Protecting Your Private Information

The Centre for Psychological Services is committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the services we provide.  We also try to be open and transparent as to how we handle personal information.  Under the Personal Information Protection and Electronics Documents Act (PIPEDA), which takes effect in January 2004, we are required to provide you with a description of our policies and practices for protecting personal information.  This document describes our privacy policies.

What Is Personal Information

Personal information refers to information about an identifiable individual.  Personal information includes information that relates to an individual’s personal characteristics (e.g., name, date of birth, home address, and telephone number), their health (e.g., presenting problem, health history, health services received by the individual, social situation) or their activities and views (e.g., 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), which is not protected by privacy legislation.

Who We Are

The Centre for Psychological Services is a not-for-profit clinic that provides psychological services to children, adolescents, families, and adults. The Centre is staffed by highly qualified  provincially licensed psychological service providers who are contracted to provide direct clinical service.  Clinicians also supervise graduate students in clinical psychology, who are also an essential part of the clinic’s team.  From time to time, professionals from the community are invited to provide direct service, supervise graduate students, or consult with the clinical team on an as-needed basis.  The Centre also has a clerical support person who is responsible for ensuring the completeness and security of clinical files. Everyone who works in the clinic and has access to personal information signs a confidentiality agreement indicating that they will protect personal information and follow appropriate privacy principles.

Why We Collect Information

About Clients:

The primary reason we collect information about our clients is to provide psychological services.  For example, we collect information about clients’ health history, family history, physical and psychological condition, social situation, and current functioning to help in conducting assessments, planning treatment, or to advise them of treatment options.  A secondary purpose is to obtain a baseline of health and social information so that in providing ongoing psychological services we can identify changes that are occurring over time.  We also use information to invoice clients for services that were not paid for at the time of the visit, or to collect unpaid accounts.

About Members of the General Public

We do not collect information about members of the general public.  The exception is in response to telephone or email enquiries about our services.  In these situations, messages or saved emails, containing the information provided by the enquirer, are saved until such time as the requests are dealt with then destroyed.

About Mental Health Practitioners, Psychology Interns, and Contract Staff

For people who are contracted to do work for us (e.g., psychologists, psychological associates, psychometricians, psychology interns, accountants, clerical staff), we collect information to ensure that we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., paying invoices).  Examples of the type of personal information we collect for these purposes include home address and telephone numbers.  We also collect information related to their professional qualifications and information relevant to ensuring they practice in accordance with all applicable provincial and federal legislation, as well as professional standards of practice.  If mental health practitioners, psychology interns, or contract staff request a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.

How We Use and Disclose of Personal Information

We are committed to protecting the privacy of our clients and staff by following our policies and procedures for and adhering to provincial and federal legislation concerning the collection, storage, and disclosure of personal information.

No personal information is communicated, directly or indirectly, to a third party without your informed and written consent.  Exceptions to this policy include the legal, and/or ethical obligations to:

a) inform a potential victim of violence of a client’s intention to harm.
b) inform an appropriate family member, health care professional or police, if necessary, of a client’s intention to end his or her life.
c) release a client’s file if there is a court order to do so.
d) inform child protection agencies (e.g., Family & Children’s Services) if there is suspicion of a child being at risk or in need of protection due to neglect, or physical, sexual or emotional abuse.
e) report a regulated health professional who has mistreated a client to the professional regulatory body.

The Centre for Psychological Services is regulated by the College of Psychologists of Ontario which might inspect our records and interview our mental health practitioners and staff as part of their ongoing activities in protecting the public interest.  External regulators have their own strict privacy obligations.  Sometimes these activities include inspecting the premises and practices of members of the College to ensure they are meeting all applicable legislative and professional requirements.  This might include reviewing files that include personal information about our clients or other individuals involved in the concern.  Also, like all organizations, various government agencies (e.g., Information and Privacy Commissioner, Human Rights Commission, Revenue Canada, etc.) have the authority to review any files and interview mental health practioners and staff as part of their mandates.  In these circumstances, we would consult with legal professionals in the course of compliance.

The cost of some goods/services provided to clients by our Centre is paid for by third parties (e.g., WSIB, private insurance, motor vehicle insurance, EAP Companies, First Nations and Inuit Health Branch).  These third party payers often have your previous consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.

It is the policy of the Centre that clients have a legal and moral right to know what information is contained about them in their records. Clients or their legal designates can have access to all information identified as pertaining to them (and only them) and which is stored in the client record, with the exception of information that is protected by copyright (e.g., test protocols), information  believed to be potentially harmful to clients, or information that is confidential about or from third parties.  If you request to view your information, we will need to confirm your identity and legal right to have access to the information.  We reserve the right to charge a nominal fee for such requests.  We may ask you to put your request in writing.  If we cannot give you access to your record, we will tell you within 30 days, if possible, and tell you the reason, as best we can, as to why we cannot give you access.

If you believe there is an error in the information in your file, 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 to support corrections.  If changed, a statement of changed information is included in the record.  If the request for a change is denied, the client may file a notice of disagreement in the record.

How We Protect Personal Information

We understand the importance of protecting personal information.  For that reason, we have taken the following steps:

At all times, paper information is either under direct personal supervision or secured in a locked cabinet in a locked, restricted area. Electronic information is either under direct supervision or secured in a locked area at all times.  In addition, passwords are used on computers. Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies (e.g., Canada Post). Electronic information is transmitted either through a direct line or is anonymized or strongly encrypted.  We discourage the emailing or faxing of client information unless explicitly directed to do so by clients. Any files being transported are required to be stored in a locked area (e.g., car trunk, carrying case with a locking mechanism). Mental health practitioners and staff are trained to collect, use, and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy. External consultants with access to personal information must enter into privacy agreements with us that binds them to comply with all of our privacy requirements.

How We Retain and Destroy 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.  However, we do not want to keep personal information any longer than is absolutely necessary, to protect your privacy.

We are required by provincial law to keep client files for ten years following the client’s last contact or, if the client was less than eighteen years of age, for ten years after the client turns 18.  Our client directory (a list of client names and ID numbers) is much more difficult to systematically destroy, but we remove information as soon as we can when it appears that we will not be contacting you again.  If you ask, we will remove such contact information right away.

We destroy paper files containing personal information by shredding.  We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.

If You Need More Information

For more information about our privacy policies and procedures, please contact our Director, Dr. Melanie Parkin, at:

Centre for Psychological Services
University of Guelph
Guelph, ON     N1G 2W1
Telephone: (519) 824-4120   Ext. 52578

If you wish to comment or submit a formal complaint about or privacy practices, you may make it in writing to our Information Officer.  She will acknowledge receipt of your complaint and ensure that it is investigated promptly.  She will also ensure that you are provided with a formal decision and reasons in writing.

This policy will go into effect on January 1, 2004.  The Centre for Psychological Services reserves the right to change the terms of this privacy policy and to make new policy provisions effective for all personal information we maintain.  If this privacy policy is revised, we will post the revised policy in a conspicuous location in our offices.

For more general inquires, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector.  The Commissioner also acts as an ombudsman for privacy disputes.  PIPEDA is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set our here.  There are some rare exceptions to the commitments set out above and you are encouraged to contact the Information and Privacy Commissioner for further information.

INFORMATION AND PRIVACY COMMISSIONER

112 Kent Street
Ottawa, Ontario, K1A 1H3
Telephone: 1-800-282-1376
Fax: 613-947-6850
www.privcom.gc.ca