Professions Act makes it mandatory to file a report when the practitioner has reasonable grounds to believe that another member of the same or different college has sexually abused the client.

4. The Child and Family Services Act states that when a practitioner has reasonable grounds to suspect that a child has, or may have suffered abuse (including physical, sexual, emotional abuse and neglect) the practitioner shall report the suspicion and the information on which it is based to the Children’s Aid Society (C.A.S.).

5. If the College of Psychologists of Ontario conducts an audit of the practice files, for quality assurance purposes. 

6. The Long-Term Care Homes Act and the Retirement Homes Act require mandatory reporting when there are reasonable grounds to suspect the abuse or neglect of residents of long-term care or retirement homes.

7. If your insurance company contacts Park Hill Psychology to confirm session dates and attendance that information will be released to them by phone or in writing.

8. Ontario’s Missing Person’s Act makes it mandatory to release relevant client records to a police officer, if the client is deemed a “missing person” under the Act, and if the records will assist them in finding the missing person. 

To learn more about your privacy rights under the Personal Health Information Protection Act, 2004 (PHIPA) please visit health.gov.on.ca.

All persons involved in these activities are required by law to maintain the confidentiality of any accessed information. The above exceptions are called “limits of confidentiality.”

If there are other limits of confidentiality in your situation, we will identify and discuss them with you before proceeding with your service.

Please note that the law requires any disclosure of your personal health information to be limited to information that is reasonably necessary for the purpose of the disclosure, and not to include private information provided by a third party, unless you are involved in an open mediation or custody/access assessment. Professional ethical standards additionally require that any information that might cause serious harm to someone not be disclosed, unless the law requires disclosure.

When consenting to the disclosure of your personal health information to another health professional, who is providing services to you, you may restrict us from sharing all or any part of your personal information. However, if in our opinion the information is reasonably necessary for another health service provider to provide appropriate service, we are required by law to inform the other provider that you have refused consent to provide some needed information. 

Retention and destruction of personal information

We are required by legislation and our regulatory body to retain personal information for no less than 10 years. In the case of any matters relating to custody or access, we retain personal information for 10 years after the youngest child is 18.

Your right of access to your personal health information record

With only a few exceptions, you have the right to access any record of your personal health information, and to request copies of the information. If the physical record contains personal health information about another individual, that individual’s information must be able to be severed from the record before you may access the record. Because of the nature of certain services, severing information in some, not all places of the record can be difficult and at times impossible.

Other exceptions include access to copyrighted psychological test information (test items, protocols, manuals), information provided in confidence by a third party, and information that could result in serious harm to someone’s treatment or recovery, or in serious bodily harm to someone.

If you request your personal file

We may need to confirm your identity, if you have not received service for some time, before providing you with this access.
We reserve the right to charge a nominal fee for such requests, including the cost of retrieving your file from storage and separating out your information from those of other affected parties.
If we cannot give you access, we will tell you within 14 days and explain why not.
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 there is an error, we will make the correction and notify anyone to whom we have sent the incorrect information. If we do not agree that we have made an error, you may provide a notice of disagreement that will be included in the file and we will forward that notice to anyone else who received the earlier information.

Concerns and Further Information

If you would like more detailed information at any time, would like to access or ask for a correction of your record, have a concern about our privacy policies and procedures, or have a concern about the way your privacy has been handled, please do not hesitate to speak or write to us. This privacy policy has been developed in accordance with the Personal Health Information Protection Act, 2004 (PHIPA) and professional regulations and ethical standards.

Further details of the applicable laws, regulations, and standards may be found at the Websites of the Ontario Ministry of Health and Long Term Care (www.health.gov.on.ca), the College of Psychologists of Ontario (www.cpo.on.ca), the Canadian Psychological Association (www.cpa.ca), and the Personal Health Information Protection Act (www.ipc.on.ca).

For more general inquiries, the Information and Privacy Commissioner of Ontario oversee the administration of the privacy legislation in the private sector. The Commissioner can be reached at:
80 Bloor Street West, Suite 1700
Toronto, Ontario M5S 2V1
Phone (416) 326-3333
Web: www.ipc.on.ca 

E-mail: commissioner@ipc.on.ca