Privacy Statement

Glebe Psychotherapy Personal Health Information Protection Plan

We are committed to protecting your privacy and ensuring the confidentiality of your personal health information. Glebe Psychotherapy engages in a regulated health profession subject to the Personal Health Information Protection Act, 2004 (“PHIPA” or the “Act”). The purpose of this statement is to provide you with information to help you understand how your personal health information is collected and used.

What is my personal health information?

Personal health information includes your name, address, phone number, date of birth, presenting issues, insurance details, and records of the care provided to you. This information is referred to as your health record. Knowing what is in your health record and understanding how your personal information is used, helps you to:

• ensure its accuracy

• better understand who, what, where, why and how others may access your personal information and

• make informed decisions regarding disclosures to others

We collect, and use your personal health information

for the following purposes:

• to provide intakes and referrals to our Registered Psychotherapists and Registered Psychotherapists (Qualifying) in order for them to provide services to clients.

• to obtain payment for services provided.

• to comply with our regulatory obligations to the College of Registered Psychotherapists of Ontario (CRPO) and maintain the standards of record keeping outlined by CRPO.

• your information is disclosed only when you make a request to have information shared, or a request is made and you provide written consent.

What can you expect from Glebe Psychotherapy and your Therapist?

Any personal information collected will be used for your care and treatment. Glebe Psychotherapy, and your Therapist share the responsibility of Custodian of your Health Record.

Your consent will be implied for the collection and use of your personal information for care and treatment purposes once you know your personal information protection rights and you continue with care and treatment.

Your personal information will not be disclosed to anyone unless you give written permission.

Your personal information may only be disclosed without your permission when it is required or authorized by law. For example, in the case where a child, a senior, or a vulnerable member of society has been harmed or is at risk of being harmed. Or if you are at risk of harming yourself or someone else is in danger, or you disclose the name of a regulated health professional who has been abusive to you we are required to report that person to their regulating body, or your health record is subpoenaed by the court.

In the collection and storage of your Personal Health Information, Glebe Psychotherapy maintains compliance to PHIPA by ensuring compliance to administrative controls, physical controls, technical controls are met according to the standards outlined by PHIPA.

We will collect, use and disclose only as much personal health information as is needed to achieve these purposes. You can withhold or withdraw your consent to the collection, use or disclosure of your personal health information by contacting our Health Information Custodian, Susan Kim, at (819) 712-8405.

What are your rights?

Your personal information protection rights include knowing why your personal information is collected, how it is used, and to whom it is disclosed.

Access Rights

• PHIPA provides a broad right of access to the personal health information held by a custodian about an individual. However, PHIPA provides some grounds for refusing such a request including the following:

• it is quality of care information or information generated for the College’s quality assurance program;

• it is raw data from standardized psychological tests or assessments;

• there is a risk of serious harm to the treatment or recovery of the individual or of serious bodily harm to another person; or

• access would reveal the identity of a confidential source.

PHIPA provides procedures for handling access requests including the following:

• the custodian must assist the individual in making a meaningful request, if necessary;

• while the custodian can informally provide access, it can also insist upon a formal written request;

• the custodian should, where reasonably practical, explain terms, codes and abbreviations;

• the custodian must notify the individual of his or her right to complain to the Information and Privacy Commissioner of Ontario if the request for access is refused (along with the reasons for the refusal) and the burden of justifying the refusal is on the custodian;

• the custodian can refuse frivolous, vexatious and bad-faith requests for access;

• the custodian must satisfy themself of the identity of the individual before granting him or her access;

• the custodian must provide any personal health information maintained in electronic format to the individual in a specified electronic format to facilitate portability of the information for the individual;

• the custodian can only charge a reasonable cost recovery fee for access and must provide an estimate of the fee in advance (the Information and Privacy Commissioner has held that a reasonable fee is $30.00 for the first 20 pages and 25 cents for every additional page); and

• the custodian must respond to a request for access as soon as possible and no later than 30 days after receiving the request, but the custodian can extend the time for a response by another 30 days if necessary.

