The information collected by Here With You Therapy & Wellness depends on how an individual interacts with the practice and the services being provided.

Website and Consultation Inquiries

When an individual contacts the practice through the website, email, a therapy directory, or another referral source, information provided may include:

• name and contact information;

• preferred method of contact;

• availability;

• information related to a consultation request;

• the reason for seeking psychotherapy; and

• any other information voluntarily included in an inquiry.

Individuals are encouraged to avoid including highly sensitive personal health information in initial website forms or ordinary email communications unless necessary.

Psychotherapy Services

When an individual becomes a client, the practice may collect personal health information reasonably necessary to provide psychotherapy services and administer the therapeutic relationship.

Depending on the circumstances, this may include identifying and contact information, relevant personal and health history, information shared during psychotherapy, treatment goals and plans, clinical notes, consent documentation, appointment information, communications relating to care, emergency contact information where appropriate, billing and payment information, and other information relevant to the provision of psychotherapy.

Only information reasonably necessary for the provision and administration of services, or otherwise permitted or required by law, is collected.

Personal information and personal health information may be collected and used for purposes including:

• responding to inquiries and consultation requests;

• assessing whether the practice may be an appropriate fit for a prospective client;

• scheduling and providing psychotherapy services;

• communicating about appointments and care;

• maintaining accurate clinical and administrative records;

• processing payments and providing receipts;

• supporting continuity of care;

• fulfilling legal, ethical, regulatory, and professional obligations;

• maintaining the security and administration of the practice; and

• other purposes for which consent has been provided or that are permitted or required by law.

Information is not collected, used, or disclosed for purposes unrelated to the provision or administration of services unless consent has been obtained or the collection, use, or disclosure is otherwise permitted or required by law.

Personal health information is generally collected, used, and disclosed with consent, except where PHIPA or another applicable law permits or requires otherwise.

Depending on the circumstances, consent may be express or implied. Where express consent is required, appropriate steps will be taken to obtain that consent.

Consent may be withdrawn for certain collections, uses, or disclosures, subject to legal, professional, and contractual limitations. Withdrawal of consent may affect the practice's ability to provide certain services.

Withdrawal of consent does not necessarily require information already forming part of a clinical record to be removed or destroyed where the practice has a legal or professional obligation to maintain that record.

Information shared in the course of psychotherapy is confidential.

Here With You Therapy & Wellness does not disclose personal health information to third parties without consent except where the disclosure is permitted or required by law.

There are circumstances in which confidentiality may be limited by legal or professional obligations. These may include mandatory reporting requirements, court orders or other lawful processes, or other circumstances in which disclosure is authorized or required by applicable law.

The limits of confidentiality relevant to psychotherapy are also addressed as part of the informed consent process.

Here With You Therapy & Wellness maintains clinical records in accordance with PHIPA and applicable CRPO professional standards.

Clinical records may contain intake and consent documentation, identifying and contact information, treatment goals or plans, clinical notes, relevant communications, appointment information, billing information, and other information required to appropriately document the provision of psychotherapy.

Records are maintained in a manner intended to preserve their confidentiality, security, integrity, and accessibility. CRPO requires registrants to take reasonable steps to protect personal health information against theft, loss, unauthorized use or disclosure, modification, and improper disposal.

Clinical records are retained for the period required by applicable legislation and CRPO standards and are securely disposed of when the applicable retention period has ended.

Here With You Therapy & Wellness operates as a virtual psychotherapy practice.

Virtual psychotherapy sessions are provided through Jane, which is also used for practice-management functions such as scheduling, client administration, and certain payment functions.

Reasonable safeguards are used to protect privacy and confidentiality when services are delivered electronically. However, no electronic communication, internet connection, or technology platform can be guaranteed to be completely secure.

Clients are encouraged to attend virtual sessions from a private location whenever possible and to take reasonable steps to protect their devices, passwords, accounts, and internet connections from unauthorized access.

Here With You Therapy & Wellness uses third-party technology and service providers to support the operation of the practice. Depending on the nature of an individual's interaction with the practice, these may include:

Jane — for practice management, scheduling, virtual psychotherapy, client administration, and certain payment functions.

Google Workspace — for practice email and related business communications.

Squarespace — for website hosting, website contact forms, and website analytics.

Financial institutions and payment processors — for payments processed through Jane or by electronic transfer.

Therapy directories and referral platforms — where an individual chooses to locate or contact the practice through an external directory or platform.

Third-party providers maintain their own privacy, security, and data-handling practices. Reasonable steps are taken to use services appropriate to the nature and sensitivity of the information being handled.

