Privacy Policy
PURPOSE
Catherine Dwyer Counselling is committed to upholding client confidentiality and protecting personal health information. The following is the Privacy Policy for Catherine Dwyer Counselling and exists to inform clients of my responsibilities and your rights around the collection, use and disclosure of your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Health Information Protection Act (PHIPA), and the standards set out by my regulatory college, the Ontario College of Social Workers and Social Service Workers (OCSWSSW). This policy applies to anyone who is a current or past client of Catherine Dwyer Counselling.
COLLECTING YOUR PERSONAL INFORMATION
The primary purpose of collecting personal information is to provide therapeutic and consultation services. I will collect and use personal information only as it is relevant to the rendering of therapeutic services as requested by you. This personal information may be used for the purposes of providing counselling services to you, responding to phone or email inquiries, to provide resources to augment your therapy experience, to organize consultations with other professionals, or to contact you in order to manage appointments and cancellations.
The information I collect about you may include your name, date of birth, address, phone number, email address, presenting concerns, medical history, records of our counselling sessions and the supports or recommendations you have received during your interactions with me.
All personal information collected will be recorded electronically via Canada’s most secure and compliant online practice management system; Owl Practice. All client records are owned and retained by me unless a transfer is authorized by the client in writing.
EMAIL, INTERNET, ELECTRONIC DEVICES, TEXTING AND MESSAGING
Please note that there are risks to communicating with technology such as emails, computers, tablets, cell phones. Texting, emails and messaging through social media sites are not considered a secure and confidential way of communicating. Computer and e-mail communication can be accessed by unauthorized people which can compromise the privacy and confidentiality of our communication. E-mails, in particular, are vulnerable due to the unlimited and direct access that email servers have.
For the protection of your privacy, please do not text, message or email any private information that you would not be comfortable sharing in a more public domain or any content related to your therapy session.
The best way to communicate with me is through Owl Practice’s secure messaging service found within your client portal. To learn more about OWL Practice’s security measures, please visit: https://faq.owlpractice.ca/category/owland-security. You can also call or email me, and I will do my best to get back to you within 24-48 hours.
You may wish to protect your personal information by using pins and passwords, encryption and/or by deleting texts, messages, emails once you have completed the communication. If you must communicate confidential information through email, texts or social media messages, we will assume you understand the risks of this communication. Emails, texts and social media messages or posts may be included in counselling records.
Please DO NOT use e-mail, texts, or social media/website messaging for emergencies. If you are experiencing an emergency, you should call 911 or go to your local emergency room. You can also call your local 24-7 mental health crisis lines such as 613-722-6914 (within Ottawa) or 1-866-996-0991 (toll free outside Ottawa); 709-737-4668 (within St. John’s) or 1-888-737-4668 (toll free outside St. John’s).
www.catherinedwyer.ca exists for the purpose of educating potential and current clients regarding the services provided at Catherine Dwyer Counselling. www.catherinedwyer.ca does not actively collect personal and identifiable information about you. Google analytics collects statistics on popular webpages, search terms, browsers, operating systems and devices used. This information is given as aggregate data and is not personally identifiable. Internet browsers may passively, and not at my request, collect IP addresses and locations.
PROTECTING PERSONAL INFORMATION
I treat all aspects of your personal information with the greatest care and take active steps to protect your information. As per the requirements of PIPEDA, PHIPA and OCSWSSW, I securely stores client/clinical information via the online practice management system, OWL Practice.
Owl Practice, a Canadian company, uses a combination of SQL and MongoDB databases to store all practice data and has secure servers located in Montreal and Toronto so that data is located in Canada and continually backed up. Each Owl Practice account has its own segregated database, accessible only from a customized, account-specific URL. There is no way to login to an Owl account from the Owl marketing site, and these login pages are not searchable on Google, for security reasons. Owl Practice uses bank-level encryption (SSL) to encrypt all data that moves between their secure and dedicated servers and the device and browser on which a clinician accesses their Owl Practice account.
I may also have paper files holding rough session notes. These notes are either under supervision or secure in locked or restricted areas when not in use.
All electronic hardware is either under supervision or always secured in a locked or restricted area when not in use. In addition, security access systems are used on all devices including computers and phones. Electronic information is transmitted through either a direct line or is anonymized or encrypted.
In the unlikely event that there is a breach of privacy with respect to your personal health information, I will notify you immediately of this breach.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
I am legally required to retain personal information for 10 years after the last client contact. Paper files are then subject to confidential shredding and disposal. Electronic information is destroyed by deleting it and when the hardware is eventually discarded, the hard drive is physically destroyed.
If I was to pass away or become unable to practice for whatever reason, your file would become the responsibility of an alternate designated clinician. You may wish to ask me who I have appointed as responsible for your file in this eventuality.
