This privacy policy outlines how T. Davidson Psychotherapy manages the personal health information (PHI) collected, used, and disclosed in this practice. This practice is committed to protecting your privacy and strives to adhere to all applicable privacy laws and professional standards.

1. Our Commitment to Privacy

T. Davidson Psychotherapy prioritizes protecting your privacy and the trust you place in this practice. The Personal Health Information Protection Act, 2004 (PHIPA), which governs the handling of personal health information in Ontario, is strictly adhered to.

● As health information custodians under PHIPA, T. Davidson Psychotherapy is obligated to keep your PHI confidential and secure.

● Staff receive privacy training to ensure they understand and fulfill their responsibilities regarding properly handling your information.

● This dedication to protecting your information and well-being is unwavering, regardless of the services provided.

2. What is Personal Health Information (PHI)?

PHI is any information, written or spoken, that can identify you and relates to your physical or mental health. Examples of PHI include:

● Your name, address, telephone number, date of birth, and health card number.

● Information about your legally authorized representatives, if applicable.

● Your diagnosis, treatment plans, session notes, assessment results, and therapist observations.

● Billing and payment information.

● Information shared during individual or group therapy sessions.

3. How T. Davidson Psychotherapy Collects, Uses, and Discloses PHI

● Collection: Only the information necessary for your treatment and the management of your care is collected. You will be informed of the purposes for which information is collected and how it will be used.

● Use: Your PHI is used to offer and manage your health care services, including assessing your needs, developing treatment plans, collaborating with other health care providers involved in your care, and managing billing and financial aspects of your treatment.

● Disclosure: T. Davidson Psychotherapy is committed to maintaining the confidentiality of your PHI and will not disclose it to any third party without your explicit consent, except under specific circumstances allowed by law. These exceptions include:

○ Duty to Warn: When T. Davidson Psychotherapy becomes aware of your intention to cause harm to yourself or others, there is a duty to warn the potential victim and inform the appropriate authorities.

○ Mandatory Reporting: If child abuse or neglect is suspected or if T. Davidson Psychotherapy is aware of other situations that require reporting under the law, there is an obligation to report these to the relevant authorities.

○ Court Orders: When ordered by a court or tribunal to release information, T. Davidson Psychotherapy must comply.

○ Legal Proceedings: PHI may be disclosed when required for legal proceedings or when a summons or similar legal request is received.

4. Your Rights Regarding Your PHI

● Access: You have the right to access your PHI and receive a copy of your records upon request. T. Davidson Psychotherapy will provide you with this information within a reasonable timeframe and in an easy-to-understand format. In situations involving multiple clients (e.g., couples, families), access to records is determined based on consent and the nature of the information. You may only access information directly related to you unless all parties involved provide consent for full access7.

● Correction: If you believe that the information in your record is inaccurate or incomplete, you have the right to request that it be corrected. You can submit a written request outlining the changes you wish to make. If your request is denied, you have the right to provide a statement of disagreement, which will be included in your file.

● Complaint: You have the right to file a complaint with the Information and Privacy Commissioner of Ontario (IPC) if you believe your privacy rights have been violated. T. Davidson Psychotherapy will provide you with information on how to contact the IPC.

5. Security of Your PHI

Ensuring the security of your PHI is crucial. T. Davidson Psychotherapy implements a variety of security measures to protect your information from unauthorized access, use, or disclosure. These safeguards include:

● Physical Safeguards: Securely storing paper records in locked spaces. Complete clinical records are maintained to prevent loss or incompleteness of information.

● Technological Safeguards: Implementing robust password protection, encrypting electronic communications, and employing secure systems for electronic record-keeping. Digital security measures, like encryption and firewall software, are especially important when keeping digital records. T. Davidson Psychotherapy is using Jane App and Upheal for digital record keeping, which adhere to PHIPA regulations. Click to read more about Jane App and Upheal.

● Administrative Safeguards: Establishing and enforcing comprehensive policies and procedures for handling PHI. Privacy training is provided for all staff, and confidentiality agreements are required for anyone who may access PHI, including administrative support staff.

● Breach Protocol: Clear procedures have been established to address any suspected or actual breaches of privacy promptly. If a breach occurs, steps will be taken to contain it, investigate its cause, and notify affected individuals as required by law.

