Introduction

The Sereda Psychotherapy Group (“The Sereda Psychotherapy Group”) is committed to protecting the privacy and confidentiality of the personal health information we collect from our clients. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal health information in compliance with Canadian privacy laws, including the *Personal Health Information Protection Act, 2004* (PHIPA) and the *Protection of Personal Information and Electronic Documents Act* (PIPEDA).

In this Privacy Policy, “you”, “your”, and “client” or “clients” refer to the users of The Sereda Psychotherapy Group’s services. This includes a user’s substitute decision-maker as defined under PHIPA.

What is Personal Health Information?

The practice of psychotherapy in Ontario is regulated under the *Regulated Health Professions Act* (RHPA). All identifiable information collected by a psychotherapist about an individual while engaging in psychotherapy services is considered “personal health information” under PHIPA. This includes your name, contact information, and any information collected or recorded in the course of providing services to you or your minor child.

Collection of Your Personal Health Information

We collect your personal health information directly from you or the parents/caregivers of a minor child, except:

1. When you have provided consent to obtain information from others (e.g., reports, assessments, or other relevant services); or
2. When the law requires or allows us to collect information without your consent (e.g., urgent situations where information is needed to prevent potential harm).

We collect only the information we believe is necessary to:

• Provide you with the psychotherapy services you have requested;
• Maintain contact with you for service-related purposes; and
• Prevent harm (e.g., emergency contact information).

By law and in accordance with professional standards, we are required to keep a record of services and contacts with you or your minor child. Your record includes information you provided to us or authorized us to receive, such as assessment results, consent forms, session notes, billing information, contact logs, and correspondence.

In this practice, information is recorded in both written and electronic form. For electronic records, we use Noustalk, a Canadian fully encrypted service that is private, confidential, and meets all of Canada’s privacy laws, including PHIPA. Noustalk and any other third-party service providers we engage are also required to comply with PHIPA and other applicable privacy laws. We ensure that contracts are in place with these providers to safeguard your personal health information and maintain confidentiality.

Use of Your Personal Health Information

Your personal health information is used to provide psychotherapy, counselling, and consultation services to you or your minor child. This includes carrying out all functions reasonably necessary to provide those services.

Paper and electronic information are secured in locked or restricted areas at all times, and passwords are used on computers. Electronic information is transmitted through Noustalk, a Canadian fully encrypted service that complies with PHIPA. Faxing is sometimes used to send or receive confidential client information.

The College of Registered Psychotherapists of Ontario (CRPO), the organization that regulates psychotherapists in Ontario, may access and inspect client records as part of an external audit. All professionals involved in these activities are required by law to maintain confidentiality.

Disclosure of Your Personal Health Information

With only a few exceptions, your personal health information will not be disclosed to persons outside this practice without your knowledge and expressed, written consent. The exceptions, known as limits of confidentiality, include:

1. When allowed by law (e.g., clear and imminent risk of serious bodily harm to someone; professional or legal consultation); and
2. When required by law (e.g., mandatory reporting of a child in need of protection; mandatory reporting of a regulated health professional who has sexually abused a client; a court order to release information).

Please note that any disclosure of your personal health information is limited to information that is reasonably necessary for the purpose of the disclosure and does not include private information provided by a third party.

Right of Access to Your Personal Health Information

With limited exceptions, you have the right to access any record of your personal health information and to request copies of the information (we reserve the right to charge a nominal fee for record copying). If the record contains personal health information about another individual, that individual’s information must be redacted before you may access the record.

If you believe that information in your record is inaccurate, you have the right to request a correction. This applies to factual information, not to the professional opinion of your therapist. Your request to correct the record must be written and will require 30 days to review. If we agree there is an error, we will make the necessary correction and notify all persons to whom the information was sent. If we do not agree to correct the record, you may file a notice of disagreement, which will be added to your record.

Retention and Destruction of Personal Health Information

We retain personal health information to ensure we can answer any questions you might have about the services provided and for our accountability to regulatory bodies. The CRPO requires that client records be kept for at least 10 years past the date of last contact for adults, and 10 years past the date at which the client would turn 18 years of age.

We destroy paper records through shredding, remove electronic information through deletion, and physically destroy the hard drives of discarded hardware.

Website Privacy and Cookies

Our website uses cookies to ensure you get the best experience. Cookies are small text files placed on your device to help personalize your online experience. They cannot be used to run programs or deliver viruses.

We use cookies to:

• Track visitor preferences and usage patterns;
• Improve website functionality; and
• Analyze website traffic.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline them if you prefer.

Privacy Breach Protocols

If The Sereda Psychotherapy Group or a Therapist becomes aware of a privacy breach, we will:

1. Notify the affected parties;
2. Contain and minimize the breach;
3. Assess the risk of access to the personal health information;
4. Investigate the circumstances leading to the breach;
5. Implement improved processes to prevent future breaches; and
6. Report to the regulator, as required by law.

Rights of Minors

Under PHIPA, minors who are capable of understanding the nature and consequences of their decisions have the right to consent to or refuse the collection, use, and disclosure of their personal health information. In such cases, the minor’s consent or refusal will be respected, and their privacy rights will be upheld. For minors who are not capable of making these decisions, a parent, guardian, or substitute decision-maker may act on their behalf.

Questions or Concerns

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact our Privacy Officer:

Privacy Officer
privacyofficer@seredapsychotherapy.com

You may also contact:
The Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Phone: 416-326-3333 or 1-800-387-0073
Website: www.ipc.on.ca

If you have concerns about the professionalism or competence of our services, you may contact:

The College of Registered Psychotherapists of Ontario
375 University Avenue, Suite 803
Toronto, Ontario M5G 2J5
Phone: 416-479-4330 or 1-844-712-1364
Email: info@crpo.ca

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Changes will be effective immediately upon posting on our website. Your continued use of our services constitutes your acceptance of the updated Privacy Policy.

This Privacy Policy was last updated on March 12, 2025.

Your privacy is critically important to us. Thank you for trusting The Sereda Psychotherapy Group with your care.