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Privacy Policy

At The Waterloo CBT Clinic we are committed to protecting your privacy and safeguarding your Personal Health Information (PHI). This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in accordance with the Personal Health Information Protection Act (PHIPA) in Ontario as well as other applicable laws and regulations.

If you have any questions or concerns about your privacy or this policy, please contact us using the information provided below.

What is “Personal Health Information”?

The practices of psychology and psychotherapy in Ontario are regulated under the provincial Regulated Health Professions Act. As such, all identifiable information collected by a psychologist, psychotherapist or psychological associate about an individual, in the course of practicing their profession, is considered “personal health information” under the Personal Health Information Protection Act, 2004 (PHIPA). Personal health information (PHI) includes information that relates to:

  • an individual’s personal characteristics (e.g. gender, age, address, phone number, family status);
  • physical or mental health (e.g. health history, health conditions, health services received by them);
  • activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).

By law and in accordance with professional standards, we are required to keep a record of all services provided to you, including any significant communication with you. The physical and electronic records are the property of our practice.

1. Collection and Use of Personal Health Information

Our primary purpose for collecting personal information is to provide psychological and psychotherapy services. We collect information from you in order to:

  • provide you with the services you have requested and/or for which you have been referred;
  • maintain contact with you for service-related or future consent purposes; and
  • prevent or offset harm (e.g., asking for an emergency contact).

2. Who Has Access to Your Information

Waterloo CBT Clinic personnel include registered psychologists, registered psychotherapists, and one office administrator. Staff members are only permitted to access information that they require to carry out their duties. The clinic co-directors and office administrator require access to certain information (e.g., your name, contact information, dates of sessions, payments) to carry out administrative duties (e.g., responding to emails and telephone calls from clients, scheduling appointments, billing/issuing receipts, sending and receiving faxes) but do not access information about the clinical services you are receiving or the content of your assessment/treatment sessions. 

Except in extenuating circumstances (e.g., incapacity of your treatment provider), your treating professional is the only person who will ever access information related to the content of your sessions (e.g., session notes, reports from other professionals). We use some service providers that may, in the course of their duties, have limited access to your personal health information. These include Jane and Hushmail tech support, accountants, bookkeepers, and lawyers. Your personal health information is not shared with any of these professionals in carrying out their typical duties but may be necessary in rare situations. Even in these rare situations, we only provide the information that is necessary for their duties and the operation of the clinic.

If you choose to communicate with your clinician by email, be aware that all emails are retained in the logs of both your and our internet service providers. While it is unlikely that someone will be looking at these logs, they are, in theory, available to be read by the system administrator(s) of the internet service provider.

3. Disclosure of Personal Information

The information that you share with your therapist is strictly confidential. This means that we will not release information about you outside of the Waterloo CBT Clinic without your explicit consent. There are, however, several exceptions to confidentiality, as follows:

  • If there is reason to believe that someone is at serious and imminent risk of harming themselves or another person. Keeping you and others safe is always our first priority.
  • If there is reason to believe that a child/adolescent has been abused or is at risk of being abused, your therapist is obligated to report this to the local children’s aid society. This includes physical abuse, sexual abuse, emotional abuse, and/or neglect.
  • If we learn that someone has been sexually abused by a registered health professional, this must be reported to that professional’s regulating body. This can be done without providing your name.
  • If your file is subpoenaed, we are legally required to comply with court orders for the release of records.
  • If the police or the court require our records in the case of a missing person and the records could help locate the missing individual.
  • If there is reason to believe that a resident of a retirement home or long-term care facility has been harmed, put at risk of harm, abused, or neglected, this must be reported to the Ministry of Health and Long-Term Care.
  • If our files are audited by our regulatory body, your file could be reviewed for quality assurance purposes. Such a review would be focused on ensuring that your therapist is following proper guidelines and record keeping polices.

4. Data Security

We take precautions to safeguard your personal information from unauthorized access, use, or disclosure. These measures include:

  • Securing physical access to our clinic and records.
  • Using encryption and secure methods for digital information.
  • Limiting access to your information to authorized staff members only.

5. Retention of Personal Information

Consistent with our Standards of Practice, we retain client files for at least 10 years after the date of last contact. For child and adolescent clients, we retain files for at least ten years after their eighteenth birthday.

Paper files containing PHI are destroyed by confidential shredding. We destroy electronic information by deleting it in a manner that cannot be restored. When hardware is discarded, we ensure that the hard drive is physically destroyed.

6. Your Rights

To access your personal information:

Under Ontario’s privacy laws, you have the right to access any records of your personal health information and to request copies of the information. We reserve the right to charge a reasonable fee for such requests. There are a few exceptions where access to data may be limited:

  • If the physical record contains personal health information about another individual, that individual’s information must be able to be severed from the record before you may access the record. Because of the nature of certain services, severing information in some, but not all places of the record can be difficult and at times impossible. We reserve the right to charge a reasonable fee for such requests.
  • If access is requested to copyrighted psychological test information (e.g., test items, protocols, manuals);
  • If the information could result in serious harm to someone’s treatment or recovery;
  • If the information could result in serious bodily harm to someone;
  • If you are the custodial parent or guardian of a child or adolescent receiving services, you may not access their personal health information if they have been deemed competent and consented to the service on their own (unless the child or adolescent consents). In addition, there are restrictions on custodial parents’/guardians’ access to individual therapy notes regarding their children.

If we cannot give you access to your personal health information, we will advise you within 14 days of the request and provide reasoning for our decision.

To correct or update your personal information:

If you believe that there is a mistake in your personal information, you have the right to ask for it to be corrected. This applies to factual information only and not to any professional opinions we may have formed as part of our assessment/treatment services. We may ask you to provide documentation correcting any erroneous information. Where we agree there is an error, we will make the correction and notify anyone to whom we have sent the incorrect information. Note that the original information cannot be removed and will instead be corrected with an addendum. If we do not agree that there is an error, you may provide a notice of disagreement that will be included in the file, and we will forward that notice to anyone else who received the earlier information.

7. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on our website, and we encourage you to review the policy periodically.

Concerns and Further Information

If you would like more detailed information, would like to access or ask for a correction of your record, have a concern about our privacy policies and procedures, or have a concern about the way your privacy has been handled, please do not hesitate to speak to or email our Health Information Custodians, whose contact information is below.

This privacy policy has been developed in accordance with the Personal Health Information Protection Act, 2004 (PHIPA) and professional regulations and ethical standards.

The Health Information Custodians at the Waterloo CBT Clinic are:

Dr. Dubravka Gavric
Tel: 226-686-0848 ext. 1
Fax: 226-686-0870
Email: dgavric@waterloocbt.ca 

and

Dr. Erin Fallis
Tel: 226-686-0848, ext. 7
Fax: 226-686-0870
Email: efallis@waterloocbt.ca

Further details of the applicable laws, regulations, and standards may be found at the Websites of the Ontario Ministry of Health and Long Term Care (www.health.gov.on.ca), the College of Psychologists of Ontario (www.cpo.on.ca), the Canadian Psychological Association (www.cpa.ca), and the Personal Health Information Protection Act (www.ipc.on.ca).

For more general inquiries, the Information and Privacy Commissioner of Ontario oversees the administration of the privacy legislation in the private sector. The Commissioner can be reached at:

2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Phone (416) 326-3333 or 1-800-387-0073

Web: www.ipc.on.ca E-mail: info@ipc.on.ca