Who We Are

The Design Your Life Centre is a private mental health practice providing psychological and psychotherapy services.

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For personal health information in its custody or control, The Design Your Life Centre and/or the regulated health professional responsible for your care may act as a Health Information Custodian as defined by PHIPA.

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Members of our clinical and administrative team who handle personal health information do so only as authorized and as necessary to perform their roles.

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We require members of our team to understand and respect their responsibilities regarding privacy and confidentiality.

What Is Personal Health Information?

Personal health information, or PHI, is identifying information about an individual that relates to their physical or mental health or the provision of health care.

Depending on the services you receive, this may include information such as:

• your name, date of birth and contact information;

• information about your physical or mental health;

• personal, family, relationship and social history;

• information you provide during consultations, assessments or therapy;

• clinical notes, treatment plans and assessment information;

• information about medications, diagnoses or other health-care providers;

• referral information and reports;

• appointment and attendance information;

• billing, payment and insurance information;

• communications relating to your care; and

• other information reasonably necessary to provide psychological or psychotherapy services.

We aim to collect only the information reasonably necessary for the purpose for which it is being collected.

Information Collected Before You Become a Client

You do not need to provide detailed personal health information simply to explore whether The Design Your Life Centre may be right for you.

When you contact us or schedule a complimentary consultation, we may collect basic information such as your:

• name;

• email address;

• telephone number;

• appointment preference; and

• general type of service you are seeking.

Our online scheduling system is intended primarily for scheduling and basic service matching, rather than for collecting detailed clinical information.

For this reason, we ask that you do not include sensitive personal health information or detailed descriptions of your mental health concerns in our online booking form.

If you proceed with services, information necessary for your care will be collected through the appropriate clinical and administrative processes.

Why We Collect and Use Personal Health Information

We may collect and use your personal health information to:

• understand your needs and determine whether our services are appropriate;

• match you with an appropriate clinician;

• provide psychological, psychotherapy, assessment or consultation services;

• develop and support your treatment or care;

• communicate with you about appointments and services;

• coordinate care when appropriate;

• participate in clinical supervision and consultation within our clinical team to support the quality of care we provide;

• maintain accurate clinical records;

• process payments, receipts and insurance documentation;

• meet professional, regulatory, legal and ethical obligations;

• maintain and improve the quality and safety of our services; and

• carry out administrative activities reasonably necessary to operate a health-care practice.

We will not collect, use or disclose more personal health information than is reasonably necessary to accomplish a particular purpose, subject to applicable legal requirements.

Your Consent

Whenever possible, we collect, use and disclose your personal health information with your knowledge and consent.

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Consent may be express or implied, depending upon the circumstances and what PHIPA permits.

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For example, when you choose to participate in therapy and provide information to your therapist, your consent to use that information for the purpose of providing your care may generally be implied.

We will seek express consent where required or where the circumstances make express consent appropriate.

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You may ask questions about how your information will be used at any time.

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You may also withdraw or place conditions on your consent to certain uses or disclosures of your personal health information, subject to legal, professional and contractual limitations. Withdrawing consent cannot generally apply retroactively to information already collected, used or disclosed with valid consent.

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If limiting or withdrawing consent would affect our ability to provide you with safe or appropriate services, we will discuss that with you.

Confidentiality and Its Limits

What you discuss with your therapist is confidential.

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There are, however, circumstances in which a health professional may be permitted or legally required to disclose information without your consent.

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Depending upon the circumstances and applicable law, these may include situations involving:

• a serious risk of harm to you or another person;

• suspected abuse or neglect where reporting is required by law;

• certain concerns involving regulated health professionals;

• a court order, warrant or other legal requirement;

• regulatory investigations or proceedings;

• emergencies; or

• another circumstance in which disclosure is permitted or required by law.

Where we are legally permitted to do so, we aim to discuss such disclosures with you.

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When information must be disclosed, we endeavour to disclose only the information reasonably necessary for the purpose.

Safeguarding Your Information

We take reasonable administrative, technical and physical measures to protect personal and personal health information against:

• unauthorized access;

• unauthorized use or disclosure;

• loss or theft;

• copying or modification;

• accidental disclosure; and

• improper disposal.

