We value your privacy, and take it very seriously.
When you contact us, your intake information (name, phone number, email, and message are reviewed by the clinical director and assigned to the appropriate therapist(s). After the assignment, the Clinical Director deletes your information. It is not stored on any sort of central intake system.
Typically, this deleted within 96 hours.
Each of our therapists operates independently and is committed to protecting your privacy and confidentiality. They are Heath Information Custodians under Ontario’s health privacy legislation called PHIPA. They also belong to a regulatory body; the OCSWSSW or the CRPO. This means they adhere to strict standards when handling your Personal Health Information. Your assigned therapist will receive your intake to their email in order to contact you. During your first session, they will go over confidentiality and the limitations of confidentiality with you. They will also be available to discuss how they store your information within their practice management software.
YYZ Talks does not operate any mailing lists or surveys or anything of the sort, nor do any of its associated Psychotherapists.
Principle 1 – Accountability for Personal Health Information
As Health Information Custodians, YYZ Talks is responsible for the personal health information they hold until they have passed this PHI on to the Independent Therapists in our network. They are responsible for managing their own Owl Practice of Jane App which are 3rd party electronic medical practice management software.
Principle 2 – Identifying Purposes for Collecting Personal Health Information
Psychotherapists have to collect personal health information for the delivery of care, and administration.
In particular, personal information and personal health information may be collected for the following purposes and using the following services:
- Attributing incoming phone calls to the proper marketing channels (tracking marketing initiatives)
We use this to figure out how best to channel our limited marketing budget. This information is anonymized and deleted quarterly.
Principle 3 – Consent for the Collection, Use and Disclosure of Personal Health Information
Health Information Custodians are required to obtain consent to collect, use, or disclose PHI. However, there are some cases where we may collect, use or disclose personal health information without consent, as permitted or required by law in extenuating circumstances.
Should a client wish a third party have access to their health record, all health info custodians require verbal or written consent to this effect.
There are certain activities for which consent is not required to use or disclose personal health information. These activities are permitted or required by law. For example, we do not need consent from clients to (this is not an exhaustive list):
- Invoice and bill
- Engage in process improvements
- Manage internal workings
- Report or respond to the Regulatory Body
- Deal with legal requirements
- Maintain compliance with mandatory reporting obligations
- If anyone under our employ have questions about using and disclosing personal health information without consent, they can ask the Privacy Officer.
Withholding or Withdrawal of Consent
If consent is sought, a client may choose not to give consent (“withholding consent”). If consent is given, a client may withdraw consent at any time, but the withdrawal cannot be retroactive. The withdrawal may also be subject to legal limitations.
Principle 4 – Limiting Collection of Personal Health Information
We really want the minimal amount of personally identifying information of yours. We only ask for what we’re legally obligated to obtain to provide services
Principle 5 – Limiting Use, Disclosure and Retention of Personal Health Information Use
We don’t use your info for anything but delivery of services and process improvement. We don’t disclose it without your consent or unless the law requires us to mandatorily report
Health records are retained as required by regulatory law and professional regulations and to fulfill the purposes for which personal health information is collected. Registered Psychotherapists have to hold onto your records for 10y, (10y post 18 if you started / ended before 18) and Registered Social Workers for 7 years. For under 18, 7 years post turning 18
Principle 6 – Accuracy of Personal Health Information
You are responsible to ensuring the information you provide is accurate as we may need to potentially use that to make decisions about your care.
Principle 7 – Safeguards for Personal Health Information
Our safeguards are physical and the use of passwords, encryption, updated technology, and a need to know basis of communication.
Regarding Email: You acknowledge that email is not secure by default, much cannot be verified over email, and there are inherent risks. We all use encrypted software for delivery of virtual care. We will get your consent at every necessary turn to ensure your privacy and confidentiality is maintained.
Virtual care is delivered from a secure/confidential/private space. No recordings are made.
Files are deleted thoroughly when the time comes.
Each psychotherapist is accountable for their own privacy needs, and protocols to preclude breaches. If that happens, we will notify you, and contain the breach asap. It will be thoroughly investigated and reported to the regulator.
Principle 8 – Openness about Personal Health Information
Just ask your therapist, we aren’t going to make it difficult for you to access your info and update your records. If there are issues, you know which regulatory body to complain to via your consent forms.
Principle 9 – Client Access to Personal Health Information
Just ask your therapist, we aren’t going to make it difficult for you to access your info and update your records. Just do it in writing. There may be a charge for eg submitting sessions to your lawyer for your divorce proceedings.
There’s a few exceptions: If the info you’re requesting could lead to a risk of harm.
In the event that happens, your therapist will discuss this extentuating circumstance with you as clearly as possible and discuss next steps as applicable.
We try to manage all requests in under 25 days.
Principle 10 – Challenging Compliance with Psychotherapy Collective’s Privacy Policies and Practices
Let us know if there are any issues you have with any of this. Via email. We’re here to help and are happy to clarify things to ensure you’re comfortable working with us
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