Correction Rights

• We have an obligation to correct personal health information if it is inaccurate or incomplete for the purposes it is to be used or disclosed.

• Clients may request that their health information be corrected if it is inaccurate or incomplete. Such requests must be made in writing and must explain what information is to be corrected and why.

• We must respond to requests for correction within 30 days (or seek an extension of up to an additional 30 days but only if we have let the client know, in writing). Corrections are made in the following ways:

o Striking out the incorrect information in a manner that does not obliterate the record or

o If striking out is not possible: Labelling the information as incorrect, severing it from the record, and storing it separately with a link to the record that enables Glebe Psychotherapy or the Health Information Custodians to trace the incorrect information, or

o Ensuring there is a practical system to inform anyone who sees the record or receives a copy that the information is incorrect and directing that person to the correct information.

• The record will not be corrected if:

o The record was not originally created by the Health Information Custodians and the Health Information Custodians do not have the knowledge, expertise or authority to correct the record, or

o The record consists of a professional opinion which was made in good faith.

• If we choose not to correct a record, the client must be informed in writing. The client will have the choice to submit a statement of disagreement, which will be scanned onto the health record and released any time the information that was asked to be corrected is released. In these cases, clients have a right to complain to the Information and Privacy Commissioner of Ontario.

Complaints

• We will receive and respond to complaints or inquiries about our policies and practices relating to the handling of personal health information. We will inform clients who make inquiries or lodge complaints of other available complaint procedures.

• All complaints about the nature of the safeguards or the secure handling of information related to Glebe Psychotherapy’s information records, both electronic and physical, should be directed to the Information Security Custodian contact person - Susan Kim (819) 712-8405.

• A review will be conducted within 7 business days.

• If a complaint is found to be justified, we will take appropriate measures to respond.

• The custodian will address any further action required regarding the complaint, via internal procedures, or if required via the Privacy Commissioner of Ontario.

• The Information and Privacy Commissioner of Ontario oversees compliance with privacy rules and PHIPA. Any individual can make an inquiry or complaint directly to the Information and Privacy Commissioner of Ontario by writing to or calling:

2 Bloor Street East, Suite 1400

Toronto, Ontario M4W 1A8 Canada

Phone: 1 (800) 387-0073 (or (416) 326-3333 in Toronto)

Fax: 416-325-9195

www.ipc.on.ca

Retention and Destruction of Personal Information

• Glebe Psychotherapy will establish a retention policy of 7 years after the last client interaction in accordance with the standards outlined by CRPO. After which information will be disposed of.

• Should your therapist leave Glebe Psychotherapy, they will become the custodian of your personal health information beginning the day following their last day at Glebe Psychotherapy.

• Information will be disposed of in a secure manner. (shredding, deletion in a manner that files cannot be recovered). No 3rd party shredding company will be employed by Glebe Psychotherapy.

Personal Health Information Breach Procedure

In the event of an information breach, the Information Custodian will:

• Ensure the Contact Person and appropriate staff/departments are informed of the breach.

• Consider whether the Commissioner must or should be notified.

• Consider the most appropriate way to notify affected individuals in light of the sensitivity of the information (e.g., by phone, in writing, at the next appointment)

• Provide the organization’s contact information in case the individual has further questions

Health Information Custodian

The health information custodian is ultimately responsible for the personal health information in his or her custody or control. Each Therapist who provides care to clients registered through Glebe Psychotherapy is a health information custodian (“Health Information Custodian”) under Ontario’s health privacy legislation, (PHIPA.)

Glebe Psychotherapy Health Information Custodian contact is Susan Kim, Clinical Director (819) 712-8405.

As custodian you can expect:

• facilitate organization-wide compliance with PHIPA,

• educate the agents of the custodian,

• respond to public inquiries about the custodian’s information practices,

• oversee access and correction requests,

• handle privacy complaints.

If you have questions or want to make a complaint about our privacy practices, please contact Susan Kim, Clinical Director, Glebe Psychotherapy (819) 712-8405.