Depending upon the information and system involved, safeguards may include password protection, encryption, secure clinical record systems, access controls, confidentiality agreements, staff training and procedures governing the handling of personal health information.

Access to clinical information is limited to individuals who require it to carry out their authorized responsibilities.

Electronic Records and Technology Providers

Like most contemporary health-care practices, we use technology to support certain aspects of our work.

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This may include third-party providers that support functions such as:

• electronic clinical records;

• appointment scheduling;

• secure forms;

• email and communications;

• video appointments;

• payment processing;

• accounting and administrative functions; and

• website operation.

We select services with privacy and security in mind and take reasonable steps to ensure that personal health information is protected appropriately.

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Where a third-party provider processes information on our behalf, we remain responsible for meeting our obligations under PHIPA and take reasonable steps to ensure that information is handled only for authorized purposes.

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Some technology providers may process or store information outside Ontario or Canada. When this occurs, information may be subject to the laws of the jurisdiction in which it is processed or stored.

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For this reason, we seek to minimize both the amount and sensitivity of information collected through non-clinical systems.

Email, Text Messages and Electronic Communication

We may use email, telephone, text messaging or other electronic communication for administrative purposes such as scheduling and appointment reminders.

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Although we take reasonable precautions, ordinary email and text messaging cannot be guaranteed to be completely secure.

We therefore encourage clients not to send highly sensitive clinical information through ordinary email, text messages or website forms unless specifically instructed to do so through an approved secure method.

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If you have questions about the safest way to send information to us, please contact our office.

When We May Disclose Personal Health Information

We do not sell personal health information.

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We may disclose personal health information:

• when you have provided consent;

• to another health-care provider involved in your care, where authorized or permitted by law;

• to service providers or agents assisting us in delivering or administering services, where appropriate safeguards are in place;

• for billing or insurance purposes where authorized;

• where disclosure is permitted or required by PHIPA or another law; or

• where necessary to comply with regulatory or legal obligations.

Whenever reasonably possible, we limit disclosure to the information necessary for the particular purpose.

Clinical Supervision and Consultation

As part of our commitment to providing thoughtful, high-quality care, clinicians at The Design Your Life Centre participate in ongoing clinical supervision and consultation within our clinical team.

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This may include individual and group supervision in which clinicians reflect on their work, consider different therapeutic perspectives, and support one another in providing effective and ethical care.

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When client cases are discussed in group supervision, personal identifying information is not shared. Case material is presented in a way that protects the client’s identity and confidentiality.

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All clinicians participating in supervision and consultation are bound by professional and ethical obligations regarding privacy and confidentiality.

Where circumstances arise in which sharing identifiable personal health information is necessary for a client’s care, this will occur only with appropriate consent or where otherwise permitted or required by law.

Clinical Records

If you receive services through The Design Your Life Centre, a clinical record will be created and maintained in accordance with applicable legislation and the requirements of the clinician’s regulatory college.

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Clinical records may include information such as:

• intake and consent documentation;

• assessment information;

• session notes;

• treatment plans;

• correspondence relevant to your care;

• reports;

• consultation information; and

• billing and administrative information associated with your care.

Clinical records are retained for a minimum of 10 years following the client’s last professional contact with the Centre, or for 10 years after the client reaches the age of 18, whichever is later, unless a longer retention period is required by law or applicable professional standards.

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At the end of the required retention period, records may be securely destroyed or permanently deleted in a manner designed to protect client confidentiality.

Accessing Your Personal Health Information

In most circumstances, you have the right to request access to personal health information about you that is in our custody or control.

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You may be asked to submit your request in writing so that we can clearly understand what information you are requesting and verify your identity.

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We will respond to formal requests within the timelines established by PHIPA.

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There are limited circumstances in which PHIPA permits or requires access to be withheld. These may include certain information that relates to another individual, information subject to legal privilege, and certain raw data from standardized psychological tests or assessments.

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A reasonable fee may be charged for providing access or copies where permitted by law. If a fee will apply, we will provide information about the anticipated cost before proceeding.

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Requests for access should be directed to our Privacy Officer using the contact information below.

