Privacy policy.
Bloom Child and Youth Counselling is a private practice counselling clinic that collects, uses, modifies, discloses, retains, and disposes of your personal health information under the Personal Health Information Protection Act (PHIPA).
What does this mean?
This means that there are laws that Bloom (and all of Bloom’s therapists) are required to follow to protect your privacy when you receive counselling therapy.
Who do I contact if I have questions or concerns about how personal health information is being managed at Bloom?
Stacey Coene (owner) is the information officer responsible for your personal health information. Stacey can be reached at 519-567-9067 or by email at staceycoene@bloomchildandyouth.com.
Affiliate therapists at Bloom are also designated as agents of your personal health information; therefore, your therapist also plays an active role in collecting, using, modifying, disclosing, retaining, and disposing of your personal health information.
What information about me is collected, used, and disclosed? Why do you collect it?
Any information that helps your therapist achieve a good picture of your mental health needs and therapy goals is collected. This assists your therapist in choosing the most effective therapeutic approaches to use in sessions, and also gives them a baseline so that changes during the course of therapy can be identified. Your personal health information may also be collected to obtain payment for therapy, to conduct quality improvement activities, or to train new therapists.
Two types of information is collected:
Demographic information - this includes any information that helps us identify characteristics of you as a person. This may include your date of birth, name of your caregivers, your address / contact information, and your pronouns.
Health information related to mental health - this includes any information that helps your therapist assess your needs in therapy. This may include presenting concerns, history of mental health concerns, family history, social history, mental health related diagnoses, other service providers involved, medical concerns related to therapy, and strengths.
Can my personal health information be collected without consent?
No, under no circumstances will we collect personal health information without your written or verbal consent, unless it is to keep you safe (see below).
Can my personal health information be disclosed without consent?
No, we cannot disclose your personal health information to anyone without your consent. The only exception is if your therapist reasonably believes that your safety is at risk and is required by law to report the information to others to keep you safe, or if your personal health information is subpoenaed by a court of law.
Your therapist can also share personal health information for statistical purposes, but can only do so as non-identifying information. For example, Bloom may collect data on the ages of clients referred to the practice to determine trends in referrals, but can only share that data with others without names attached.
How do you ensure that my personal health information is protected?
We have various safeguards to protect your personal health information:
Administrative
Bloom has specific policies around the management of personal health information and therapists are trained in these policies.
Bloom has non-clinical contractors (such as office cleaners, bookkeepers, accountants) sign a privacy agreement that is in effect during the duration of their services.
The physical layout of the Bloom office ensures that sessions are held in a private room with closed doors, and has a policy that personal health information is not discussed in common areas (such as the lobby area).
Physical
All sessions are conducted in a private room with closed doors.
All written personal health information is stored in a locked drawer, container, filing cabinet, or room, when not in use and the therapist is away.
Any transfer of written personal health information is shared in a sealed envelope and marked confidential.
Any written notes that are no longer required by your therapist will be destroyed using a shredder.
Technical
All electronic personal health information is stored and accessed by your therapist with encryption and is password protected.
All virtual sessions are encrypted within transit.
Transfer of electronic personal health information is shared through encrypted email; however, Bloom cannot guarantee that the recipient of the information uses encrypted email when replying. Bloom only shares information via email with the following conditions: consent is obtained, the message is anonymized, or the information is encrypted in some way.
Our wireless network has up to date transmission encryption.
How long do you keep my personal health information and how do you dispose of it?
Bloom will keep your personal health information for ten years after your 18th birthday. After that time, your electronic information will be deleted and your physical information will be shredded.
How can I access my personal health information?
You can access your personal health information at any time by simply asking your therapist. They will set aside a time to sit with you and go through the information requested and answer any questions you have about the information. If there is any information that is not correct, you can request that your therapist make the corrections in your file. Your therapist, under most circumstances, will be able to make the correction.
Who do I contact if I have a complaint about how my personal health information is being managed?
You can contact Stacey Coene (owner) who is the information health officer of Bloom. She can be contacted at 519-567-9067 or through email at staceycoene@bloomchildandyouth.com. She will go over your complaint with you and advise you of your rights moving forward.
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
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.