Privacy of personal information is an important principle to us. We are 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. This document describes our privacy policies.

Use and Disclosure of Personal Information

No personal information will be 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:

• Inform a potential victim of violence of a client’s intention to harm.
• Inform an appropriate family member, health care professional or police if necessary of a client’s intention to end his or her life.
• Release a client’s file if there is a court order to do so.
• Inform Child and Family 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.
• Report a regulated health professional who has sexually abused a client to the professional’s regulatory body.

Dalton Associates Psychological Services is regulated by the College of Psychologists and Behaviour Analysts of Ontario who may inspect our records and interview our mental health practitioners and staff as part of their regulatory activities in the public interest. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals to support the concern (e.g., improper services).

Like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our mental health practitioners and staff as part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.

The cost of some goods/services provided by our practice to clients 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 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 Dalton Associates that clients have a legal and moral right to know what information is contained about them in their record. Clients or their legal designates shall have access to all information which can be identified as pertaining to them (and only them) and which is stored in the client record, with the exception of information that is believed to be harmful or that is confidential about or from third parties. We will need to confirm your identity and legal right to have access to the information. In some cases, this may include producing identification and or proof that you have legal authority to make decisions on behalf of the client. 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 at all possible and tell you the reason, as best we can, as to why we cannot give you access.

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. If changed, a statement of changed information is included in the record. If the request for a change is declined, the client may file a notice of disagreement in the record.

Protecting Personal Information

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

• Paper information is stored 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, 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 encrypted.
• 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 fulfil their duties and in accordance with our privacy policy.
• 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, we do not want to keep personal information too long in order to protect your privacy.

As required by our external regulatory bodies, we retain personal information for 10 years following the client’s last contact or, if the client was less than 18 years of age at the time of last contact, for 10 years following the day the client would have turned 18.

Under our general correspondence, we keep any personal information relating to people who are not clients contained in newsletters, seminars and marketing activities for six months after the newsletter ceases publication or a seminar or marketing activity is over.

To safeguard your privacy, we shred paper files containing personal information. We destroy electronic information by deleting it and when the hardware is discarded, we ensure the hard drive is physically destroyed.

What is Personal Information?

Personal information refers to information about an identifiable individual and 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 not the same as business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

We use a number of consultants and agencies that may, in the course of their duties, have limited access to the personal information we hold. These consultants and agencies include bookkeepers and accountants, lawyers, office maintenance, cleaners, computer consultants, credit card companies, financial institutions, marketing personnel and website managers. We restrict their access to any personal information we hold as much as reasonably possible. We also have a confidentiality agreement with them.