6. Technology and Communication

● Electronic Records: Electronic means may be utilized to collect, use, store, and disclose PHI. T. Davidson Psychotherapy guarantees that any electronic systems employed are PHIPA-compliant and adhere to appropriate security measures. When using electronic record-keeping, compliance with PHIPA regulations is ensured and systems are in place for maintaining the original entry and indicating any amendments made, including the details of who made the changes and why. T. Davidson Psychotherapy is using Jane App and Upheal for digital record keeping, which adhere to PHIPA regulations. Click to read more about Jane App and Upheal.

● Email and Texting: Due to inherent security risks, transmission of PHI through email or texting is generally avoided. These risks will be discussed with you before using these methods and explicit consent will be obtained.

● Social Media: Strict professionalism is maintained in T. Davidson Psychotherapy’s online presence. No information about clients or work with them is posted on social media.

● Teletherapy: If services are offered through teletherapy, the platform's security will be ensured. You will be informed about the risks and limitations associated with teletherapy and T. Davidson Psychotherapy will ensure that you are adequately prepared to use it. In addition to informed consent for general therapy services, your informed consent will be obtained specific to the unique features and potential risks of using technology-based applications like teletherapy. T. Davidson Psychotherapy is using Jane App for teletherapy, which adhere to PHIPA regulations. Click to read more about Jane App.

7. Record-Keeping

● Content: Clinical records encompass all pertinent information related to your care. This includes session notes, treatment plans, correspondence, assessment results, and any other relevant documentation. T. Davidson Psychotherapy makes every effort to maintain accurate, complete, and legible records.

● Retention: Records are retained for the period mandated by law and professional standards. They are securely destroyed to prevent unauthorized access when they are no longer required.

● Fees and Payments: You will be informed of T. Davidson Psychotherapy's fee schedule and any associated administrative fees before your first session. Sliding scale fees based on financial need may be offered. You will be provided with an itemized account of services upon request. Various forms of payment are accepted, but no extra charges for credit card payments are imposed. Policies regarding payment and cancellation fees will be communicated to you.

8. Third-Party Services

Third-party service providers, such as Jane App and Upheal are engaged to efficiently deliver services for billing and electronic health records. These third parties are contractually obligated to maintain the confidentiality of your PHI. You will be informed if any third-party service providers are engaged and how your information will be protected.

9. Changes to This Privacy Policy

Updates may be made to this privacy policy to reflect changes in legislation or T. Davidson Psychotherapy’s practices. Any revisions will be posted on the website and you will be informed of any significant changes. Review this privacy policy periodically to stay informed about T. Davidson Psychotherapy's commitment to safeguarding your privacy.

10. Contact Us

If you have questions or concerns about this privacy policy or our privacy practices, please contact us.

You can also contact the College of Registered Psychotherapists of Ontario at:

College of Registered Psychotherapists of Ontario

375 University Avenue, Suite 800

Toronto, ON M5G 2J5

T: 416-479-4330 / 1-844-712-1364

F: 416-639-2168

e: info@crpo.ca

Sources

● Canadian Counselling and Psychotherapy Association. (2020). CCPA-2020-code-of-ethics-e-book-en [PDF]. https://www.ccpa-accp.ca/wp-content/uploads/CCPA-2020-Code-of-Ethics-E-Book-EN.pdf

● College of Registered Psychotherapists of Ontario. (n.d.). Clinical records. https://www.crpo.ca/practice-standards/record-keeping-documentation/5-1-clinical-records/

● College of Registered Psychotherapists of Ontario. (n.d.). Confidentiality. https://www.crpo.ca/practice-standards/client-therapist-relationship/3-1-confidentiality/

● College of Registered Psychotherapists of Ontario. (n.d.). Fees. https://www.crpo.ca/practice-standards/business-practices/6-1-fees/

● College of Registered Psychotherapists of Ontario. (n.d.). Record-keeping & documentation. https://www.crpo.ca/practice-standards/record-keeping-documentation/

● College of Registered Psychotherapists of Ontario. (n.d.). Record storage, security, & retrieval. https://www.crpo.ca/practice-standards/record-keeping-documentation/5-6-record-storage-security-retrieval/

● Government of Ontario. (2004). Personal health information protection act, 2004. https://www.ontario.ca/laws/statute/04p03