Privacy Policy
Healing Journey Privacy Policy
The purpose of this document is to outline Healing Journey’s privacy policy and practices and to provide information regarding confidentiality and laws related to the collection, use, and disclosure of your personal health information while engaging with our clinic.
Who We Are:
Healing Journey is a counselling and psychotherapy clinic comprised of a small team of practitioners and administrative staff. All confidential information is stored securely within our healthcare app utilized for all aspects of our clinic functions, Jane App. Information can and will only be provided to third parties with written request and permission from the client concerned. Practitioners only have access to records concerning their own clientele.
In the case of outside billing/sessions covered by Non-insured Health Benefits (NIHB), only essential information is provided to that agency for billing purposes such as name registered to NIHB, date of birth, and status card number or N number, and number of sessions being billed. Chart notes and intimate details are not shared.
What is Personal Health Information?
Personal health information is defined as data used to identify a person including details of their healthcare. This may include contact information (e.g., name, address, telephone number, e-mail address), personal characteristics (e.g., age, gender, cultural/ethnic background), and health details (e.g., presenting issues, health history, medical/mental health conditions, treatments being received).
Collection and Use of Personal Health Information:
In order to best provide our services, Healing Journey will collect limited personal health information from you. We will ask you to complete intake forms and self-report tests as needed to elucidate details relevant to your presentation and treatment needs.
Sometimes, third party insurers may request to be provided limited healthcare information (session dates, duration, clinician’s name, estimated treatment course/timeline, etc.)
Information Sections:
Electronic Communication of Personal Health Information (“E-mail”)
Disclosure of Personal Health Information
Access to Your Personal Health Information & Requests for Correction
Storage and Destruction of Personal Health Information
Questions and Complaints
Additional Privacy Policy Information
Healing Journey’s Privacy Policy
Healing Journey collects demographic information such as name, e-mail, phone number, and home address. We will also collect information related to your health and the identities that you hold in order to serve you better and work towards treatment goals. We collect this personal health information through intake, during sessions, and when we do self-report questionnaires or tests with you in session or sent through our database, Jane app.
Your personal health information will influence treatment options available to you (such as Safe and Sound Protocol (SSP) and Eye Movement Desensitization and Reprocessing Therapy (EMDR)). Some treatments are contraindicated in individuals with specific physical and mental health conditions.
Personal health information can be released with the patient’s written informed consent to specified healthcare professionals involved in your collaborative care.
For covered services, insurance companies sometimes request specific information be released to them. That information includes: your practitioner’s contact information and registration number, information about session dates, and duration.
In terms of work-related short-term or long-term medical disability, government organizations such as Ontario Disability Support Program (ODSP) require release of certain personal health information to your employer. When we write letters on your behalf, you will overlook the document before we submit it in order to edit, remove/insert information, and give informed consent on what is released.
Non-insured Health Benefits Claims
NIHB requests little information outside of standard identifying information (legal name, date of birth, status number, and the amount of sessions that you have completed with your practitioner). For extension requests for continuation of sessions, a letter will be submitted to NIHB on your behalf stating the need and amount of hours for approval, the estimated treatment duration/completion date, and a simple explanation as to why we are requesting more sessions. Specific information will not be released by your practitioner (this is a breach of confidentiality and not required by NIHB). An example of reasoning for extending the number of sessions may be “client is facing significant safety issues” or “ongoing mental health challenges”.
Virtual and Telephone Sessions
Healing Journey provides virtual and phone sessions only. Some people prefer one over the other, and your practitioner is available to elucidate which delivery method works best for you. Certain treatment modalities, such as EMDR, emotion-focused therapy, and Polyvagal theory, require the practitioner to assess the non-verbal feedback of the client and would be best suited to video sessions; however, you always have the right to change the method of virtual care at any point in your treatment.
Virtual sessions are just as effective as in-person sessions as any intervention that can be done in-person can also be done virtually. Healing Journey uses videoconferencing through Jane app and, for some practitioners, virtual services are provided through Zoom. These videoconferencing methods are secure through private links which will be provided to you prior to each session through the Jane app or via your practitioner.
It is helpful to test your audio and video well before your session time through the Jane app or Zoom. Jane app has technology support to assist you with any issues you are having with their technology. You can also reach out to your practitioner about technology issues as we have backup methods of videoconferencing that can be utilized such as Psychology Today’s Sessions, Doxy.me, or even via phone call through the number that you provide to us. Please note that with phone sessions, practitioner caller ID may show up as “Unknown” or blocked – please ensure you are answering this call at our scheduled time.