RELEASING YOUR PERSONAL INFORMATION
All my services are confidential, and I am not authorized to disclose your personal information to any third party without your informed, written, and signed consent. This consent permits me to release information/reports to, or consult with, the individuals you have indicated can examine your file.
Under PHIPA, your consent is implied when discussing your case with members of your health care team. Under PHIPA, you can withdraw your consent, in writing, at any time, however, you cannot rescind consent for information that has already been collected.
There are exceptions to confidentially wherein I have a legal duty to divulge personal information about you to a third party without your explicit consent. I will do my best to notify you if one of these situations occurs. These exceptions include:
– If I suspect that you may do harm to yourself or others;
– If child abuse is suspected or reported;
– If you advise me of sexual abuse by another registered health care provider;
– When a Court issues a subpoena for your file or requires my testimony.
I may also discuss your personal information with a registered clinical psychologist/social worker who acts as my supervisor or my peer supervision group, comprised of registered professionals, with whom I have entered consulting agreements. In general, personal identifiers are not revealed when discussing your case. Please note that these professionals are bound by the same rules of confidentiality as outlined above.
If you would like me to provide information from your file to another person, a Release of Information form must be filled out providing your written authorization. I will only release information that has been collected directly by me while any other reports provided to me by allied health providers will not be released by me. Should you wish to review your file or the information that is being released in advance, I will review it with you before I release the information. I reserve the right to charge a nominal fee for copying your file.
ACCESSING YOUR PERSONAL INFORMATION
Clients have a right to view or receive a copy of their file, or portions of the file, if this information is still available. Clients also have the right to request a correction to their personal health information if it is inaccurate or incomplete.
Any information either given by third parties, or about third parties that is contained in the file, is required to be blacked out, to preserve the third party’s privacy.
Access requests by clients can be refused if there is a risk of significant harm to either the client or to others by releasing the information. If access cannot be provided, you will be informed within 30 days. I reserve the right to charge a nominal fee for copying your file.
Social Media Policy
PURPOSE
The following is the Social Media Policy for Catherine Dwyer Counselling which outlines my office policies related to use of the internet and social media within my practice. The OCSWSSW’s Code of Ethics and Standards of Practice requires me to establish and maintain clear and appropriate boundaries in professional relationships for the protection of clients including transparency about the purposes for which I will communicate using communication technology.
This policy exists to ensure college compliance, protect our relationship and to ensure your privacy, as the internet and many social media sites are not secure or compliant. Please read it to understand how I conduct myself on the internet as a mental health professional and how you can expect me to respond to various interactions that may occur between us on the internet.
If you have any questions about anything within this document, I encourage you to bring them up when we meet. As new technology develops and the internet changes, there may be times when I need to update this policy. If I do so, I will notify you in writing of any policy changes, inform you of any changes within session and update this page on my website accordingly.
Social media is a fantastic tool for helping people get informed and engaged. I use social media for this purpose. However, the use of social media may compromise your privacy depending on how you engage with my social media pages. As your therapist, I must keep our relationship completely confidential (with noted exceptions above in the privacy policy).
However, you can decide what you want to keep confidential regarding your relationship with me. If you follow, like or post on any of my social media pages, you are opening yourself up to the possibility of people inferring about our relationship or asking you about your connection to me. You get to decide what you tell people, and you have a choice as to what you reveal about yourself online. However, I will not reveal my connection to you. The following is how I handle different social media options:
FRIENDING, FANNING AND FOLLOWING
Catherine Dwyer Counselling currently maintains social media accounts for the purpose of education, inspiration and engagement. Clients are welcome to follow or like Catherine Dwyer Counselling using these platforms, however, Catherine Dwyer Counselling and myself as an individual on these sites will not follow or like current or former clients. If you chose to follow or like Catherine Dwyer Counselling on social media, I assume that you understand the risks to confidentiality that this interaction may pose.
I do not accept friend or contact requests from current or former clients on any social media site. I believe that adding clients as friends or contacts on these sites can compromise your confidentiality and our respective privacy. It may also blur the boundaries of our therapeutic relationship.
Catherine Dwyer Counselling may follow other health professionals, related organizations, on social media or non client contacts, however, I do not follow current or former clients on blogs or other social media. I believe that casual viewing of clients’ online content outside of the therapy hour can create confusion in regard to whether it’s being done as a part of the treatment or to satisfy a personal curiosity.
In addition, viewing your online activities without your consent and without our explicit arrangement towards a specific purpose could potentially have a negative influence on our working relationship. If there are things from your online life that you wish to share with me, please bring them into sessions where you and I can view and explore them together, during the therapy hour.