Where third-party service providers handle information on behalf of the practice, information is limited to what is reasonably necessary for the applicable service where practicable.

Email and other electronic forms of communication carry inherent privacy and security risks and cannot be guaranteed to be completely secure.

Individuals are encouraged to limit highly sensitive clinical information in ordinary email communications where possible.

By choosing to communicate with the practice electronically, individuals acknowledge the privacy risks inherent in electronic communications.

Payments for psychotherapy services may be processed through Jane or by e-transfer.

Payment information may therefore be processed by the applicable financial institution or payment service provider.

Here With You Therapy & Wellness does not request or intentionally retain online banking passwords or complete payment-card credentials.

Information relating to payment for health-care services may constitute personal health information and is handled accordingly where applicable.

The Here With You Therapy & Wellness website is hosted through Squarespace and uses Squarespace Analytics.

When an individual visits the website, certain technical information may be collected automatically by Squarespace, such as information about the visitor's browser or device, IP address, and interaction with the website. Cookies and similar technologies may also be used for website functionality and analytics.

Analytics information may be used to understand how visitors interact with the website, monitor website performance, and improve the website and its content.

External websites, including therapy directories and other websites linked from the Here With You Therapy & Wellness website, operate according to their own privacy policies and practices. Here With You Therapy & Wellness is not responsible for the privacy practices of independently operated third-party websites.

Here With You Therapy & Wellness uses reasonable administrative, technical, and organizational safeguards appropriate to the sensitivity of the information being protected.

These measures are intended to protect personal information and personal health information against risks including unauthorized access, use, disclosure, modification, loss, theft, copying, or disposal.

Safeguards may include password-protected systems, access controls, appropriate security settings, secure practice-management technology, and procedures designed to maintain the confidentiality and integrity of records.

CRPO specifically requires reasonable safeguards for personal health information and identifies measures such as password protection, encryption, system security, appropriate access controls, backups, and secure disposal among the safeguards relevant to electronic record keeping.

No electronic storage or transmission system can be guaranteed to be completely secure. Privacy and security practices are therefore reviewed and updated as appropriate.

Subject to limited exceptions under PHIPA, individuals have the right to request access to personal health information about themselves that is in the custody or control of Here With You Therapy & Wellness.

Formal requests for access should be made in writing to:

Monika Georgieva
Health Information Custodian
monika@herewithyou.ca

Formal access requests will be addressed within the timelines required by PHIPA. Generally, a custodian must respond within 30 calendar days, although PHIPA permits an extension of up to an additional 30 days in specified circumstances.

A reasonable fee may be charged where permitted by law. Where a fee applies, an estimate will be provided as required.

PHIPA provides limited circumstances in which access to some or all of a record may be refused.

Individuals who believe that personal health information in their record is inaccurate or incomplete for the purposes for which the information is used may request a correction.

Correction requests should be submitted to:

monika@herewithyou.ca

Requests will be considered and responded to in accordance with PHIPA. Certain circumstances may permit or require a requested correction to be refused. Where applicable, an individual may be entitled to have a statement of disagreement attached to the record.

A privacy breach may include the loss of personal health information or unauthorized access, use, disclosure, copying, modification, or disposal of that information.

If a privacy breach occurs, Here With You Therapy & Wellness will take reasonable and appropriate steps to contain and investigate the incident, reduce the risk of further unauthorized activity, address the effects of the breach, and review safeguards to reduce the likelihood of recurrence.

Affected individuals and the Information and Privacy Commissioner of Ontario will be notified where notification or reporting is required by PHIPA or other applicable law.

Questions, concerns, or complaints regarding the privacy practices of Here With You Therapy & Wellness or the handling of personal health information may be directed to:

Monika Georgieva
Health Information Custodian
Here With You Therapy & Wellness
Email: monika@herewithyou.ca

Privacy concerns and complaints will be reviewed and addressed in accordance with applicable privacy legislation and professional obligations.

Individuals also have the right to make a complaint to the Information and Privacy Commissioner of Ontario (IPC) regarding the handling of personal health information under PHIPA.

Information and Privacy Commissioner of Ontario

Where PIPEDA applies, individuals may also have rights under federal privacy legislation and may contact the Office of the Privacy Commissioner of Canada.

Office of the Privacy Commissioner of Canada

This Privacy Policy may be updated periodically to reflect changes to the practice, technology, professional standards, or applicable privacy legislation.

The current version will be made available on the Here With You Therapy & Wellness website, and the effective date at the top of the policy will be updated when material changes are made.