What Is Personal Health Information?
Personal health information is information about an identifiable individual. Personal information includes information that relates to an individual’s personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status); health (e.g., health history, health conditions, health services received by them); or, activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is different from business information (e.g., an individual’s business address and telephone number). This is not protected by privacy legislation.
Collection of Personal Health Information: Primary Purposes: About Clients
The primary purpose of collecting personal information is to provide mental health services (eg: assessment, therapy, consultation, psychotherapy). For example, the collection of information about a client’s health history, including their family history, physical condition and function, and social situation is conducted in order to help with the assessment of client needs, to advise clients of their options, and then to provide the health care they choose to have.
A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services one can identify changes that occur over time. It would be rare for us to collect such information without the client’s express consent, but this might occur in an emergency (e.g., the client is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from a client and we have no reason to believe that the message is not genuine).
About Members of the General Public
For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of our psychological services. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list. On our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you provided (e.g., to respond to your email message, to register for a course, to subscribe to a newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.
Collection of Personal Health Information: Related and Secondary Purposes:
Like most organizations, we also collect, use, and disclose information for purposes related to (or secondary to) our primary purposes. The most common examples of our related and secondary purposes are as follows:
Protecting Personal Health Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Retention and Destruction of Personal Health Information
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We keep client files for ten years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We destroy paper files containing personal information by shredding them. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.
Access to Your Health Information
With only a few exceptions (eg: copyright-protected tests), you have the right to see what personal information we hold about you. Often all you have to do is ask. 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 there is a problem we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible, and tell you the reason, as best we can, as to why we 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 we may have formed. We may ask you to provide documentation that our files 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 on the point and we will forward that statement to anyone else who received the earlier information.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. They will acknowledge receipt of your complaint, ensure that it is investigated promptly, and that you are provided with a formal written decision with reasons. If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we ask you to discuss those concerns with Vera Roncon, Clinical Psychologist / Clinic Owner, at 416-488-2838. If Vera Roncon cannot satisfy your concerns, you are entitled to complain to one of our regulatory bodies:
College of Psychologists of Ontario
110 Eglinton Ave West, Ste 500
Toronto, ON M4R 1A3
College of Registered Psychotherapists of Ontario
75 University Avenue, Suite 803,
Toronto, ON M5G 2J5
Tel: 1 844-712-1364
Ontario College of Social Workers and Social Service Workers
250 Bloor Street East, Suite 1000
Toronto, Ontario M4W 1E6
This policy is made under the Personal Health Information Protection Act (PHIPA). For more general inquiries, the Information and Privacy Commissioner of Ontario oversees the administration of privacy legislation. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Phone (416) 326-3333
Fax (416) 325-9195
TTY (416) 325-7539
Orchid Psychotherapy Clinic
120 Eglinton Ave East, #500, Toronto, ON M4P1E2 Tel: 416-488-2838 Email: email@example.com
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