Last updated: July 31, 2024

 

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.

What is Personal Information?

Personal information is information about an identifiable individual. Personal information includes information that relates 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. an individual’s business address and telephone number), which is not protected by privacy legislation.

Our Primary Purposes for Collecting Personal Information are Summarized Below

About Clients

We collect, use and disclose personal information only in order to provide psychological services to our clients. For example, we may collect information about a client’s health history, including their family history, physical condition and function and social situation in order to help us arrive at a psychological opinion (for the client or for an authorized third party, if applicable), to 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 psychological functioning so that in providing psychological and psychotherapeutic 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, a worker’s compensation board/insurance company (e.g., Workplace Safety and Insurance Board), psychological/legal reports for lawyers, no-fault automobile insurance, child protection agencies (e.g., Children’s Aid Society) and rehabilitation companies.

It would be rare for us to collect or disclose personal information without the client’s expressed 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 a client and we have no reason to believe that the message is not genuine).

About Members of the General Public who call for information about our services

For members of the general public, our primary purposes for collecting personal information (e.g., contact numbers) are to make them aware of the range of psychological and psychotherapeutic and other health services we offer.

Protecting Personal Information

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

  • Paper information is either under close supervision or secured in a locked or restricted area.
  • Electronic hardware is either under close supervision or secured in a locked or restricted area at all times. Passwords are used on computers.
  • Paper information is transmitted through sealed, addressed envelopes or boxes by reputable couriers or Canada Post. 
  • Electronic information is transmitted through secure means whenever possible. While we cannot guarantee the security and privacy of e-mail communication, we will only communicate with a client or authorized others over e-mail with the client’s consent, and clinical information will always be sent only in an encrypted and secure manner.

Limits to Protection of Private Information

Limits to the protection of private information include legally mandated disclosure to child protection agencies (e.g., Children’s Aid Society), professional licensing bodies, Court orders to release information, search warrants for a file in a criminal or a legal case, subpoenas, mandated disclosures to the Ministry of Health (for seniors in long-term care settings who are being abused or neglected), to the college or licensing body of a regulated health professional who has sexual contact with a patient (you or someone you tell us about), and to aid in locating you if you become declared a missing person. If we believe you are imminently at risk of harming yourself or harming (a) specific other person(s), we may disclose private information in order to protect the safety of yourself or others.

Other examples of where we may disclose personal information can be found below under the heading “Disclosure of Your Personal Data.”

Retention and Destruction of Personal Information

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 provided 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 professional licensing bodies also require us to retain our client records. For clients who are seen before the age of 18, records are retained for ten years following their 18th birthday.

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.

You Can Look at Your Information

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 what records we might have about you. We will also try to help you understand any information you do not understand (e.g., abbreviations, technical language, etc.) We reserve a right to charge a fee for such requests. We may also ask you to put your request in writing. If we cannot give you access, we will tell you within 10 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.

Further Technical Information 

Interpretation and Definitions

Interpretation

The words in which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in the plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to InnerQore Health: Psychology and Wellness, 19 Centre Street, Thornhill, Ontario, L4J 1G1
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to Canada
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the services you are agreeing to receive at InnerQore Health: Psychology and Wellness, and includes the use of the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a user can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to InnerQore Health: Psychology and Wellness, accessible from website www.innerqore.com
  • You mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.

We use both session and persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies
  • Type: Session Cookies
  • Administered by: Us
  • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contracted service: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to Contact You, to initiate and carry out a service requested by you, and to monitor and analyze the use of our Service.
  • For Business transfers: We may share or transfer Your personal information in connection with, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. 
  • With Third Party Companies: We may share Your information with third party companies that provide us with services that in turn facilitate the services we provide to You. These companies all have strict Privacy Standards themselves and are legally bound by our confidentiality and privacy requirements.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Limits to protection of private information can be found above under the heading Limits to Protection of Private Information. In addition, here are other circumstances whereby we may disclose your Personal Information:

  • Our Service Providers are regulated by provincial or state licensing bodies (e.g., College of Psychologists of Ontario; Newfoundland and Labrador Psychology Board; Nova Scotia Board of Examiners in Psychology; College of Registered Psychotherapists of Ontario; Ontario College of Social Workers and Social Service Workers; College of Dietitians of Ontario)  who may inspect our records and interview us as a part of their regulatory activities in the public interest. These licensing bodies have their own strict privacy obligations.
  • The cost of some services provided by us to clients is paid for by third parties (e.g., private insurance, workers compensation boards such as WSIB, automobile insurance, First Nations and Inuit Health Branch, Canadian Forces, CUPE). 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).
  • Business Transactions. If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
  • Law enforcement. Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
  • Collection of Unpaid Accounts. In the event that an account remains unpaid, we will make reasonable efforts to obtain payment from the Client but if necessary, will disclose information to third party Collections Agencies and/or to the Courts in order to assist with collection of the unpaid amounts.
  • Other legal requirements. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation.

 

Security of Your Personal Data

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

Financial Data
Financial data is data that is related to your payment methods, such as credit card or bank transfer details. We collect financial data in order to allow you to purchase, order, return or exchange products or services from the Company. We store limited financial data. Most financial data is transferred to our payment processor, Stripe, Moneris, and/or PayPal, and you should review these processors’ Privacy Policy to determine how they use, disclose and protect your financial data. As a courtesy, Stripe’s Privacy Policy can be found here: https://stripe.com/us/privacy. Moneris’s Privacy Policy can be found here: https://www.moneris.com/en/legal/privacy-notice/. PayPal’s Privacy Policy can be found here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy, located on this web page, from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Do You Have a Question?

Please feel free to bring any questions to our attention. We will attempt to answer any questions or concerns you might have.

If you have a complaint about our collection, handling, or disclosure of your personal information, please feel free to discuss this with Dr. Jeremy Frank, the clinic director and privacy officer. If the problem is not addressed to your satisfaction, you have the right to file a complaint with the Privacy Commissioner in the province you are located (e.g., Office of the Information and Privacy Commissioner for Nova Scotia; Information and Privacy Commissioner of Ontario; Office of the Information and Privacy Commissioner for Newfoundland/Labrador). The identities of the Privacy Commissioners in these offices periodically change and are not included here but can be easily found through an online search (for example, go to Google and search for “Ontario Privacy Commissioner”). 

This policy is made under the Personal Information Protection and Electronic Documents Act. It is also determined by and is compliant with provincial legislation such as the Personal Health Information Protection Act (PHIPA). Indeed, our policy to protect your privacy is more stringent than the legislation requires because of our Psychology Ethics Code. 

Contact Us

If you have any questions about this Privacy Policy, You can contact us: