CLIENT PRIVACY POLICY

OUR COMMITMENT TO PRIVACY 

Safeguarding the personal information of our clients is of fundamental importance to Psych Consult.  We are committed to meeting the privacy standards as set forth by our regulatory/licensing body (The College of Health and Care Professionals of BC), guidelines from the Canadian Psychological Association, and federal and provincial law pertaining to psychological services.

This policy outlines Psych Consult’s policies and practices regarding the collection, use, disclosure, and protection of personal information, including the steps that we have taken to ensure such information is handled appropriately and securely. 

THE MEANING OF PERSONAL INFORMATION

“Personal information” refers to any information about an identifiable individual that is collected, used, disclosed or processed by Psych Consult in connection with its services, operations or administration, and includes information about Psych Consult’s past, present and prospective patients and (in some cases) their family members.

Examples of personal information include: name, age, contact information, medical and mental health history, information about substance use, and treatment plans. 

OUR ACCOUNTABILITY FOR PRIVACY

Maintaining the privacy and security of your personal information is important to us.  Under the BC Personal Information Protection Act (“PIPA”), we are accountable for the protection of the personal information within our control.  

Anyone with questions about how we use, process, manage, and protect personal information may contact our Privacy Officer for more information. We are committed to responding to your questions and concerns. 

THE BASIS ON WHICH WE COLLECT PERSONAL INFORMATION 

When you visit our website, we may automatically collect and store information. This information may include the length, data and time of your visit, and the pages you looked at. 

We may also collect information in a non-automatic way when you contact us (e.g., by telephone or email), when you perform certain functions on our website or if you complete any online forms. This information may be collected using the following methods: 1) Creating an account in the Jane App 2) Completing forms in the Jane App 3) Emailing us 4) Calling us. 

We collect, use and disclose personal information with the knowledge and consent of our clients, except in circumstances in which applicable privacy or other laws permit or require us to collect, use, and disclose personal information without consent. By interacting with us through email or by phone you are voluntarily providing us with your personal information and thereby giving your informed consent for us to collect, use and store for the purposes only outlined in this Privacy Policy.  

Your consent to our collection, use, or disclosure of personal information can be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice.  The withdrawal of consent should be in written form if possible. Those who withdraw consent to the collection, use or disclosure of their personal information should be aware that this may impact the services we are able to provide.  Also, you may not be permitted to withdraw consent to the collection of personal information that we are required by law to collect and maintain.  Questions about withdrawing consent should be directed to our Privacy Officer. We will process your request promptly and ensure that your personal information is no longer used or disclosed, except as required or permitted by law.

THE PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION 

The information we collect automatically is used to help us make our website more accessible and easier to use for Search Engine Optimization. 

Otherwise, we collect, use and disclose personal information about patients for purposes that include: 

• to provide clinical services;
• to communicate with you about the services we provide to you;
• to process payments;
• to respond to complaints or concerns;
• for safety and investigative purposes;
• to facilitate consultations with other health care professional when requested and permitted by you;
• to comply with our legal and professional obligations.

The personal information that we collect for the above purposes may include the following.

• Name, contact information and identity information;
• Emergency contact and medical information;
• Medical and mental health history; 
• Information that you supply to us about your life, lifestyle, family or mental health;
• Information collected in connection with our security and video surveillance systems;
• Financial and payment information, where needed to process payments, including through insurance and benefits providers.

HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION

Psych Consult limits the personal information it collects to information that is related to and necessary for carrying out its programs and activities or for other purposes authorized by applicable laws. Psych Consult seeks to collect personal information by fair, lawful, and transparent means, including by collecting personal information directly from the individual, except where otherwise authorized by applicable laws.

WHO HAS ACCESS TO YOUR PERSONAL INFORMATION

Psych Consult limits the internal and external use and sharing of personal information to what is required or authorized in the circumstances.  Psych Consult only uses or discloses personal information for the purposes for which it was collected, except with the individual’s consent or as otherwise required or permitted by applicable laws. If you follow hyperlinks from our website to another website, please note that we are not responsible for and have no control over their privacy policies and practices. 

We may share personal information with our staff and service providers to support the delivery of services or Clinic management and administration.  We do so on a confidential and need-to-know basis.

