Privacy & Information Management Program:
How the business handles and protects information in its care
Privacy Management, Information Handling & Use of Personal Information
Personal information is collected, used, and maintained in accordance with standards outlined by relevant privacy legislation acts, such as the Freedom of Information and Protection of Privacy Act (FOIP), the Health Information Act (HIA), the Personal Information Protection Act (PIPA), and the Personal Information Protection and Electronic Documents Act (PIPEDA), and in accordance with the College of Alberta Psychologists’ Practice Guidelines.
The below outlines current privacy management and information handling practices Yellowtree Therapy Services adheres to, which were built primarily around the Acts and Guidelines mentioned above. The practices outlined here are subject to change. Changes will be made available through this website. You are encouraged to review this page periodically for the most current information.
Collection & Handling of Personal Information
What information is collected and why?
Personal Information is collected and recorded when such information is required to contact the client for business purposes including but not limited to client record maintenance, collection of payment, issuing invoices, appointment reminders, and notification of business changes. Examples of information collected for business purposes include, but are not limited to: name, date of birth, phone number, email address, and credit card information.
Other Information is collected and recorded during therapy sessions when it is deemed by the therapist to be relevant for assessment (e.g. collecting demographic and background information) or when it is deemed important for planning intervention, monitoring progress, and planning ongoing care (e.g. asking questions about current functioning and situation, future plans, and/or requesting letters/reports written for or received by the client).
How is information collected and kept?
Personal Information provided by clients on intake (e.g. information provided when booking appointments, information provided on intake forms or consent forms, credit card information) is collected through, and kept within, the therapist's chosen secure Practice Management Software and point-of-sale (POS) systems.
Other Information gathered by the therapist in session or through other communications with clients (e.g., phone calls, emails, video-conferencing) may be recorded in the therapist’s Clinical Notes, at the discretion of the therapist, based on whether the therapist deems the information relevant to the therapeutic process. The information gathered by the therapist is recorded and maintained by the therapist in one of two ways:
1. Clinical Notes are recorded using secure technologies (e.g. iPad) that are secured with password-protection and end-to-end encryption. Clinical notes are either recorded in a secure app on the device then transferred to the secure, password-protected, encrypted Practice Management Software’s Electronic Medical Records (EMR) or are taken in and saved directly to the Practice Management Software’s EMR.
2. Clinical notes are recorded on physical paper. Once recorded, photos are taken with secure technologies, then uploaded directly to the Practice Management Software’s EMR. The physical paper copy is shredded and disposed of.
How is Personal Information and Other Information kept correct, accurate, and up-to-date?
Clients are asked to inform the therapist if their contact information (e.g., phone number, email address, etc.) is incorrect or needs to be updated. When a request to correct or update Personal Information is received, the therapist will correct/update it as soon as reasonably possible. The therapist will conduct a brief review of the client’s file periodically (usually before each session with the client) to ensure the clinical notes are accurate, complete, and current.
Who has access to my information and to whom is it disclosed?
Your therapist and your therapist's supervisor(s), Brooke Hendricks (primary supervisor) and Diane Priebe (secondary/back-up supervisor), will have access to your Personal Information and Other Information. The therapist, who is practicing as a provisional psychologist, is required by the College of Alberta Psychologists to receive ongoing supervision for mental health services provided to clients. As such, the therapist will share client information, including identifying information, with the supervisors for the purpose of receiving necessary supervision and providing optimal client care.
The therapist may consult with other professionals (e.g., art therapists, provisional psychologists, registered psychologists) about client cases if it is deemed to be in the client's best interest and only for the purpose of providing optimal client care. In cases where the therapist deems it to be in the best interest of the client to consult with another professional (aside from the supervisors) about a case, the therapist will ensure client anonymity. She will not share any identifying personal information about the client and will limit information shared to that which is necessary to receive appropriate consultation (e.g., general information about the presenting issues).
Any administrative support person for Yellowtree Therapy Services may also have access to your personal information on a need-to-know basis for the purpose of ensuring optimal client care, including file management and technology support.
Your information may also be used for the purpose of billing and collections, if required.
The Personal Information & Protection Act (PIPA) outlines what consent is and when and how it is to be obtained. Yellowtree Therapy Services abides by these standards and by the College of Alberta Psychologists’ Informed Consent Practice Guidelines and the Canadian Psychological Association Code of Ethics. The College of Alberta Psychologists defines consent as "permission to do something." Consent should be:
Informed - you understand the services you are agreeing to prior to receiving those services and based on sufficient information. You are invited to "fully and actively participate in the decisions that effect you and your opinions and wishes are integrated as much as possible" (Canadian Psychological Association Code of Ethics).
