Privacy Policy
THIS NOTICE INVOLVES YOUR PRIVACY RIGHTS AND DESCRIBES HOW INFORMATION ABOUT YOU MAY BE DISCLOSED, AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
I. Confidentiality
As a rule, I will disclose no information about you, or the fact that you are my patient, without your written consent. My formal mental health record describes the services provided to you and contains the dates of our sessions, your diagnosis (provided by other professionals), functional status, symptoms, prognosis and progress, assessments completed, information shared and discussed, and case conceptualizations (treatment plans). Information may also be disclosed to other people within the organization for administrative purposes (i.e., bookings and emails) and no personal health information pertaining to treatment will be accessible to anyone other than the treating professional (administration will only have access to demographic and contact information for purposes of emails and billing purposes). Health care providers are legally allowed to use or disclose records or information for treatment, payment, and health care operations purposes, however, I do not routinely disclose information in such circumstances, so I will require your permission in advance, either through your consent at the onset of our relationship (by signing the attached general consent form), or through your written authorization at the time the need for disclosure arises. You may revoke your permission, in writing, at any time, by contacting me.
The following is considered confidential information:
All matters/documents relating to clients
Contracts
Human resource files and proceedings
Financial information, status, and statements
All information of documentation including those labeled as “confidential”
Requirement of Confidentiality
In accordance with the Personal Health Information Act, sensitive personal client information is handled in a confidential and appropriate manner and several precautions are in place to ensure confidentiality of such information (information is locked, computer and information is encrypted, computer screens are shielded when not being used to guard from unauthorized viewing; special precautions are taken when transporting confidential documentation).
II. “Limits of Confidentiality”
Possible Uses and Disclosures of Mental Health Records without Consent or Authorization
There are some important exceptions to this rule of confidentiality – some exceptions required by law. If you wish to receive mental health services from me, you must sign the attached form indicating that you understand and accept my policies about confidentiality and its limits. You may reopen the conversation at any time during our work together.
I may use or disclose records or other information about you without your consent or authorization in the following circumstances, either by policy, or because legally required:
· Emergency: If you are involved in in a life-threatening emergency and I cannot ask your permission, I will share information. I will also share information if you are someone else reports being at imminent risk of harm.
· Child Abuse Reporting: If I have reason to suspect that a child is abused or neglected, I am required to report the matter immediately to Children’s Aid Society.
· Adult Abuse Reporting: If I have reason to suspect that an elderly or an individual with developmental disabilities is abused, neglected or exploited, I am required by law to immediately make a report and provide relevant information to the appropriate governing body.
· Health Oversight: Laws require professionals to report misconduct by a health care provider of their own profession. By policy, I also reserve the right to report misconduct by health care providers of other professions. By law, if you describe unprofessional conduct by another mental health provider of any profession, I am required to explain to you how to make such a report. If you are yourself a health care provider, I am required by law to report to your licensing board that you are in treatment with me if I believe your condition places the public at risk. Licensing Boards have the power, when necessary, to subpoena relevant records in investigating a complaint of provider incompetence or misconduct.
· Court Proceedings: If the therapist receives a subpoena, warrant, summons, or request for records or testimony, I will notify you and may be subjected to release the file. In such cases, the therapist will have a discussion will occur regarding options and next steps.
· Records of Minors: Minors who attend therapy are also subject to similar confidentiality regulations as adults. If the individual is under the age of 18, confidentiality is maintained for all individuals unless otherwise granted by the individual (under the premise of mature minor). Thus, parents regardless of custody may be denied access to their child’s records in order to allow for the safety within the therapeutic relationship.
Safeguarding of Personal Information
Client information is stored electronically and is protected by password on OWL Practice. Access to this electronic database is limited for added security. Two factor authentication is required for access. Any information collected in physical form is locked and shredded upon completion of inputting data electronically. Information located electrically and physically are only accessible to the treating therapist. Demographic information and contact information may be accessible for administrative and billing purposes and such individuals are required to uphold the confidentiality agreement. Virtual therapy is completed via a PHIPA compliant, encrypted website to ensure and protect client privacy and confidentiality.
Notice of Theft, Loss, Unauthorized Access, and Use of Disclosure of Client Information
The treating therapist will immediately report any theft, loss, unauthorized access, use or disclosure of personal information to individuals immediately upon awareness. Communication will be received either verbally or via email. Upon awareness, the treating therapist will investigate immediately into the breach and notify those involved as soon as possible. Any verbal contact will be logged into client records and may be followed up with a letter.
Inquires or Complaints
Any questions, comments, or complaints can be made directly to the treating therapist who can provide further information and support regarding this.
III. Patient’s Rights and Provider’s Duties:
· Right to Request Restrictions-You have the right to request restrictions on certain uses and disclosures of protected health information about you. You also have the right to request a limit on the medical information I disclose about you to someone who is involved in your care or the payment for your care. If you ask me to disclose information to another party, you may request that I limit the information I disclose. However, I am not required to agree to a restriction you request. To request restrictions, you must make your request, and tell me: 1) what information you want to limit; 2) whether you want to limit my use, disclosure or both; and 3) to whom you want the limits to apply.
· Right to Receive Confidential Communications by Alternative Means and at Alternative Locations — You have the right to request and receive confidential communications of PHI by alternative means and at alternative locations. (For example, you may not want a family member to know that you are seeing me. Upon your request, I will send your bills to another address. You may also request that I contact you only at work, or that I do not leave voice mail messages.) To request alternative communication, you must make your request in writing, specifying how or where you wish to be contacted.
· Right to an Accounting of Disclosures – You generally have the right to receive an accounting of disclosures of PHI for which you have neither provided consent nor authorization (as described in section III of this Notice). On your written request, I will discuss with you the details of the accounting process
. · Right to Inspect and Copy – In most cases, you have the right to inspect and copy your medical and billing records. To do this, you must submit your request in writing. If you request a copy of the information, I may charge a fee for costs of copying and mailing. I may deny your request to inspect and copy in some circumstances. I may refuse to provide you access to certain psychotherapy notes or to information compiled in reasonable anticipation of, or use in, a civil criminal, or administrative proceeding.
· Right to Amend – If you feel that protected health information I have about you is incorrect or incomplete, you may ask me to amend the information. To request an amendment, your request must be made in writing, and submitted dot me. In addition, you must provide a reason that supports s your request. I may deny your request if you ask me to amend information that: 1) was not created by me; I will add your request to the information record; 2) is not part of the medical information kept by me; 3) is not part of the information which you would be permitted to inspect and copy; 4) is accurate and complete.
· Right to a copy of this notice – You have the right to a paper copy of this notice. You may ask me to give you a copy of this notice at any time. Changes to this notice: I reserve the right to change my policies and/or to change this notice, and to make the changed notice effective for medical information I already have about you as well as any information I receive in the future. The notice will contain the effective date . A new copy will be given to you or posted in the waiting room. I will have copies of the current notice available on request.
Complaints: If you believe your privacy rights have been violated, you may file a complaint. To do this, you must submit your request in writing to my office. You may also send a written complaint to the College of Registered Psychotherapists of Ontario