ACCURACY AND CORRECTION

We make reasonable efforts to ensure that personal information is accurate and current, and we may contact you from time to time to ensure your information is complete and up to date.  To help us maintain the accuracy of your personal information, we encourage you to inform us promptly of any changes. Where appropriate, we may also verify information directly with you, particularly if it is being used to make decisions that affect you. You have the right to request the correction of your personal information by contacting our Privacy Officer, and Psych Consult will respond to such requests in accordance with the requirements of PIPA. Upon receiving your request, we will take reasonable steps to investigate and, if necessary, correct the information. If we do not agree with the requested correction, you may ask us to attach a statement of disagreement to the record. 

HOW LONG WE RETAIN PERSONAL INFORMATION

Consistent with requirements for psychologists in B.C., we keep your clinical file for at least seven years after your case is closed. When it is no longer needed for these purposes, it will be securely destroyed. Referral information will be stored for a minimum of one year, in accordance with PIPA section 35(1). Following the one-year period, referral information will be deleted from our email server. 

HOW WE PROTECT YOUR PERSONAL INFORMATION

We are committed to protecting the personal information that we collect, use, share and store about you.  We maintain safeguards that are appropriate to the sensitivity of the personal information we collect, use and maintain.  Such security safeguards include physical, organizational, and technological security. All client information is stored in an individual client fie which is stored electronically and encrypted. Data gathered electronically is gathered through the Jane software program. This program is a secured platform in Canada used by many healthcare professionals. All client information is encrypted using 256-bit encryption (the same level of security that your bank uses to transfer information) and stored on secure SOC 2-audited Canadian servers. Jane is accessed by your clinician using a private account secured by a username and password, as well as two-factor authentication. We also use Hushmail by Hush Communications Canada, Inc. Hushmail is a secure email system that allows for messages to be sent and received with industry-standard OpenPGP encryption. Communication between the Hushmail user and Hushmail servers use secure A+ grade SSL/TLS connection (rated by Qualysys SSL Labs). Data is never sold, emails are never analyzed to display advertising, and the user IP address remains invisible. Like Jane, Hushmail data is stored only in Canada under the protection of Canadian Law, and is accessed by your clinician using a username, password, and two-factor authentication. While we take all reasonable precautions to ensure that personal information is secure and that all users are protected, there always remains the risk of harm. The internet as a whole can be insecure at times and therefore, we are unable to guarantee the security of user data beyond what is reasonably practical. 

ACCESSING YOUR PERSONAL INFORMATION

Under PIPA, you have the right to request access to your own personal information.  Requests may be submitted in writing to the Privacy Officer at Psych Consult, Dr. Brooke Seal.  Psych Consult will receive and respond to such requests in accordance with the requirements of PIPA or, where applicable, other comparable laws. Requests will be responded to within the time limits set by PIPA, typically within 30 business days. If we require more time, we will inform you of the reason for the delay and the expected response date. 

Psych Consult reserves the right to deny access to some personal information or records where permitted under applicable laws, such as where the disclosure of information may threaten someone else’s safety, mental or physical health, or where disclosure could be harmful to the personal privacy of a third party. If we deny your request, we will provide a written explanation outlining the reasons for the refusal and inform you of your right to challenge the decision. 

BREACH NOTIFICATION

We have procedures in place to address and respond to any actual or suspected privacy breach, including to contain, evaluate and notify. We will provide appropriate notices of any such incidents as required and in accordance with applicable privacy laws.

QUESTIONS, CONCERNS AND COMPLAINTS 

Questions, concerns, and complaints about privacy, confidentiality, and personal information handling policies and practices of Psych Consult should be directed to the Privacy Officer using the contact information set out above. Complaints must be submitted in writing and should include your name, contact information, a description of your concern, and any relevant details or documents. Once we receive your complaint, we will acknowledge receipt and begin an internal investigation. We aim to resolve all complaints in a fair, transparent, and timely manner – typically within 30 business days. If additional time is required, we will notify you of the reason for the delay and provide an updated timeline. You have the right to seek assistance from the Office of the Information and Privacy Commissioner for British Columbia.

MODIFICATIONS 

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are aware of any updates.