Privacy Policy
Privacy of personal information is of utmost importance. Personal information includes any “identifying” information collected about an individual. This relates to an individual’s personal characteristics (e.g. gender, age, address, ethnic background, family status, etc.), health (e.g. developmental, physical and mental health history/current functioning etc.), personal activities and views (e.g. opinions expressed by an individual, social, political, and extracurricular activities.). 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 gave it to us (e.g., to respond to your email message).
Our Privacy Policy complies with the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as the Personal Health Information Protection Act, 2004 (PHIPA). The Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation and also acts as an ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at: 2 Bloor Street East, Suite 1400, Toronto, ON, M4W 1A8. Phone (416) 326-3333. www.ipc.on.ca
The primary purpose of collecting, using, and disclosing personal information is to provide psychological services. For example, collecting information about a client's medical, academic, social, and emotional history is required to assess a client’s current and historical functioning across environments, and to advise clients and their families of related recommendations and resources. There are also two secondary purposes for collecting personal information. Firstly, registered psychologists are regulated by the College of Psychologists and Behaviour Analysts of Ontario, who may elect to inspect individual psychologists’ records as part of their regulatory activities in the public interest. Similarly, registered psychotherapists are regulated by the College of Registered Psychotherapists of Ontario, who also may elect to inspect the records of an individual registered psychotherapists as a part of their regulatory activities. Secondly, if a client submits a claim for reimbursement by an insurance company (or other third party) for the services provided, then the third party will require the client’s consent to contact the clinician as needed, in order to confirm the client’s attendance and entitlement to funding.
If your family is accessing services from more than one clinician at Avalon Psychology, a single client file is created for each person in your family. If one clinician is working with you individually, and another clinician is working with you as a part of a child/adolescent, couples or family case, the clinicians cannot access the records created by the other clinician. If clinicians need to discuss content from their session notes or clinical impressions, a separate consent to exchange information will be requested from you.
The following steps are taken to protect personal health information:
Our clinic uses a secure, web-based practice management system to store and manage client personal information and clinical records. This includes information such as client contact information, appointments, billing documents, session notes, and any other client-related information/documents. This system is encrypted and stores your information exclusively on servers exclusively located in Canada. All practice data in the system is routinely backed up to ensure the privacy and protection of sensitive client information and to assist with PHIPA compliance. The system is Jane App - please visit their website for more information: https://jane.app/
Hard copy documents/files and any electronic hardware are secured in a locked filing cabinet that only the clinician can access. Paper information is transmitted with written informed consent (as needed) in sealed envelopes/boxes via reputable companies with tracking numbers.
Electronic information is stored on computers and electronic devices with encryption and password protection. Electronic information is transmitted with written informed consent, or where necessary by law.
In compliance with PHIPA legislation, personal information is retained for the greater of 10 years, or 10 years after the client’s 18th birthday to ensure that the information is available to the client as needed, and for accountability to external regulatory bodies. Once that time period has elapsed, any paper documents containing personal information are destroyed via shredding, and cloud-based or electronic information is deleted. Discarded computer hardware is physically destroyed. Clients have the right to view their personal information with only a few exceptions (e.g. copyright restrictions, and test materials), and are required to make any requests in writing to their individual clinician (or clinician’s supervisor).
In almost all cases (except those defined below), no information will be communicated, directly or indirectly, to a third party without your written informed consent. The following are limits to confidentiality (i.e., instances where your personal information may be released as required or allowed by relevant legislation):
All verbal and written communications are treated as confidential, with these exceptions:
If you are at risk of seriously harming yourself, we are permitted to take steps to ensure your safety.
If there is a risk of you harming another individual, we are permitted to inform that person and/or notify the police.
If we have reasonable grounds to be concerned about the welfare of a child under 16, we must alert the appropriate authorities.
If we believe that someone who has committed a sexual offence against a child (or may have a sexual interest in children) has unsupervised contact with a child under 16, we must inform the relevant authorities.
If we become aware of sexual abuse by a regulated health professional, we are obligated to report this to their professional College.
If the police submit an “urgent demand” for a client’s personal records to aid in a missing person’s case, we may be required to provide those records.
If a judge issues a court order for my clinical documents, we must release them. The clinician overseeing your clinical services may also be subpoenaed to testify in court.
If there are concerns that a resident of a long-term care facility or retirement home has been harmed or is at risk of harm, we must report it to the appropriate authorities.
If the College(s) with which your clinician is registered [e.g., College of Psychologists and Behaviour Analysts of Ontario (CPBAO) or the College of Registered Psychotherapists of Ontario (CRPO)] randomly selects your clinician’s files for review, that regulatory body may access your records.
The registered psychologists or registered psychotherapist who oversees your case will make every effort to notify you if it becomes necessary to break your confidentiality.
In addition, please be advised that your information may be accessed by the Avalon Psychology administrative team (e.g. clinic administrator, intake coordinator) for the purposes of supporting you/your family’s scheduling, billing, and other administrative needs. Avalon Psychology’s founder, Dr. Brent Mulrooney, C.Psych. may also review client files for the purpose of supporting administrative tasks, and ensuring high quality services and file keeping.
Treatment services that are being offered via video sessions are conducted on a secure web-based platform. To access the video sessions, you will need a smartphone, tablet, or computer. To maintain confidentiality, therapy sessions are conducted in a private room utilizing software that is encrypted and maintains high standards of privacy and security. It is the client’s responsibility to maintain confidentiality in their own space when engaging in treatment via video or telephone in their home or any other environment (e.g., setting up the technology in a room with the door closed, headphones, etc.). No personal health information is recorded, and all data is destroyed at the end of the call.