PRIVACY POLICY

Last updated 11/2/2018

Privacy of personal information is an important principle to Live Empowered Counselling. I am committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services I provide. This document describes my privacy policies.

WHAT IS PERSONAL INFORMATION?

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, home address or phone number, ethnic background, family status), their mental health (e.g., mental health history, health conditions, counselling services received by them) or their activities and views (e.g., academic or work history, religious affiliation, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.

WHO I AM

Live Empowered Counselling is a private counselling practice registered with the government of Ontario as Sole Proprietorship. Live Empowered Counselling is composed of one counsellor who offers individual and groups counselling services.

I COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES

Like all Private Counselling Practices, I collect, use and disclose personal information in order to serve my clients. For my clients, the primary purpose for collecting personal information is to provide personal counselling. For example, I collect information about a client's mental health history, including their family history, physical condition and function in social situations in order to help me assess what their mental health needs are, to advise them of their options and then to provide the counselling care they choose to have. A second primary purpose is to obtain a baseline of mental functioning and social information through assessment so that in providing ongoing counselling services I can identify changes that are occurring over time. It would be rare for me to collect such information without the client's express consent, but this might occur in an emergency. My duty to report is defined by my professional body and the Mental Health Act.

I COLLECT PERSONAL INFORMATION: RELATED & SECONDARY PURPOSES

Like most organizations, I also collect, use and disclose 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 goods or services (i.e.: missed appts; resources not returned)
• To advise clients and others of special events or opportunities (e.g., a workshop, development of a new service) that we have available.

• I review client and other files for the purpose of ensuring that I provide high quality services with my supervisor. In addition, external consultants (e.g., auditors, lawyers) may on my behalf do audits and continuing quality improvement reviews of my services, including reviewing client files and interviewing me.

• Clients or other individuals I deal with may have questions about our goods or services after they have been received. I also provide ongoing services for many of my clients over a period of months or years for which my previous records are helpful. I retain my client information for a minimum of 10 years to enable me to respond to those questions and provide these services.


PROTECTING PERSONAL INFORMATION

I understand the importance of protecting personal information. For that reason, I have taken the following steps:
• Paper information is either under supervision or secured in a locked or restricted area.
• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.
• Paper information is transmitted through sealed & addressed envelopes

• Electronic information is transmitted through a direct line.
• Staff is trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with my privacy policy.
• External consultants and agencies with access to personal information must enter into privacy agreements with us.

SECURITY

The security of your Personal Information is important to me, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While I strive to use commercially acceptable means to protect your Personal Information, I cannot guarantee its absolute security.

BOOKING ONLINE: WHAT INFORMATION DO I COLLECT?

I do not collect any Personally Identifiable Information when browsing my site. When you book an appointment online, I collect personal information necessary to provide you with the service you have requested.

 RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

I need to retain personal information for some time to ensure that I can answer any questions you might have about the services provided 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. I keep my client files for about ten years. I destroy paper files containing personal information by shredding.

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 can help you identify what records we might have about you. I will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). I will need to confirm your identity, if I do not know you, before providing you with this access. I reserve the right to charge a nominal fee for such requests. 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 my file a brief statement from you on the point and I will forward that statement to anyone else who received the earlier information.

PRIVACY AND MY WEBSITE

(a) Cookies – When an individual visitor accesses the Live Empowered Counselling website, I may use ‘cookies’ to collect information, such as the type of internet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on my website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser but not necessarily the visitor each time my website is visited. Unless a visitor specifically informs me (e.g. by registering for an event or sending me correspondence from the website), I will not know who the individual visitors are. In addition to the identified purposes described in my privacy policy, I may use this website information and share it with other organizations with which I have a commercial relationship to measure the use of my website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on my website.

(b) Squarespace/Stripe – This site is subject to the terms of both Squarespace and Stripe. This site is built using Squarespace. Squarespace's terms and conditions, including its privacy policy, can be found here. This site's payment processing system is run using Stripe. Stripe's terms and conditions, including its privacy policy, can be found here. Squarespace and Stripe may have access to your information as they support this site in its authorized use of your information.

(c) Online Communications – In order to provide my website visitors with a service or information, visitors may voluntarily submit personal information to me for purposes such as asking a question, obtaining information, reviewing or downloading a publication or participating in a seminar or other event. If you are known to Live Empowered Counselling as a registered user of an online service, I may combine and store personal information about your use of my website and the online information you have provided with certain other online and offline information I may have collected.

(d) Email Communications – Occasionally, I may send marketing or promotional email communications to you with information that may be useful, including information about Live Empowered Counselling and other third parties with whom I have a relationship. I will include instructions on how to unsubscribe and inform me of preferences if you decide you do not want to receive any future marketing or promotional emails from Live Empowered Counselling.

(e) Links – My website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than Live Empowered Counselling, and Live Empowered Counselling has no responsibility for such third party websites.

CHANGES TO MY PRIVACY POLICY

Live Empowered Counselling reserves the right to modify or supplement this privacy policy at any time. If I make a change to this privacy policy, I will post such changes on my website and make such revised policy and changes available upon request to Live Empowered Counselling as above. However, Live Empowered Counselling will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your personal information for purposes other than those for which your consent is obtained unless otherwise required or permitted by law.

DO YOU HAVE A QUESTION?

Contact our Privacy Compliance Officer by e-mail or mail:

Martina Mariglia, MSc.

1047 Main Street East Hamilton, ON L8M 1N5

OR

6150 Valley Way Niagara Falls, ON L2E 1Y3

martina@liveempoweredcounselling.com

She will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about my privacy practices, you may make it in writing to the Privacy Compliance Officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

This policy is made under the Personal Information Protection and Electronic Documents Act, which took full effect in Ontario and most other provinces on January 1st 2004.