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Privacy of personal information is an important principle
to Gilmour Psychological Services. We
are committed to collecting, using and disclosing personal information responsibly
and only to the extent necessary for services we provide. We are open and
transparent as to how we handle personal information. This document describes
our privacy policies. What is Personal Information?
Personal
information is information about an identifiable individual. Personal information includes information
that relates to: an individual’s personal characteristics (e.g. gender, age,
home address or phone number, education and training, family circumstances); health
(e.g. health history, health conditions, health services received); or, activities
and views (e.g. occupation/profession, ideas and concerns expressed by an
individual). Personal information is different from business information (e.g.
an individual’s business address and telephone number), which is not protected
by privacy legislation. Who We Are
Our
organization, Gilmour Psychological Services, includes many psychologists, a business
manager and a receptionist. From time
to time we also include psychologists in Supervised Practice and on occasion,
psychology students working under the supervision of a licensed
psychologist. Our primary purposes for Collecting Personal Information
are summarized below.
About Clients
We
collect, use and disclose personal information only in order to provide
psychological services to our clients. For example, we collect information about a client’s health
history, including their family history, physical condition and function and
social situation in order to help us assess what their mental health needs are,
to advise them of their options and then to provide the psychological services
they choose to have. A second primary
purpose is to obtain a baseline and ongoing record of psychological functioning
so that in providing psychological services we can monitor treatment progress
and identify changes that occur over time. In some situations, the
primary purpose of collecting personal information would be to conduct an
assessment to provide a professional opinion about the individual’s
psychological functioning. With the client’s consent, the opinion would be
reported to the appropriate person or agency, for example, an insurance
company, Workplace Safety and Insurance Board, psychological/legal reports,
no-fault automobile insurance, Children’s Aid Society and rehabilitation
companies. It
would be rare for us to collect or disclose personal information without the
client’s express consent, but this might occur in an emergency (in this case
the client would be notified in writing as soon as possible) or if 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 our client and we have no reason to
believe that the message is not genuine). About Members of the General Public who call for information
about our services
For
members of the general public, our primary purposes for collecting personal
information (e.g. contact numbers) are to make them aware of the range of psychological
services available in our clinic and to direct them to the appropriate psychologist.
Here
are some additional reasons why We Collect Personal Information.
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: q
To invoice clients for services that were not paid for at the time, to
process credit card payments or to collect unpaid accounts. q
Psychologists in supervised or autonomous practice are regulated by the
College of Psychologists of Ontario who may inspect our records and interview
our psychologists as a part of their regulatory activities in the public
interest. The College of Psychologists of Ontario has its own strict
privacy obligations. q
The cost of some services provided by the organization to clients is
paid for by third parties (e.g. private insurance, WSIB, automobile insurance,
First Nations and Inuit Health Branch, Canadian Forces, CUPE). These
third-party payers often have your consent or legislative authority to direct
us to collect and disclose to them certain information in order to demonstrate
client entitlement to this funding (e.g. Canadian Forces identification, First
Nations identification). Protecting Personal Information
We
understand the importance of protecting personal information. For that reason,
we have taken the following steps: q
Paper information is either under supervision or secured in a locked or
restricted area. q Electronic
hardware is either under supervision or secured in a locked or restricted area
at all times. Encryption and passwords
are used on computers. q Paper information is transmitted through sealed, addressed envelopes or
boxes by reputable couriers or Canada Post. q
Electronic information is transmitted through a dedicated line only to
people and agencies that have a privacy policy. q
All members of Gilmour Psychological Services are trained to collect,
use and disclose personal information only as necessary to fulfil their duties
and in accordance with our privacy policy. LIMITS TO PROTECTION OF
PRIVATE INFORMATION Limits to the protection of private information
include: legally mandated disclosure to Children’s Aid Society, College of
Psychologists of Ontario and Court orders to release information, search
warrants for a file in a criminal or a legal case, and subpoenaes. Retention and Destruction of
Personal 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. q
Clients or other individuals we deal with may have questions about our
services after they have been received. We also provide ongoing services for
many of our clients over a period of months or years for which our previous
records are helpful. We retain our client information for a minimum of ten
years after the last contact to enable us to respond to those questions and
provide these services. The College of Psychologists of Ontario also requires
us to retain our client records. For clients who are seen before the age of 18,
records are retained for ten years following their 18th birthday. q
If Gilmour Psychological Services were sold none of the client records
would be transferred to or accessed by the new owners. q
We destroy electronic information by deleting it and, when the hardware is replaced or discarded,
we ensure that the hard drive is physically destroyed. Alternatively, we may
send some or all of the client file to our client. Personal information that is
not part of the permanent clinical file is shredded. You Can Look at Your Information
With
only a few exceptions, 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. abbreviations, technical language,
etc.). We may need to confirm your identity, if we do not know you, before
providing you with this access. We reserve the right to charge a fee for such requests. 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. Do You Have a Question?
For
the year 2007, our Information Officer is Dr. Karen Davies She can be reached at: Gilmour Psychological Services 437 Gilmour St., Ottawa, Ontario K2P 0R5 (613) 230-4709
extension 26 She will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about our
privacy practices, you may make it in writing to our Information Officer. She
will acknowledge receipt of your complaint, ensure that it is investigated
promptly and that you are provided with a formal written decision with reasons. This policy is made under the Personal Information
Protection and Electronic Documents Act. For more general inquiries, the
Information and Privacy Commissioner of Canada oversees the administration of the privacy
legislation in the private sector. The Commissioner also acts as a kind of
ombudsman for privacy disputes. The Information and Privacy Commissioner can be
reached at: 112 Kent Street Ottawa, Ontario K1A 1H3 Phone (613) 995-8210 | 800-282-1376
| Fax (613) 947-6850 | TTY (613) 992-9190 www.privcom.gc.ca |