Personal information is information about an identifiable individual. Personal information includes information that is related to an individual’s personal characteristics (e.g., gender, age, home address or phone number, education and training, family circumstances); health (e.g., health history, health conditions, health services received); or, activities and views (e.g., occupation/profession, ideas and concerns expressed by an individual). Personal information is different from business information (e.g., am individual’s business address and telephone number), which is not protected by privacy legislation.

You privacy is important to us at Ivanova Psychology & Associates.
We are committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for services we provide. We are open and transparent as to how we handle personal information. This document describes our privacy policies.

Our Primary Purposes for Collecting Personal Information

We collect, use and disclose personal information only in order to provide psychological services to our clients. For example, we collect information about clients’ health history, including their family history, physical condition and function and social situation in order to help us assess what their mental health needs are to advise them of their options and then to provide the psychological services they choose to have. A second primary purpose is to obtain a baseline and ongoing record of psych0ological functioning so that in providing psychotherapy and psychological services we can monitor treatment progress and identify changes that occur over time.

In some situations, the primary purpose of collecting personal information would be to conduct an assessment to provide a professional opinion about the individual’s psychological functioning. With the client’s consent, the opinion would be reported to the appropriate person or agency, for example, an insurance company, Workplace Safety, and Insurance Board, psychological/legal reports, automobile insurance, Children’s Protection Agency and rehabilitation companies.

It would be rare for us to collect or disclose personal information without the client’s express consent, but this might occur in an emergency (in this case the client would be notified in writing as soon as possible) or if 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 s is not genuine).

For members of the general public who have contacted us, our primary purposes for collecting personal information (e.g., contact numbers) are to make them aware of the range of services available in our clinic and to direct them to the appropriate psychologist or psychotherapist.

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our 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.

Psychologists in supervised or autonomous practice are regulated by the College of Psychologists of Ontario who may inspect our records and interview our psychologist as a part their regulatory activities in the public interest. The College of Psychologists of Ontario has its own strict privacy obligations. 

Similarly, the College of Registered Psychotherapists may conduct an audit of our records as part of quality control and are obliged to follow privacy obligations.

The cost of some services provided by the organization to clients is paid for by third parties (e.g., private insurance, Workplace Safety and Insurance Board automobile insurance, First Nations and Inuit Health Branch, Canadian Forces, Canadian Union of Public Employees). 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 (e.g., Canadian Forces identification, First Nations identification).

We understand the importance of protecting personal information, and we take several steps to ensure its security:

Electronic records that are stored in “Jane”, our patient management system, are encrypted using 256 bit encryption when sent between clinician’s device and Jane’s servers (in the same way as your banking information would be). See https://jane.app/guide/security/security-faq for additional security information related to Jane. 

Administrators, practitioners and patients each access Jane using their own account secured by a username and password. Account owner (Dr. Iryna Ivanova) controls access permissions for each clinician and administrators, which includes control of accessing patient charts, billing records, and schedule records. All members of Ivanova Psychology & Assocaites use and disclose personal information only as necessary to fulfil their duties and in accordance with our privacy policy.

Electronic hardware is either under supervision or secured in a locked or restricted area at all times. Encryption and passwords are used on computers.

We use password protected and encrypted email service (i.e. Hushmail) to transmit some personal information. See https://www.hushmail.com/downloads/ for Hushmail’s security protocols. 
Electronic information is transmitted through a dedicated line only to people and agencies that have a privacy policy.

Paper information is transmitted through sealed, addressed envelopes or boxes by reputable couriers or Canada Post.

In rare cases where Paper information is used, it is either under supervision or secured in a locked or restricted area.

All members of Ivanova Psychology & Associates are trained to collect, use and disclose personal information only as necessary to fulfil their duties and in accordance with our privacy policy.

Limits to the protection of private information include legally mandated disclosure to the Children’s Aid Society, authorities responsible to protect seniors and other vulnerable populations from abuse, the College of Psychologist of Ontario or College or College of Registered Psychotherapists, which regulate the health professions, court orders to release information, search warrants for a file in a criminal or a legal case, and subpoenas.

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.

Clients or other individuals we deal with may have questions about our services after they have been received. We also provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful. We retain our client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services. The College of Psychologists of Ontario also requires us to retain our client records. For client who are seen before the age of 18, records are retained for ten years following their 18th birthday.

If Ivanova Psychology & Associates were sold, none of the client records would be transferred to or accessed by the new owners.

We destroy electronic information by deleting it and, when the hardware is replaced or discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or all of the client file to our client, Personal information that is not part of the permanent clinical file is shredded.

With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify which records we might have about you. We will also try to help you understand any information you do nor understand (e.g., abbreviations, technical language, etc.). We may need to confirm your identity if we do not know you, before providing you with this access. We reserve the right to charge a fee for such requests. We may ask you to put your request in writing. If we cannot give you access, 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. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.

Our Information Officer is Dr. Iryna Ivanova. She can be reached at:

Ivanova Psychology & Associates
160 Preson St, Ottawa ON K1R 7P7
Tel: (613) 688-3230
Iryna@IvanovaPsychology.com

She will attempt to answer any questions or concerns you might have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and ensure that you are provided with a formal written decision with reasons.

This policy is made under the Personal Information Protection and Electronic Documents Act.

For more general enquiries, 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:

30 Victoria St
Gatineau, QC K1A 1H3
Phone (819) 994-5444 | 1-800-282-1376 | Fax (819) 994-5424 | TTY (819) 994-6591
https://www.priv.gc.ca/en/

Our policy is also determined by and is compliant with The Ontario Personal Information Act. Indeed, our policy to protect your privacy is more stringent that the legislation requires because of our Psychologists’ Ethical Code. The Ontario Information and Privacy Commission (www.ipc.on.ca) can be reached at:

The Registrar, Information and Privacy Commission of Ontario
2Bloor St. W, Ste. 1400
Toronto, ON, M4W 1A2
1-800-387-0073