Privacy of personal information is an important principle to Dr. Naomi Slonim, C.Psych. and Associates. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.
What is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information that relates to: an individual’s personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status); health (e.g., health history, health conditions, health services received by them); or, activities and views (e.g., religion, politics, 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). This is not protected by privacy legislation.
Who We Are
Our organization, Dr. Naomi Slonim, C.Psych., includes at the time of writing one Psychologist and one Psychometrist. We use a number of consultants that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, receptionists, office security and maintenance, bookkeepers and accountants, website managers, and lawyers. 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.
We Collect Personal Information: Primary Purposes
About Clients
Like all Psychologists, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide psychological treatment. 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 occur over time. It would be rare for us to collect such information without the client’s express consent, but this might occur in an emergency (e.g., the client is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our client and we have no reason to believe that the message is not genuine).
About Members of the General Public
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 website uses cookies as follows:
- Cookies that are required for the website to operate properly. If these are deactivated, the website will not function properly and may not be useable to that user.
- Performance cookies are used to monitor website performance. They allow us to correct errors and optimize our website for the best possible user experience.
You are able to disable cookies directly in your website browser.
Visit www.AboutCookies.org for information.
Personal information is also collected and used for purposes related to or secondary to my primary purposes. The most common examples of and secondary purposes include:
- Psychologists are regulated by the College of Psychologists of Ontario who may inspect my records and interview me as a part of their regulatory activities in the public interest. In addition, as a Psychologist, I am required to report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or my own. Also, my College believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about clients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review my files and interview me as a part of their mandates. In these circumstances, I may consult with other professionals (e.g., lawyers).
- The cost of some services I provide to clients might be paid for by third parties (e.g., private insurance). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
- Client information is processed by third-party data servers for administrative purposes. These purposes may include: emailing invoices and/or receipts, client file management (e.g. writing session notes), and clinical testing (e.g. assessment administration and testing).
- Clients may have questions about my services after they have been received. In responding to these questions or providing future services, my previous records are helpful.
You can choose not to be part of some of these related or secondary purposes (e.g., by paying for services at the time of delivery or in advance). I do not, however, have a choice about some of these related or secondary purposes (e.g., external regulation).
Protecting Personal Information
I understand the importance of protecting personal information. For that reason, I have taken the following steps:
- Paper information is secured in a locked or restricted area.
- Electronic hardware is secured. In addition, drives are encrypted.
- Paper information is transmitted through sealed, addressed envelopes.
- Faxes and emails will only be transmitted after discussing associated risks with you.
- I will collect, use and disclose personal information only as necessary to fulfil my duties and in accordance with this privacy policy.
Retention And Destruction Of Personal Information
I must retain personal information for some time to ensure that I can answer any questions you might have about the services provided and for my own accountability to external regulatory bodies. For these purposes, I will retain client information for a minimum of ten years after the last contact for adult clients, and for ten years past the date they turn 18 years of age for clients who are children when service is provided. The Standards of the College of Psychologists of Ontario also requires that I retain client records for this period of time.
I will destroy paper files containing personal information by shredding. I destroy electronic information by deleting it and, when the hardware is discarded, will make efforts to ensure that the hard drive is physically destroyed.
You Can Look At Your Information
With only a few exceptions, you have the right to see your personal information. I will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). If I do not know you, I will need to confirm your identity, before providing you with this access.
If there is a problem I may ask you to put your request in writing. If I cannot give you access, I will tell you the reason, as best I can, in a timely manner.
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 professional opinions I may have formed. I may ask you to provide documentation that my files are inaccurate. Where I agree that a mistake has been made, I will make the correction and notify anyone to whom this information has been sent. If I do not agree that a mistake has been made, I will still agree to include in my file a brief statement from you on the point and I will forward that statement to anyone else who received the earlier information.
Do You Have A Question?
As the Information Officer for my private practice I can be reached at 416-624-2670.
If you wish to make a formal complaint about these privacy practices, please notify me. I will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal written decision with reasons.
If you have a concern about the professionalism or competence of my services I would ask you to discuss those concerns with me. However, if I cannot satisfy your concerns, you are entitled to complain to my regulatory body:
The College of Psychologists of Ontario
110 Eglinton Avenue West, Suite 500
Toronto, ON, M4R 1A3
Phone: 416-961-8817/800-489-8388
Fax: 416-961-2635
www.cpo.on.ca
This policy is made under the Personal Information Protection and Electronic Documents Act. This is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street
Ottawa, Ontario K1A 1H3
Phone (613) 995-8210 | 800-282-1376 |
Fax (613) 947-6850 | TTY (613) 992-9190
www.privcom.gc.ca