Ottawa Therapy Group
PRIVACY POLICY
Who we are
The Ottawa Therapy Group is a group private practice, and includes a number of psychologists, psychotherapists, social workers, nurse practitioners, psychotherapists and psychologists in supervised practice and administrative staff. Privacy of personal information is an important principle in our practice. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services provided. Any individual who might have access to information are trained according to our privacy policy. These include administrative support staff (including practice management and accounting assistance), psychometrists, and persons involved in billing and collections.
What is Personal Information and Personal Health Information?
The term “personal information” is defined in the federal Personal Information Protection and Electronic Documents Act, 2011 (PIPEDA) and refers to information about an identifiable individual, including, but not limited to a person’s characteristics such as gender, age, address, phone number and email address. The term “personal health information” is defined in the Personal Health Information Protection Act, 2004 (PHIPA). This includes information that relates to your healthcare and billing (e.g., health history, assessment results, diagnoses, ongoing progress notes etc.) as well as information about personal characteristics, activities, and views This Privacy Policy uses the term “personal information” which also includes personal health information.
Reasons for Collecting Personal Information
The primary reason we collect, use and disclose personal information is to serve clients and provide clinical services requested by clients. We collect and use your personal information to communicate with you (e.g; setting up appointments or contacting you), to deliver ongoing services and treatment to you, and to prevent and offset harm. Another reason we collected personal information is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that occur over time.
By law and in accordance with standards of professional conduct, we are required to keep a record of services provided to each client. This record includes information you provide or authorize us to receive, results of any assessments, consent forms, contact notes, progress summaries, billing information, referral information, and copies of correspondence that we have sent or received related to the services provided to you.
We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include bookkeepers and accountants, insurance companies, credit card companies, collection agencies, lawyers, computer and website support as well as a practice management software company. We restrict their access to any personal information as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
The cost of some services we provide to clients is paid for by third parties (e.g., insurance companies). These third-party payers may have the client’s consent or legislative authority to direct us to collect and disclose certain information and we restrict their access to only personal information that is required.
You may withdraw your consent for the collection, use and disclosure of personal health information at any time by speaking with your service provider or by contacting our information officers Dr. Stephanie Yamin or Dr. Cynthia Bilodeau at admin@ottawatherapygroup.ca
Protecting Your Personal Information
We are committed to protecting the the security of your personal information. We have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use your personal information.
Your personal information may be stored on our database servers or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Policy. Data centers are designed to be physically secure and protected from unauthorized access by unauthorized persons.
Although we will make reasonable efforts to protect personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to bypass our security systems.
To protect personal information, we have also undertaken the following steps:
- Paper information is either under supervision or locked securely.
- Online electronic files are kept on an encrypted secure client management database that is PHIPA and PIPEDA compliant.
- Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on all computers.
- Paper information are sent in sealed, addressed envelopes by reputable courier companies.
- Electronic transmission of files are sent through secure fax or encrypted document sharing systems.
- Staff are trained to collect and use personal information only as necessary and in accordance with our Privacy Policy.
- External consultants and agencies are required to enter into privacy agreements with us.
- The Ottawa Therapy Group ensures your records remain in the care of licensed professionals.
- Our website is SSL encrypted and hosted on a secure server.
Protecting Personal Information – Consent and Confidentiality: You have the right to request that we provide information in your file to third parties and such requests must be done in writing. With the exceptions below, personal information is not collected or revealed to anyone without your consent. Below are the situations in which we may be required to release information without consent.
- If there is imminent risk of serious harm to the client or serious bodily harm to someone else
- If there is indication that a child or a resident of a long-term care facility or retirement home is at risk of abuse or neglect
- In some cases where a file is subpoenaed by a court, where a warrant may be issued to facilitate an investigation, or a file is reviewed by a regulatory body
- In the case where a someone has been sexually abused or harassed by a registered health professional
You can view your information
You have the right to see what personal information we hold about you. At your written request, we can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests. If we cannot give you access, we will tell you within 30 days, if at all possible, and tell you the reason as to why we cannot give you access. If you believe that 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 that we may have formed. We may ask you to provide documentation that our records are wrong. 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 our file a brief statement from you, and we will forward that statement to anyone else who received the earlier information.
Retention of Personal Information
The Ottawa Tehrapy Group serves as the health information custodian for all personal health information collected by the individual regulated health professionals who serve as agents of our practice. We retain your personal information only for as long as is necessary, for the purpose for which it was collected, in accordance with the ethics and standards of our regulatory bodies. We are required to retain personal information for some time to ensure that we can answer any questions you might have about the services provided. We retain client records for at least 10 years after the last contact (and in the case of children, for at least ten years past their 18th birthday). We destroy electronic information by deleting it and, when the hardware is replaced or discarded, we ensure that the hard drive is physically destroyed. Personal information that is not part of the permanent clinical file is shredded or otherwise destroyed or de-identified. We retain any personal information relating to our general correspondence (e.g., with people who are not clients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.
Still have questions?
You may contact our Information Officers Dr. Stephanie Yamin or Dr. Cynthia Bilodeau at: The Ottawa Therapy Group
356 Maclaren Street, Ottawa Ontario, K2P 0M6 Tel: 613-404-5400.
Fax: 613-691-6061
Email: admin@ottawatherapygroup.ca
They are responsible for overseeing any requests for access or correction to personal health records and handling privacy complaints. They will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices, please make it in writing to Dr. Stephanie Yamin and Dr. Cynthia Bilodeau at admin@ottawatherapygroup.ca. They will acknowledge receipt of your complaint and ensure that it is investigated promptly and that you are provided with a formal written decision.
We will assist you if you inform us that you need assistance in preparing a request concerning Personal Information. Administrative charges may apply.
If there are any concerns about the privacy practices outlined in this policy, complaints can be filed with the Information and Privacy Commissioner of Ontario by contacting them at:
2 Bloor Street East, suite 1400 Toronto, Ontario M4W 1A8 Tel: 1-800-387-0073
Email and Social Medica Policy
This policy describes how we use email and social media. The most important thing to keep in mind is that email and social should never be used for emergency communication – our email and social media accounts (and those of our clinicians) are not constantly monitored. If you have any questions about aspects of this policy please discuss them with your clinician.
We prefer using email only to arrange or modify appointments. Email is not completely secure, so please do not use it to share private information. Any emails you send to your clinician will become part of your clinical file.
Our Social Media pages
The OTG has both a Facebook, Instagram, LinkedIn and a Twitter account. We use these accounts to provide general information about our practice as well as share general information related to mental health. We do not use these accounts to target specific users, clients, or potential clients. You are welcome to view our social media accounts, but we prefer that current and former clients do not interact with our pages (or those of our individual clinicians) in any way to ensure your confidentiality.