Privacy of personal information is an important principle to me. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services I provide. I also try to be open and transparent as to how I handle personal information. This document describes my privacy policies, applying to information collected by phone, email, website (www.familycounselling.net), or through any other direct contact with you.
Your Privacy is my Priority
No personal information will be communicated, directly or indirectly, to a third party without your informed and written consent. Exceptions to this policy include the legal, and/or ethical obligations to:
- Inform a potential victim of violence of a client’s intention to harm.
- Inform an appropriate family member, health care professional or police if necessary of a client’s intention to end his or her life.
- Release a client’s file if there is a court order to do so.
- Inform Child and Family Services if there is suspicion of a child being at risk or in need of protection due to neglect, or physical, sexual or emotional abuse.
- Report a regulated health professional who has sexually abused a client to the professional’s regulatory body.
Stephen Douglas Registered Psychotherapist is regulated by the College of Registered Psychotherapists of Ontario who may inspect my records as part of their regulatory activities in the public interest. External regulators have their own strict privacy obligations. 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 my files as part of their mandates. In these circumstances, I may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to me. The cost of some goods/services provided by my practice to clients is paid for by third parties (e.g., WSIB, private insurance, motor vehicle insurance, EAP Companies, First Nations and Inuit Health Branch). 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. It is my policy that clients have a legal and moral right to know what information is contained about them in their record. Clients or their legal designates shall have access to all information which can be identified as pertaining to them (and only them) and which is stored in the client record, with the exception of information that is believed to be harmful or that is confidential about or from third parties. I will need to confirm your identity and legal right to have access to the information. In some cases, this may include producing identification and or proof that you have legal authority to make decisions on behalf of the client. I reserve the right to charge a nominal fee for such requests. I may ask you to put your request in writing. If I cannot give you access to your record, I will tell you within 30 days if at all possible and tell you the reason, as best I can, as to why I 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 I may have formed. I may ask you to provide documentation that my file is wrong. If changed, a statement of changed information is included in the record. If the request for a change is declined, the client may file a notice of disagreement in the record. I understand the importance of protecting personal information. For that reason, I have taken a number of steps.
Protecting personal information
I understand the importance of protecting personal information. For that reason, I have taken the following steps:
- Paper information is stored 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 or boxes by reputable companies (e.g., Canada Post).
- Electronic information is transmitted either through a direct line or is anonymized or encrypted.
- Any files being transported are required to be stored in a locked area (e.g., car trunk, carrying case with a locking mechanism).
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.
Retention and Destruction of Personal Information
What is Personal Information?
Personal information refers to information about an identifiable individual and includes information that relates to an individual’s personal characteristics (e.g., name, date of birth, home address and telephone number), their health (e.g., presenting problem, health history, health services received by the individual, social situation) or their activities and views (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is not the same as business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation. I use a number of consultants and agencies that may, in the course of their duties, have limited access to the personal information I hold. These consultants and agencies include bookkeepers and accountants, lawyers, office maintenance, cleaners, computer consultants, credit card companies, financial institutions, marketing personnel and website managers. I restrict their access to any personal information I hold as much as reasonably possible. I also have a confidentiality agreement with them. Policy Concerning Online Privacy I advertise services online, so that individuals, couples and families in need of counselling or psychotherapy can find me easily. I know that more and more people are searching for mental health services on the Internet, versus traditional means of referral. I rely on the use of search keywords, such as depression, counselling, anxiety, stress, or therapy, which are often tied to location-based search terms (e.g. “Psychotherapy in Toronto”). This allows me to connect my services and office locations with the people searching for help with these particular issues. I only have access to/collect information that you voluntarily provided via email or other direct contact from you. I will use your information to respond to you, regarding the reason you contacted me. I will not sell your information to any third party.
Collection of non-personal information
For purposes of improving this website, I may collect and aggragate non-personal information about my visitors, such as the type of internet browsers used or the website from which visitors linked to the familycounselling.net. I may also aggregate details that have been submitted to the website (for example location or browser). You cannot be identified from this information and it is only used to assist us in providing an effective service on this website. Google and other search engines similarly use sophisticated systems to show you content based on your previous searches. The search engines learn about the content you look at, as each website you visit leaves a small bit of data in your Internet browser (called a “cookie.”) The next site you visit will have access to these “cookies,” so your previous web activity is available. Websites then use this information to show you ads and content based on your preferences and interests. So, when you use a search engine, ads and search results will appear based on your location, what you have searched for, as well as previous searches you have conducted and sites visited in the past. When you visit sites other than search engines, you will see ads in various formats. The content of the ads may be based on your previous engagement online. So, if you have recently searched for vacations in Mexico it is likely that you will encounter ads featuring Mexico vacations as you navigate online. In turn, if you have searched for counselling, the ads you will see in the future may be focused on therapy, mental health, and other counselling-related topics. If this makes you uncomfortable, causes you distress in any way, or makes you worry about your confidentiality, there are a few options you can pursue.
You can engage a function called “Private Browsing” on your Internet browser. This function allows you to visit websites so that no browsing history is recorded and cookies are deleted when you close the browsing window. The following steps outline how to engage private browsing.
|Safari:||>Safari >Private Browsing|
|Google Chrome||>Click the Chrome menu on the browser toolbar. >Select “New incognito window.”|
|Mozilla Firefox||>File >Select “New Private Window.”|
|Internet Explorer||>Safety >InPrivate Browsing|
If you are concerned about privacy, you should frequently delete cookies from your browser.
|Safari||>Safari >Preferences >Privacy >Remove All Website Data|
|Google Chrome||>Tools >Options >Under the Bonnet >Privacy >Clear Browsing Data >Delete Cookies and Other Site Data|
|Mozilla Firefox||>Tools >Options >Privacy >Cookies >To remove a single cookie click on the entry in the list and click on the “Remove Cookie” button >To remove all cookies click on the “Remove All Cookies” button|
|Internet Explorer||>Tools >Safety >Delete Browsing History >Check the “Cookies” box >Delete|
Opt-Out of Interest-Based Ads on Google
Many websites rely on ads for funding. So, just as you cannot get rid of commercials on television, you cannot completely rid yourself of ads online. However, you can change your ad settings on Google, so that the ads you see are not based on your interests and demographics details. You may still want to clear your history and delete your cookies after searching for sensitive information or visiting certain sites. The following directions are taken directly from Google Support, and can be accessed at: https://support.google.com/ads/answer/2662922?hl=en
- Sign in to Ads Settings at www.google.com/settings/ads.
- Under “Ads on Google” click the “Opt out” link.
- In the dialog that opens, click the Opt out button.
Google ads across the web
- Sign in to Ads Settings at www.google.com/settings/ads.
- Under “Google Ads Across the Web” click the “Opt out” link.
- In the dialog that opens, click the Opt out button.
To opt out of Google’s interest-based ads altogether, you’ll need to opt out twice: once for Google products (Ads on Google) and once for ads on the Display Network (Google ads across the web). Use of your personal information submitted to other websites I cannot be responsible for the privacy policies and practices of other websites even if:
- you accessed the third party website using links from this website; or
- you linked to this website from a third party website.
I recommend that you check the policy of each site you visit and contact the owner or operator of such website if you have any concerns or questions.
Your Access to and Control Over Information
You may opt-out of any future contacts from us at any time. You can do the following at any time by contacting me via the email address or phone number given on my website:
- see what data I have about you, if any.
- change/correct any data I have about you.
- have me delete any data I have about you.
- express any concern you have about my use of your data.