Regarding virtual and phone sessions, the following applies:
Laws and professional standards that apply to regular mental health services also apply to virtual and telephone-based care.
Exceptions to client confidentiality policies that exist for regular therapy also apply to virtual and telephone-based services. The exceptions are provided in the “Disclosure of Personal Health Information” section below.
You have the right to withdraw your consent at any time, and it will not affect your right to further treatment.
Your practitioner has the right, at any time, to determine if virtual and/or telephone-based sessions are not appropriate for your care. Should this be determined, your practitioner will suggest alternate ways to continue your therapeutic care.
There is always a risk that virtual services can be disrupted or distorted by unforeseen technical problems.
Consent to the use of virtual and telephone-based sessions indicates your agreement with the following conditions:
Confidentiality laws apply to mental health services delivered virtually, and the session may not be recorded by the practitioner or yourself without permission from the other person(s).
You will need a quiet, private space that is free of distractions during the session with a secure internet connection (as opposed to public/free Wi-Fi).
For child/adolescent clients, permission from your parent/legal guardian (and their contact information) is required to engage in virtual sessions.
*Use of virtual and telephone-based sessions is voluntary. Please advise us if you no longer wish to engage in virtual services, and we will discuss alternate options with you at that time.
Electronic Communication of Personal Health Information (“E-mail”)
Healing Journey uses e-mail communication as a primary method of contact between yourself and our practice. It is utilized for appointment confirmations, reminders, and delivery of invoices and paid receipts. E-mail communication is not mandatory – please let your practitioner know your preferences and if you would like your e-mail removed from our communications.
The following risks do exist with electronic communication:
The privacy and security of e-mail communication cannot be guaranteed.
E-mail is easier to falsify than other communication modalities as it is impossible to verify the true identity of the sender or to ensure that only the recipient can access the sent e-mail.
E-mail has risks of introduction of computer viruses or other damaging or disrupting changes.
E-mail can be forwarded, intercepted, circulated, stored, or even changed without the knowledge or permission of the sender or recipient. E-mail senders can easily misaddress an e-mail resulting in it being sent to unintended and unknown recipients.
E-mail is a permanent record. Even after the sender and recipient have deleted their copies of the e-mail, backup copies may exist on a computer or in cyberspace.
Consent to the use of e-mail indicates your agreement with the following conditions:
E-mails received containing relevant information may be made part of your clinic record, at the discretion of your practitioner, which then would be accessible to authorized individuals when requesting your records. We discourage the use of e-mail to discuss sensitive personal health information unless this is an agreement that you have with your practitioner.
E-mail should not be used for emergencies or other time-sensitive matters. It is not always possible for your practitioner to get back to you right away.
E-mail communication is not akin to treatment. You must follow up with us to schedule appointments, and in cases where you have not received a response within a reasonable time period, it is your responsibility to follow up on your message.
Disclosure of Personal Health Information
In accordance with laws, professional standards, and the code of ethics we adhere to, the information you share with Healing Journey remains confidential. Your information will not be disclosed to anyone without your consent, with the exception of the specific situations outlined below.
Your information may be released without your consent in the following situations when safety planning is not possible because there is imminent risk and the potential of loss of life:
1. Harm to Self/Others: If there is reason to believe that you are in danger of harming yourself or others in ways that may be life-threatening, Healing Journey has an ethical obligation to take further steps including, but not limited to, contacting your emergency contact person on file, seeking hospital admission, contacting law enforcement, and notifying anyone at potential risk.
2. Abuse/Neglect: If our practitioner has reasonable grounds to suspect that a child under 16 years of age is, or may be, in need of protection, they will report this information to appropriate organizations or authorities. Additionally, if there are reasonable grounds to suspect that a resident of a nursing, retirement, or other long-term care home has suffered harm, or is at risk of harm due to improper or incompetent treatment or care, unlawful conduct, abuse or neglect, or possible misuse or misappropriation of the resident’s money or funding, Healing Journey will report this information to the Registrar of the Retirement Homes Regulatory Authority, or long-term care home director. Further examples of reportable situations include any physical harm/abuse, sexual abuse, emotional harm (e.g., verbal abuse, humiliation, witnessing violence), or a pattern of neglect or failure to protect a child from harm.
3.Sexual Abuse by a Regulated Health Professional: If there are reasonable grounds to believe that another regulated health professional has sexually harassed or abused a client, Healing Journey will report this health professional’s name and information related to the sexual abuse to the appropriate regulatory body.
