At Cook Social Work Professional Corporation (“Family TLC”), we are committed to maintaining the accuracy, confidentiality and security of your personal information.
How Personal Information is Collected
As a general rule, Family TLC collects personal information directly from you or from its partners at your request. In circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions).
From time to time, we may use the services of third parties in our activities and operations and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
Form of Personal Information Collected
We may collect information related to you as part of our services including the through your participation in our counselling services or through the internet protocol (“IP”) address and domain used to access our services and website, whether directly or through our technology partners. We use this information to monitor our services as well for our business purposes.
In addition, we collect the personal information that you submit to us, such as your name, username, email address and any other contact or other information that you choose to provide by using a related internet “contact us” submission, direct telephone call or email inquiry.
Where you request information from us, we may use the e-mail address that you provide to send you information about offers on the services that we believe may be of interest to you. If you have asked us to put you on an e-mail mailing list to provide you with certain information on a regular basis, or if we send you information about our offers on products and services by e-mail, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each e-mail and on our website).
Use of Online Services
As we do not control the infrastructure of the internet, to facilitate the provisioning of services to you, Family TLC may permit third-party companies to collect certain information when you visit the Family TLC website or use our services. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other websites in order to provide advertisements likely to be of greater interest to you. These companies typically use a cookie or third-party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit networkadvertising.org.
Third Party Website Links
Our website, social media spaces or email digests may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only. We cannot assume any responsibility for the accuracy or form of the content, privacy practices, policies or actions of the third parties that operate these websites, platforms or portals which you access our services. Family TLC is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these platforms, portals or websites before providing them with personal information.
Purposes of Collecting Personal Information
Generally, Family TLC collects personal information to enable us to undertake, manage and maintain our activities, improve our services and operations, including:
- to establish, maintain and manage our relationship with you so that we may provide you with the services that have been requested;
- for mentoring and supervision related to the services;
- for office administrative reasons such as follow up instructions or billing purposes;
- to be able to review the products and services that we provide to you so that we may understand your requirements for the targeted products and services and so that we and our partners may work to improve the products and services including by providing patches, fixes, bug corrections and other forms of updates and improvements;
- for marketing and promotional purposes, including remarketing to our users about services or events that we think may be of interest to them;
- to conduct research and provide reporting for internal and external clients;
- to be able to comply with your requests;
- to protect us against error, breach, fraud, theft and damage to our property;
- to enable us to comply with all applicable laws or regulatory requirements; and
- any other reasonable purpose to which you consent.
To provide you with a general idea of the scope of the personal health information we collect, this information may include, but is not limited to:
- Your own and/or your child/youth’s name, date of birth, address, school or place of employment;
- Information about the reason for the referral;
- Information about your personal and family history;
- Information about your/your child/youth’s health history, records of your visits and phone calls to Family TLC and the services during these visits; and
- Information about you and your child/youth from other sources if we have obtained your permission to do so.
Storage of Personal Information
Family TLC is the Health Information Custodian of your file and will maintain your file adhering to the privacy legislations of?Personal Health Information Act (PHIA),?while in service, and for 10 years following your last appointment, OR, 10 years from your 18th?birthdate.?
Family TLC has a contingency plan, which will ensure continuity of services?if you are no longer able to see the therapist you have been working with. Client Services will?transfer you to another professional at Family TLC?and continue to maintain your file.
Family TLC understand the importance of protecting personal information, for that reason we have implemented the following safeguards:
- Paper information is stored either under supervision or secured in a locked, secured area;
- Electronic hardware is either under supervision or secured in a locked secured area at all times;
- Computers are appropriately password protected and implement computer security technology to protect all information behind a secure firewall;
- Paper information is transmitted through sealed, addressed envelopes by reputable companies (e.g. Canada Post or Courier);
- Any files being transported are required to be stored in a locked area (e.g. car trunk, carrying case with a locking mechanism);
- Family TLC will not confirm or deny who are clients are unless the external parties provide a voluntary, informed, and signed Consent to Release Information completed by the client;
- It is the policy of Family TLC to protect the privacy and confidentiality of children. Therefore, parents of children under the age of eighteen will not be granted access to their children’s file.
Use of Your Personal Information
We may use and disclose your personal information:
- for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.
We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so including, but not limited to:
Disclosure of Your Personal Information
Where permitted by law, we may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist us in the provision of services to you including, but not limited to, provisioning of counselling services, software hosting/distribution and payment processing; and third parties whose services we use to conduct our activities and operations.
Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements or to the bodies governing our Services including but not limited to the Ontario College of Social Workers and Social Service Workers;
- to insurers or third-party payors such information to demonstrate client entitlement to funding or benefits to be paid (e.g. Private Insurance, EAP Companies, First Nations and Inuit Health);
- to comply with valid legal processes such as search warrants, summonses, or court orders;
- to protect the rights and property of Family TLC;
- to inform a potential victim of violence of a client’s intention to harm;
- to inform an appropriate family member, health care professional or police if necessary of a client’s intent to end his/her life;
- to comply with a legal request to release a client’s file if there is a court order to do so;
- to inform Child and Family Services if there is suspicion of a child being at risk or in need of protection due to neglect, or physical, sexual or emotional abuse; and
- to report to a regulated health professional governing body where a regulated professional has sexually abused a client;
- during emergency situations or where necessary to protect the safety of a person or group of persons;
- if Family TLC is acquired by or merged with another company. Family TLC may disclose your information to satisfy any reasonable diligence required to effect a merger or acquisition without further notice;
- where the personal information is publicly available; or
- with your consent.
We collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. When you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
As described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may withdraw or alter your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
Protection of Personal Information
Family TLC endeavours to maintain physical, organizational, technical and procedural safeguards that are commercially appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss or theft and unauthorized access, copying, use, modification or disclosure.
We kindly ask that you do not submit any sensitive personal information outside of secure channels. Please ask if you have any questions as to whether the channel in which you submit information is secure. If you are sending information to Family TLC via email, please ensure the accuracy of our email address. If you wish to receive information from Family TLC via email, please ensure the accuracy of your email address.
The information that you use and provide is your responsibility.
Additionally, we ask all of our clients to understand the risks involved in using internet-based and telephone-based services. In the event that your account is compromised and/or unauthorized persons gain access to your confidential information, you acknowledge your responsibility for your own account’s security. Family TLC is not liable for any damages or consequences that result from such a breach to your account.
The security of your personal information is important to us. Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
Access to Your Personal Information
Your file contains information provided by you on registration such as username, email and other identifying information. Please contact us to edit, modify or remove this information.
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with, the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
Questions about this Policy
Our Privacy Officer