Contents
- Introduction
- What Is Personal Information?
- Who I Am
- Primary Purposes for Collecting Personal Information about Clients
- Other Purposes for Collecting Personal Information
- Protecting Personal Information
- Retention and Destruction of Personal Information
- You Can Review Your Personal Information
- Do You Have a Question?
Introduction
Privacy of personal information is an important principle of my practice. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services I provide. I also try to be open and transparent as to how I handle personal information. This document describes the privacy policy of my private practice. Follow this link for the privacy policy of William Osler Health Centre. [back to top]
What Is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information that relates to an individual’s personal characteristics, health, activities, and/or views. Personal information is different from business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation. [back to top]
Who I Am
My organization, Dr. Robert F. Stevens, includes at the time of writing one Psychologist and one administrative assistant. From time to time I use the services of Psychometrists or other Psychologists on a contractual basis. I use a limited number of consultants who assist with computer operations, accounting functions and legal matters who, in the course of their duties, have limited access to personal information I hold. I restrict their access to any personal information I hold as much as is reasonably possible. I also obtain their assurance that they follow appropriate privacy principles. [back to top]
Primary purposes for collecting personal information about clients
Like all psychologists, I collect, use and disclose personal information in order to serve my clients.
- For my clients, the primary reason for collecting personal information is to provide psychological assessment and treatment. For example, I collect information about a client’s history, including their family history, physical condition and function, and social situation in order to help me assess what their psychological health needs are, to advise them of their options, and then to provide the psychological care they choose to have.
- A second primary reason is to obtain a baseline of health and social information so that in providing ongoing health services I can identify changes that occur over time.
- A third reason for collecting information is to provide feedback to family physicians and other referral sources. This is done only if the client wishes me to provide feedback.
- Personal information is generally obtained through client interviews and telephone discussions, completion of background information forms, psychological tests, and questionnaires. I may also collect personal information when I receive a referral of a possible client. I use this information to make a preliminary judgment about whether my services are likely to he relevant and to contact a potential client. At the earliest practical opportunity, I will review with the client my privacy policy and seek explicit consent for further collection and use of personal information for any other purposes. In rare instances, for example in an emergency situation, I may collect personal information without the client’s express consent. [back to top]
Other purposes for collecting personal information
Like most organizations, I also collect, use, and disclose information for purposes related to or secondary to my primary purposes. The most common examples of my related and secondary purposes are as follows:
- To invoice clients for goods or services or to collect unpaid accounts.
- To invoice third party payers including WSIB, private insurance, and auto insurance. These third-party payers often have your consent or legislative authority to direct me to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
- I review client and other files for the purpose of ensuring that I provide high quality services, including assessing the performance of my staff.
- Psychologists are regulated by the College of Psychologists of Ontario who may inspect my records and interview my staff as a part of their regulatory activities in the public interest. In addition, as a professional, I will report sexual misconduct of other practitioners, whether they belong to other organizations or my own.
- Clients or other individuals I deal with may have questions about my goods or services after they have been received. I also provide ongoing services for many of my clients over a period of months or years for which my previous records are helpful. I retain my client information for a minimum of 10 years after the last contact to enable me to respond to those questions and provide these services (my regulatory College also requires me to retain my client records). [back to top]
Protecting Personal Information
I understand the importance of protecting personal information. For that reason, I have taken the following steps:
- Paper information is either under supervision or secured in a locked or restricted area at all times.
- 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 or boxes by reputable Companies.
- Electronic information is transmitted through a direct line or has identifiers removed or is encrypted. Storage & transmission
- Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with my privacy policy.
- External consultants and agencies with access to personal information must enter into privacy agreements with me. [back to top]
Retention and Destruction of Personal Information
I need to retain personal information for some time to ensure that I can answer any questions you might have about the services provided and for my own accountability to external regulatory bodies. However, I do not want to keep personal information too long in order to protect your privacy.
My regulatory body requires that I keep client files for 10 years, or in the case of a child, for 10 years after their 18th birthday.
I destroy paper files containing personal information by shredding or burning. I destroy electronic information by deleting it and, when the hardware is discarded, I ensure that the hard drive is physically destroyed. [back to top]
You Can Review Your Personal Information
With only a few exceptions, you have the right to see what personal information I hold about you. Often all you have to do is ask. I can help you identify what records I might have about you. I will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). I reserve the right to charge a fee for such requests.
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 I may have formed. I may ask you to provide documentation that my files are wrong. Where I agree that I made a mistake, I will make the correction and notify anyone to whom I sent this information. If I do not agree that I have made a mistake, I will still agree to include in my file a brief statement from you on the point and I will forward that statement to anyone else who received the earlier information. [back to top]
Do You Have a Question?
Please do not hesitate to talk to me as I am the Privacy Officer for my private practice. I will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about my privacy practices, you may make it in writing to Dr. Stevens. I will acknowledge receipt of your complaint, ensure that it is investigated promptly, and see that you are provided with a formal written decision with reasons.
If you have a concern about the professionalism or competence of my services or the mental or physical capacity of any of my professional staff I would ask you to discuss those concerns with me. However, if I cannot satisfy your concerns, you are entitled to contact my regulatory body, the College of Psychologists of Ontario.
This policy is made under the federal Personal Information Protection and Electronic Documents Act. That 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 and acts as a kind of ombudsman for privacy disputes. The Information and Privacy commissioner can be reached at: 112 Kent St., Ottawa, Ontario K1A. 1H3; phone 613-995-8210 or 800-282-1376; fax 613-947-6850; TTY 613-992-9190, www.privcom.gc.ca.