Ongoing - you have the right to withdraw consent at any time. As your therapist, I will do my best to check in with you periodically to ensure you still consent to receiving services.
Specific - you know what services you are consenting to.
Confidentiality refers to keeping information secret or private. According to the College of Alberta Psychologists' Standards of Practice "confidential information" is information that is revealed by the client to the therapist with the expectation of privacy.
Limitations in Maintaining Confidentiality
There are certain circumstances, outlined in the College of Alberta Psychologists’ Informed Consent Practice Guidelines and Disclosure of Personal or Confidential Information Guidelines, under which the therapist may be required to disclose your information without your consent. Broadly speaking, the therapist may be required to disclose your information without your consent when:
there is known risk of harm to the health or safety of a minor
the therapist has reasonable grounds to believe the client poses an imminent risk to their own safety or the safety of others, including public safety
the therapist has reasonable grounds to believe that their is risk of harm to the public by a member of a regulated health profession
permitted or required by law, including mandatory reporting to the Workers' Compensation Board Alberta (WCB) in accordance with The Workers' Compensation Act
also see Who has access to my information and to whom is it disclosed? above
In these circumstances, the information released will be limited to persons “who reasonably [need] to know and to the extent necessary in the circumstances.”
Access Request by a Client
In accordance with the College of Alberta Psychologists' Psychological Records Practice Guidelines and Disclosure of Personal or Confidential Information Guidelines, “under various pieces of legislation, clients have the right to request and receive their record in a timely way. The only exception for release is when there is a ‘substantial adverse effect or harm’ by releasing a record. The client’s reason for the release of a record can be requested by [the therapist] so they may consider whether there may be a risk of harm prior to release.” The therapist shall provide access, as deemed appropriate, within 30 calendar days of the request.
A set fee of $25 will be charged to the client for producing a copy of the file (whether a hard copy, an electronic copy, or both). This fee includes the cost of photocopying/printing the first 20 pages of the record, preparing the document, removing information as necessary, and reviewing the record. This is the recommended fee set out in the Health Information Act.
Disposal of Information
Client records are maintained for a minimum of 10 years after the last date of professional contact with the client, as per the College of Alberta Psychologists' Standards of Practice for Psychological Records. Client Records will be reviewed each year to determine the last date of professional contact. When a Client Record is destroyed, the client’s name and unique identifier(s) will be kept indefinitely on a list of “destroyed files” that is kept on a secure, password-protected device.
Information that is no longer required for an identified purpose or a legal requirement will be destroyed, erased, or rendered anonymous.
Abandoned Psychological Records
In the case of the therapist’s unexpected absence from practice, the therapist’s supervisors will take professional responsibility for client records. Once the therapist attains Registered Psychologist status through the College of Alberta Psychologists, she will assign another professional to take responsibility for client records in the event of an unexpected absence.
Breach and Incident Management Protocol
In the event of breached, lost, or stolen psychological records, Yellowtree Therapy Services will follow the guidelines set out in the College of Alberta Psychologists' Psychological Records Practice Guidelines. This includes:
Assessing the loss
Consulting with appropriate bodies
Consulting legislations and guidelines
Fulfilling obligations to report on the breach
Determining steps to prevent future loss
Email Security for Communications with any @yellowtreetherapy.com Email Address:
When communicating with any health professional by email, you are consenting to associated email risks. Although every effort is taken to keep email confidential, email cannot be guaranteed to be secure, as rare breaches of privacy could potentially occur. Please consider carefully before emailing personally identifying or confidential information to any health professional.
Concerns or Complaints about Privacy Matters
If you are concerned about the privacy of your personal information at Yellowtree Therapy Services, you are encouraged to discuss these concerns with your therapist or email firstname.lastname@example.org. If you would like to file a complaint regarding how your information is being handled, please refer to the website of the Information and Privacy Commissioner for more information; contact the FOIP-PIPA Help Desk; or refer to the College of Alberta Psychologists’ website.
Assessment of Personal Information Management
This privacy management program will be assessed a minimum of once per year to ensure it is kept up to date with relevant privacy legislations and professional standards, and to address any shortcomings. To ensure Yellowtree Therapy Services’ practices reflect current legislation and professional standards, assessment will involve a review of the current privacy management program and review of relevant privacy legislation acts, such as the Freedom of Information and Protection of Privacy Act (FOIP), the Health Information Act (HIA), the Personal Information Protection Act (PIPA), the Personal Information Protection and Electronic Documents Act (PIPEDA), and the professional standards of practice set out by the College of Alberta Psychologists.
Thank you for reading!
Please email email@example.com if you have questions.
Last Updated: Nov 30, 2020