Robertson Therapy & Counselling— PRIVACY POLICY

Privacy of personal information is an important principle to Robertson Therapy & Counselling. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We try to be open and transparent about how we handle personal information. This document describes our privacy policies. 

 

WHAT IS PERSONAL HEALTH INFORMATION?

Personal health information is information about an identifiable individual. Personal health information includes information that relates to:  

  • the physical or mental health of the individual (including family health history);  
  • the provision of health care to the individual (including identifying the individual’s health care provider);  
  • a plan of service under the Home Care and Community Services Act, 1994;  
  • payments or eligibility for health care or coverage for health care; 
  • the individual’s health number; 
  • or  the identification of the individual’s substitute decision-maker. 

 

WHO WE ARE

Our organization, Robertson Therapy & Counselling, includes at the time of writing 8 regulated professionals and one support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal health information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, lawyers, temporary workers to cover holidays, credit card companies, website managers and cleaners. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

 

WHY WE COLLECT PERSONAL HEALTH INFORMATION 

We collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal health information is to provide psychotherapy. 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 health needs are, to advise them of their options and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that are occurring over time. We also collect, use and disclose personal health information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

Related Purpose #1: To obtain payment for services or goods provided. Payment may be obtained from the individual, OHIP, WSIB, private insurers or others. 

Related Purpose #2: To conduct quality improvement and risk management activities. We review client files to ensure that we provide high quality services, including assessing the performance of our staff. External consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may conduct audits and quality improvement reviews on our behalf. 

Related Purpose #3: To promote our clinic, new services, special events and opportunities (e.g. a seminar or conference) that we have available. We will always obtain express consent from the client prior to collecting or handling personal health information for this purpose. 

Related Purpose #4: To comply with external regulators. Our professionals are regulated by the College of Regulated Psychotherapists of Ontario who may inspect our records and interview our staff as a part of its regulatory activities in the public interest. The CRPO has its own strict confidentiality and privacy obligations. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting illegal behaviour to the authorities. In addition, we may be required by law to disclose personal health information to various government agencies (e.g. Ministry of Health, children’s aid societies, Canada Customs and Revenue Agency, Information and Privacy Commissioner, etc.). 

Related Purpose #5: To educate our staff and students. We value the education and development of future and current professionals. We will review client records in order to educate our staff and students about the provision of health care. 

Related Purpose #6: To fundraise for the operations of our organization, with the express or implied consent of our clients. If we rely on implied consent, we will only use the client’s name and address, we will provide clients with an easy opt-out option, and we will not reveal anything about our client’s health in the request. 

Related Purpose #7: To facilitate the sale of our organization. If the organization or its assets were to be sold, the potential purchaser would want to conduct a “due diligence” review of the organization’s records to ensure that it is a viable business that has been honestly portrayed. The potential purchaser must first enter into an agreement with the organization to keep the information confidential and secure and not to retain any of the information longer than necessary to conduct the due diligence. Once a sale has been finalized, the organization may transfer records to the purchaser, but it will make reasonable efforts to provide notice to the individual before doing so. 

 

PROTECTING PERSONAL INFORMATION

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

  • Paper information is either under supervision or secured in a locked or restricted area.
  • Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, strong passwords are used on all computers and mobile devices.
  • Personal health information is only stored on mobile devices if necessary. All personal health information stored on mobile devices is protected by strong encryption.  
  • We try to avoid taking personal health information home to work on there. However, when we do so, we transport, use and store the personal health information securely.
  • Paper information is transferred through sealed, addressed envelopes or boxes by reputable companies with strong privacy policies.  
  • Electronic information is either anonymized or encrypted before being transmitted.  
  • Our staff members are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.  
  • We do not post any personal information about our clients on social media sites and our staff members are trained on the appropriate use of social media sites.  
  • External consultants and agencies with access to personal information must enter into privacy agreements with us. 

 

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. However, in order to protect your privacy, we do not want to keep personal information for too long. 

We keep our client files for at least ten years from the date of the last client interaction or from the date the client turns 18. 

We destroy paper files containing personal health information by cross-cut shredding. We destroy electronic information by deleting it in a manner that it cannot be restored. 

When hardware is discarded, we ensure that the hardware is physically destroyed or the data is erased or overwritten in a manner that the information cannot be recovered. 

 

YOU CAN LOOK AT YOUR RECORDS

With only a few exceptions, you have the right to see what personal information we hold about you, by contacting info@robertsontherapy.ca. 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., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge $30.00 for the first twenty pages of records and 25 cents for each additional page. 

We may ask you to put your request in writing. We will respond to your request as soon as possible and generally within 30 days, if at all possible. If we cannot give you access, we will tell you the reason, as best we can, as to why. 

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. At your request and where it is reasonably possible, we will notify anyone to whom we sent this information (but we may deny your request if it would not reasonably have an effect on the ongoing provision of health care). 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. 

 

IF THERE IS A PRIVACY BREACH

While we will take precautions to avoid any breach of your privacy, if there is a loss, theft or unauthorized access of your personal health information we will notify you. Upon learning of a possible or known breach, we will take the following steps:

  • We will contain the breach to the best of our ability, including by taking the following steps if applicable  
    • Retrieving hard copies of personal health information that have been disclosed
    • Ensuring no copies have been made 
    • Taking steps to prevent unauthorized access to electronic information (e.g., change passwords, restrict access, temporarily shut down system)  
  • We will notify affected individuals 
    • We will provide our contact information in case the individual has further questions 
    • We will provide the Commissioner’s contact information and advise the affected individual of their right to complain to the Commissioner  
  • We will investigate and remediate the problem, by: 
    • Conducting an internal investigation
    • Determining what steps should be taken to prevent future breaches (e.g. changes to policies, additional safeguards)
    • Ensuring staff is appropriately trained and conduct further training if required 

Depending on the circumstances of the breach, we may notify and work with the Information and Privacy Commissioner of Ontario. If we take disciplinary action against one of our practitioners (or revoke or restrict the privileges or affiliation of one of our practitioners) for a privacy breach, we are required to report that to the practitioner’s regulatory College. We may also report the breach to the relevant regulatory College if we believe that it was the result of professional misconduct, incompetence or incapacity. 