Correcting Your Personal Health Information

We want your health record to be accurate.

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If you believe that factual information in your record is inaccurate or incomplete, you may request a correction.

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There are circumstances in which information may not be changed—for example, a professional opinion or observation made in good faith.

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Where applicable, you may have the right to have a statement of disagreement associated with your record if a requested correction is not made.

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Requests for correction should be directed to our Privacy Officer using the contact information below.

If a Privacy Breach Occurs

Despite strong safeguards, no information system can eliminate every possible privacy risk.

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If personal health information is lost, stolen, accessed, used or disclosed without authorization, we will take appropriate steps to:

• contain the breach;

• determine what occurred;

• reduce the possibility of further unauthorized access or disclosure;

• notify affected individuals where required;

• take steps to prevent a recurrence; and

• notify the Information and Privacy Commissioner of Ontario and/or the appropriate regulatory college where required by law.

We will respond to privacy breaches in accordance with PHIPA and applicable professional requirements.

Website Information, Cookies and Analytics

When you visit our website, certain technical information may be collected automatically, such as:

• IP address;

• browser and device information;

• pages visited;

• referring website;

• date and time of access; and

• cookie or analytics information.

We may use this information to operate our website, understand how visitors use it, improve its performance and maintain security.

Where our website uses cookies or analytics services, those providers may process information according to their own privacy practices.

Website analytics information is not intended to form part of your clinical record.

You may be able to restrict or disable cookies through your browser settings, although doing so may affect certain website functions.

Website Forms and Appointment Scheduling

Information submitted through our website or appointment-scheduling platform should be limited to the information requested.

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Our online consultation-booking system is intended for scheduling and basic service matching, not for submitting detailed clinical information.

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Please do not enter sensitive personal health information into a website or scheduling form unless the form specifically indicates that it is intended and secured for that purpose.

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If you become a client, we will provide appropriate methods for collecting information required for your care.

Links to Other Websites

Our website may contain links to websites or services operated by other organizations.

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Once you leave our website, the privacy practices of the external organization apply. The Design Your Life Centre is not responsible for the privacy practices or content of third-party websites.

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We encourage you to review their privacy policies before providing personal information.

Our Privacy Officer

The Design Your Life Centre has designated Dr. Stacy Thomas as its Privacy Officer.

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The Privacy Officer is responsible for overseeing our privacy practices, supporting the Centre’s compliance with PHIPA, responding to privacy questions and concerns, facilitating requests for access to or correction of personal health information, and receiving privacy complaints.

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Privacy Officer
Dr. Stacy Thomas
The Design Your Life Centre
321 Carlaw Avenue, Suite 209
Toronto, Ontario M4L 0A6

Email: drstacy@designyourlifecentre.com
Telephone: 647-478-9297
Fax: 647-417-7108

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Please avoid including detailed personal health information in an initial email to the Privacy Officer. If sensitive information is required, we will advise you of an appropriate way to provide it securely.

Privacy Questions or Complaints

If you have a question or concern about how your information has been collected, used, disclosed or protected, we encourage you to contact our Privacy Officer:

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Dr. Stacy Thomas
Email: drstacy@designyourlifecentre.com
Telephone: 647-478-9297

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We take privacy concerns seriously and will make reasonable efforts to understand and respond to your concern.

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You will not be penalized or treated differently for raising a privacy concern or making a complaint.

Information and Privacy Commissioner of Ontario

If you have concerns about our privacy practices or believe your rights under PHIPA have not been respected, you also have the right to contact or make a complaint to the Information and Privacy Commissioner of Ontario (IPC).

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Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8

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Telephone: 416-326-3333
Toll-free: 1-800-387-0073
Fax: 416-325-9195

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The IPC provides information about privacy rights and receives complaints relating to the collection, use, disclosure, access and correction of personal health information.

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You do not need our permission to contact the IPC.

Keeping Our Privacy Practices Current

We may update this Privacy & Personal Health Information Policy from time to time to reflect changes in our services, technology, professional requirements or applicable law.

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The most current version will be posted on our website with the date it was last updated.

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If we make a significant change affecting how we collect, use or disclose personal health information, we will take reasonable steps to provide appropriate notice.