David Latour, Psychologist
Privacy Policy
As a psychologist operating my own private practice, I understand the importance of ensuring the privacy of personal information. I am committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the services I provide. I also strive to be open and transparent as to how personal information is handled. This document describes my privacy policies.
What is personal information?
Personal information is information about an identifiable individual. It includes information that relates to an individual's personal characteristics (e.g., gender, age, date of birth, home address or phone number); physical and mental health (e.g., health history, health conditions, health services received by them); or activities and views (e.g., occupation/profession, opinions and concerns expressed by an individual). Personal information is different from business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.
Primary purposes for collecting personal information
About Clients
Like all psychologists, I collect, use, and disclose personal information in order to provide psychological services to my clients. For my clients, the primary purpose of collecting personal information is to provide psychological treatment. For example, I collect information about clients' psychological, social, and health functioning (past and current) in order to help me to assess what their psychological needs are, to advise them of their options, and then to provide the care that they choose to have. A second primary purpose is to obtain a baseline and ongoing record of psychological functioning so that in providing psychological services I can monitor treatment progress and identify changes that occur over time.
About Members of the General Public
For members of the general public, my primary purpose for collecting personal information is to make them aware of the services that I offer in general. On my web site, I only collect the personal information you provide and only use that information for the purpose you gave it to me, e.g., to respond to your e-mail message.
About Contract Staff
For people who are contracted to do work for me (e.g., temporary workers), my primary purpose for collecting personal information is to ensure that I can contact them in the future (e.g., new assignments) and for necessary work-related communication (e.g., sending out paycheques). Examples of the type of personal information I collect for those purposes include resumes, home addresses, and telephone numbers. If contract staff wish a letter of reference or an evaluation, I will collect information about their work related performance and provide a report as authorized by them.
It would be rare for me to collect or disclose personal information without the client's express consent, but this might occur in an emergency (in which case the client would be notified in writing as soon as possible) or if I 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 I have no reason to believe that the message is not genuine) or to investigate a possible breach of law (e.g., if a theft were to occur in my office).
Additional purposes for collecting personal information
Like most psychologists, I also collect, use, and disclose personal information for purposes related to or secondary to my primary purposes. The most common examples of my related and secondary purposes are as follows:
- To invoice clients for services that were not paid for at the time, to process credit card payments, or to collect unpaid accounts.
- To call clients after the termination of ongoing treatment to follow-up on their progress.
- To comply with the College of Psychologists of Ontario, of which I am a member, who may inspect my records and interview me as a part of their regulatory activities in the public interest.
- To comply with various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.), who have the authority to review my files and interview me as a part of their mandates. In these circumstances, I may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to me.
- To access third-party payers (e.g., insurance companies) for payment of services.
- To provide answers to clients who may have questions about services after they have been received. The Standards of Professional Conduct of the College of Psychologists of Ontario requires that records be retained for at least 10 years past the date of last contact for an adult client, and for clients who are children, at least 10 years past the date at which they would turn 18.
Protecting personal information
I understand the importance of protecting personal information. For that reason, your personal information will be safeguarded as follows:
- Paper information is either under supervision or secured in a locked filing cabinet or in a locked area.
- Electronic hardware is either under supervision or secured in a locked area. In addition, passwords are used on computers.
- Paper information is transmitted through sealed, addressed envelopes marked "confidential".
- Contract staff are trained to collect, use, and disclose personal information only as necessary to fulfill their duties and in accordance with this privacy policy.
- Facsimile transmissions have a cover page which contains warnings and appropriate steps to be taken if the transmission is received in error.
Limits to protection of private information
Limits to the protection of private information include: legally mandated disclosure to Children's Aid Society, College of Psychologists of Ontario and Court orders to release information, and search warrants for a file in a criminal or a legal case.
Retention and destruction of personal information
I need to retain personal information to ensure that I can answer any questions you might have in the future and for my own accountability to external regulatory bodies; however, I do not want to keep personal information too long in order to protect your privacy.
Given that, as stated above, the Standards of Professional Conduct of the College of Psychologists of Ontario requires that records be retained for at least 10 years past the date of last contact for an adult client, and for clients who are children, at least 10 years past the date at which they would turn 18, client files will be retained for a minimum of 10 years and a maximum of 12 years, to permit time for destruction of the records and to protect your privacy by not keeping the client files for too long. I keep any personal information relating to my general correspondence (i.e., with people who are not clients) for 3 years after cessation of the contract or marketing activities (e.g., web site).
I destroy paper files containing personal information by shredding. I destroy electronic information by deleting it, and when the hardware is replaced or discarded, I 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 what personal information I hold about you. Often, all you have to do is ask. I will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). I reserve the right to charge a nominal fee for such requests. 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 within 30 days if at all possible and tell you the reason, as best I can, as to why I 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 I may have formed. I may ask you to provide documentation that my files are wrong. Where I agree that I made a mistake, I will make the correction and notify anyone to whom I sent this information. If I do not agree that I have made a mistake, I will still agree to include in your file a brief statement from you on the point and I will forward that statement to anyone else who received the earlier information.
If you have a question
I am the Information Officer and I can be reached at:
150 Montreal Road, Suite 214
Ottawa, ON K1L 8H2
Tel.: (613) 741-8696
Fax.: (613) 741-3707
Email: david@davidlatour.ca
I will attempt to answer any questions or concerns that you might have.
If you wish to make a formal complaint about my privacy policies, you may make it in writing to me. I will acknowledge receipt of your complaint, ensure that it is investigated promptly, and I will provide you with a formal written decision with reasons.
If you have a concern about the professionalism or competence of my services or my mental or physical capacities, I would ask that you first discuss the concern 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
Tel.: (800) 489-8388
Fax.: (416) 961-2635
Email: cpo@cpo.on.ca
Website: www.cpo.on.ca
This policy is made under the Personal Information Protection and Electronic Documents Act. It 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, ON K1A 1H3
Tel.: (800) 282-1376
Fax.: (613) 947-6850
Website: www.privcom.gc.ca
Last updated: March 24, 2004