4. Court Order: Clinic records can be subpoenaed by a court order and Healing Journey practitioners may be required to participate in the court process. Information obtained during the course of any assessments and/or treatment sessions will not be provided without your direct request or permission without the court order. As registered healthcare professionals, we may also be required to make our files available for audit by our regulatory body, third-party agencies, or government. All audits are confidential, and a record of the audit will be inserted into your client file.
5. Missing Persons: If the police present a Court Order, Search Warrant, or Urgent Demand for Records related to a missing person, Healing Journey is required to provide the information and/or records sought by police in order to assist with locating that missing person.
Access to Your Personal Health Information & Requests for Correction
You have the right to access or amend your personal health information with a few exceptions.
A Healing Journey practitioner will review your records alongside you to help you understand any information that is not clear or amend any discrepancies. Copies of your file will be provided in an estimated timeframe and take into account the schedule of your practitioner.
Storage and Destruction of Personal Health Information
Records containing your personal health information and information about your sessions and interactions are maintained in our database, Jane app. All gathered personal health information will be held for a period of 10 years after our last contact with you (for adults) or 10 years after you turn 18 years of age (for children), whichever is later. Any personal health information that is stored electronically is protected by appropriate security measures (e.g., PHIPA-compliant software that includes bank-level encryption). After 10 years, your personal information is destroyed in a secure manner that protects your privacy.
Your practitioner maintains responsibility for your client file and will stay with them if they ever leave the clinic and continue to work with you. A copy of your client file will be retained by Healing Journey clinic as a backup but this file will not be released to anyone unless one of the limits of confidentiality comes up or you request your file.
Reporting Practitioners in Ontario
If your practitioner is a social worker and you feel that they have caused you harm, here are the steps to report them.
PLEASE READ THIS BEFORE FILING A COMPLAINT:
Information from the Ontario College of Social Workers and Social Service Workers website
The College receives a large volume of complaints. In order for the complaints process to run smoothly and efficiently, please be aware of the following:
Make sure you have checked the College’s Online Register to ensure the person you wish to complain about is a registered member of the College.
Review the College’s Guide to Complaints to satisfy yourself that the complaints process can provide the result you are looking for. Be aware that among other things, the complaints process cannot:
Award money or damages or reimburse fees paid
Require a member to do something; i.e. apologize, or stop doing something
Require a member to alter a report written in respect of custody and access or other similar issues
Substitute the decision of a member made in the context of an arbitration or other proceeding
Once your complaint is filed, please do not send additional information or raise new allegations. New allegations may require you to file a separate complaint and the receipt of additional information will delay the College’s investigation. The College will contact you if further information is required.
Please be reminded that none of the information received in the course of the complaints process is admissible in any civil court proceeding outside of the College; i.e. Family Court. This includes any responses from the College member and the decision of the Complaints Committee.
For more information on submitting a complaint, please see this link: https://www.ocswssw.org/ocswssw-resources/complaints-guide/
If your practitioner is a psychotherapist or psychotherapist (qualifying), here are the steps to report them.
About The Process
Information from the College of Registered Psychotherapists of Ontario website
Before You Make a Complaint
The complaint process can be difficult for both complainants and psychotherapists. While CRPO will always consider the information carefully, neutrally and in the public interest, the outcome may not be the one hoped for by the complainant or psychotherapist. It may be advisable to have personal supports in place during the complaint process.
For questions about the complaint process, you may email us any time at complaints@crpo.ca. Staff are also available via phone during business hours (8:00am – 4:00pm). Contact information is available on the Contact Us page. Please note that staff record written notes from all phone calls. These notes may be disclosed to the registrant in future investigations.
How to File a Complaint
If you decide to submit a formal complaint, please use the Complaint Form. You can submit the form by email, mail or fax. If you are unable to provide your complaint in writing, please contact CRPO to request accommodation.
After You File a Complaint
Once you have submitted a complaint, a staff person will contact you to confirm receipt, obtain any clarification needed and provide information on next steps. CRPO will then provide the psychotherapist you have complained about with notice of the complaint within 14 days from the time the complaint was received. In general, CRPO will provide the psychotherapist with a copy of the complaint and give them the opportunity to respond.
In addition, an investigator may be selected to investigate the matter. If this occurs, the investigator may request to speak with you in order to learn about the events and circumstances surrounding the complaint.
The investigator may be a staff person or an investigator contracted by the College. The investigator’s role is to interview relevant witnesses and collect any necessary documentation. The investigator is not a decision-maker.
For more information on this process, please see this link: https://crpo.ca/complaints-reports/filing-a-complaint/
Questions and Complaints
Any questions or concerns about the above policy can be directed to:
Founder and Clinical Director of Healing Journey, Aden Cosgrove
aden.cosgrove@outlook.com
