 |
|
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?
Who We Are
Collection of Personal Information: Primary
Purposes
Collection of Personal Information: Secondary
Purposes
Protecting Personal Information
Retention and Destruction of Personal
Information
Access to Your Personal Information
Questions, Comments or Concerns?
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.
Back to Top
X
Who We Are
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.
Back to Top
X
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.
Back to Top
X
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 behaviour 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).
Back to Top
X
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. |
Back to Top
X
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.
Back to Top
X
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
Back to Top
X
Questions, Comments or
Concerns?
Our Privacy Information
Officer, Dr. Mary Hogan-Finlay, can be reached at:
203 MacLaren Street, Ottawa, Ontario, K2P 0L4
Phone (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
http://www.privcom.gc.ca/
Back to Top
X |
|
|