 

DO YOU HAVE QUESTIONS OR CONCERNS? 

Our Information Officers, Kyli Robertson & Mandie Robertson, can be reached at: info@robertsontherapy.ca. They 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. They will acknowledge receipt of your complaint, and ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

You also have the right to complain to the Information and Privacy Commissioner of Ontario if you have concerns about our privacy practices or how your personal health information has been handled, by contacting: 

Information and Privacy Commissioner/Ontario 

2 Bloor Street East, Suite 1400 34 

Toronto, Ontario M4W 1A8 

Telephone: Toronto Area (416/local 905): (416) 326-3333 

Long Distance: 1 (800) 387-0073 (within Ontario) 

TDD/TTY: (416) 325-7539 FAX: (416) 325-9195 

www.ipc.on.ca 

This policy is made under the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3. It is a complex statute and provides some additional exceptions to the privacy principles that are too detailed to set out here.

PRIVACY POLICY – SITE RELATED

This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site. We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

WHAT IS CONSIDERED PERSONAL INFORMATION?

Personal information refers to information such as your name, address, email address, geographic location, purchase history, gender, credit card information and browsing habits on our site.

WHAT INFORMATION DO WE COLLECT?

We collect information from you when you register on the site, place an order, enter a contest or sweepstakes, respond to a survey or communication such as e-mail, or participate in another site feature.

When ordering or registering, we may ask you for your name, e-mail address, mailing address, phone number, credit card information or other information. You may, however, visit our site anonymously.

Like many websites, we use cookies to enhance your experience and gather information about visitors and visits to our websites. Please refer to the do we use cookies section below for information about cookies and how we use them.

WE MAY PROCESS THE FOLLOWING CATEGORIES OF PERSONAL DATA ABOUT YOU:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as sales offers, affiliate offers, free contests with give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

SENSITIVE DATA

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

You can ask us or third parties to stop sending you marketing messages at any time simply by unsubscribing from emails via the unsubscribe button which can be found at the bottom of each email or by sending info@robertsontherapy.ca  an email with your request to stop receiving emails.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

DISCLOSURE OF YOUR PERSONAL DATA:

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers.

  • Government bodies that require us to report processing activities.

  • 3rd party technology platforms and advertisers that support the running and growth of Robertson Therapy & Counselling 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

HOW DO WE USE YOUR INFORMATION?

We may use the information we collect from you when you register, purchase products, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

  • To personalize your site experience and to allow us to deliver the type of content and product offerings in which you are most interested.

  • To allow us to better service you in responding to your customer service requests. To quickly process your transactions.

  • To administer a survey or other site feature.

  • If you have opted-in to receive our email newsletter, we will send you educational and marketing emails.

  • If you would no longer like to receive promotional email from us, please refer to the “How can you opt-out, remove or modify information you have provided to us?” section below.

  • If you have not opted-in to receive email newsletters, you will not receive these emails.

Visitors who register or participate in other site features such as marketing programs will be given a choice whether they would like to be on our email list and receive e-mail communications from us.

DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being customers.In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

COOKIES

As you browse the Robertson Therapy & Counselling website, advertising cookies will be placed on your computer so that we can understand what you are interested in. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. To opt out of cookies, find and select the settings tab of your internet browser and click “block third party cookies and site data” or de-select the “accept cookies” box.

HOW DO WE PROTECT VISITOR INFORMATION?

We implement a variety of security measures to maintain the safety of your personal information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. When you place orders or access your personal information, we offer the use of a secure server. All sensitive/credit information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed as stated above.

DO WE DISCLOSE THE INFORMATION WE COLLECT TO OUTSIDE PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice, except as described below. It does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

HOW CAN YOU OPT-OUT, REMOVE OR MODIFY INFORMATION YOU HAVE PROVIDED TO US?

To modify your email subscriptions, you can find an unsubscribe link at the bottom of each email. Please note that due to email production schedules you may receive any emails already in production. Please note that we may maintain information about an individual sales transaction in order to service that transaction and for record keeping.

THIRD PARTY LINKS

In an attempt to provide you with increased value, we may include third party links on our site. These linked sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these linked sites (including if a specific link does not work).

YOUR ACCESS TO AND CONTROL OVER INFORMATION

You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website:

  • See what data we have about you, if any.

  • Change/correct any data we have about you.

  • Have us delete any data we have about you.

  • Express any concern you have about our use of your data.

CHANGES TO OUR POLICY

If we decide to change our privacy policy, we will post those changes on this page. Policy changes will apply only to information collected after the date of the change. This policy was last modified on June 9, 2023 .

ONLINE PRIVACY POLICY

This privacy policy refers only to information collected through our websites, and does not apply to information collected in person at events, coaching calls or social media.

YOUR CONSENT

In using our site, you agree to our privacy policy.

QUESTIONS AND FEEDBACK

We welcome your questions, comments, and concerns about privacy. Please send us any and all feedback pertaining to privacy, or any other issue via email at: info@robertsontherapy.ca