INTERACTING AND COMMUNICATING
I do not interact with clients on Catherine Dwyer Counselling’s social media sites. Please do not use messaging on social media sites to communicate with me. Social media sites are not secure, and I may not read these messages in a timely fashion, as I do not monitor social media sites 24-7. Therefore, if there was an emergency, I would not be able to respond in a timely fashion.
Also, please do not use wall postings, @replies, or other means of engaging with me in public online if we have an already established a client/therapist relationship. Engaging with me in this manner could compromise your confidentiality. If you post on my social media pages, it may also create the possibility that these exchanges become a part of your legal clinical record and will need to be documented and archived in your file. I will delete any requests regarding your sessions that appear on any of my social media platforms.
SEARCH ENGINES
It is not a regular part of my practice to search for clients on Google or other search engines or social media sites. If I do inadvertently come across your information online, I will move on and avoid reading content. Extremely rare exceptions may be made during times of crisis. If I have a reason to suspect that you are in danger and you have not been in touch with me via the usual means (coming to appointments, or phone contact) there might be an instance in which using a search engine (to find you, find someone close to you, or to check on your recent status updates) may become a necessary as part of ensuring your welfare. These are unusual situations and if I ever resorts to such means, I will fully document it and discuss it with you when we next meet.
BUSINESS REVIEW SITES
You may find Catherine Dwyer Counselling on sites such as Yelp, Google, Yahoo Local, Bing, or other places which list businesses. Some of these sites include forums in which users rate their providers and add reviews. Many of these sites comb search engines for business listings and automatically add listings regardless of whether the business has added itself to the site. If you should find Providence Catherine Dwyer Counselling on any of these sites, please know that the listing is NOT a request for a testimonial, rating, or endorsement from you as my client.
The OCSWSSW’s Code of Ethics and Standards of Practice, states that while I may advertise my services, I cannot include any endorsements or testimonials. Testimonials may create a kind of dual relationship in which clients come to believe that they have a different relationship with the member as a result of the endorsement that they have provided.
Of course, you have a right to express yourself on any site you wish. But due to confidentiality, I cannot respond to any review on any of these sites whether it is positive or negative. I urge you to take your own privacy as seriously as I take our commitment of confidentiality to you. You should also be aware that if you are using these sites to communicate indirectly with me about your feelings about our work, there is a good possibility that I may never see it.
If we are working together, I hope that you will bring your feelings and reactions to our work directly into the therapy process. This can be an important part of therapy, even if you decide in the end that we are not a good fit. None of this is meant to keep you from sharing that you are in therapy with me wherever and with whomever you like.
Confidentiality means that I cannot tell people that you are my client and my professional Code of Ethics and Standards of Practice Ethics prohibits me from requesting testimonials. But you are more than welcome to tell anyone you wish that I’m your therapist or how you feel about the treatment provided to you, in any forum of your choosing.
If you do choose to write something on a business review site, I hope you will keep in mind that you may be sharing personally revealing information in a public forum. I urge you to create a pseudonym that is not linked to your regular email address or friend networks for your own privacy and protection.
If you feel that I have done something unethical or harmful and you do not feel comfortable discussing it with me, you can always contact my regulatory body, the Ontario College of Social Workers and Social Service Workers (Telephone: 416-972-9882 Toll-Free: 1-877-828-9380 Email: info@ocswssw.org) and they will review my services.
LOCATION-BASED SERVICES
If you used location-based services on your mobile phone, you may wish to be aware of the privacy issues related to using these services. If you have GPS tracking enabled on your device, it is possible that others may surmise that you are a therapy client due to your location. Please be aware of this risk if you are intentionally “checking in’ from my office or if you have a passive LBS app enable on your mobile phone.
QUESTIONS OR CONCERNS
The information above is subject to periodic revision and changes. The current version will always be posted to www.catherinedwyer.ca and I will inform you of any changes during our next scheduled session. If you have any questions about this policy please contact me directly at (709) 499-0676 or (613) 518-3075. If you wish to make a formal complaint about my privacy policies, please do so in writing to me. I will acknowledge receipt of your complaint, ensure that it is investigated promptly, and that you are provided with a formal response in writing.
If you have a concern about my professionalism, competence or my mental/physical capacity, I ask that you discuss those concerns with me directly. However, if you do not feel comfortable discussing it with me, or if I cannot satisfy your concerns, you are entitled to make a complaint to my regulatory body, the Ontario College of Social Workers and Social Service Workers (Telephone: 416-972-9882 Toll-Free: 1-877-828-9380 Email: info@ocswssw.org).
Thank you for taking the time to review my Privacy and Social Media Policy. If you have questions or concerns about any of these policies and procedures or regarding our potential interactions on the internet, please bring them to my attention so that we can discuss them.
