Dr. Lazarovitz considers the privacy of personal information a fundamental operating principle. He is committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services provided to you. He believes that you have the right to know how he uses your personal information. This document describes Dr. Lazarovitz's privacy policy.

This Policy is based on the protection of privacy issues that face psychologists as scientists and practitioners, the provincial regulatory requirements, the Canadian Code of Ethics for Psychologists, and the Personal Information Protection and Electronic Documents Act (PIPEDA).

What is Personal Information?

According to PIPEDA, which came into effect January 1, 2004, personal information includes "any factual or subjective information, recorded or not, about an individual. This includes information in any form," such as: an individual's personal characteristics (e.g., age, name, income level, ethnic origin, gender, religion, home address or phone number, education and training, family or social status); health information (e.g., health history, health conditions, health services received); activities (e.g., occupation / profession); personal views, ideas and concerns expressed by an individual; or an opinion or evaluation of an individual. Personal information is different from business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.

Dr. Lazarovitz is a registered psychologist and a member in good standing with The College of Psychologists of Ontario.

Your personal information is collected, used and disclosed under the guidelines of The College of Psychologists of Ontario in order to provide psychological / counselling services to you. Dr. Lazarovitz collects information about your health history, including family history, physical condition, functioning and social situation in order to assess your mental health needs, to advise you of your options and then to provide you with the psychological services you choose to have.

Your information is also used to compare your condition at the beginning of treatment to the ongoing record of psychological functioning so that in providing psychological services he can monitor your progress and identify changes that occur over time.

In some circumstances, personal information would be used when a client requests an assessment to obtain a professional opinion about a person's psychological functioning. Once the client's written consent is received, the opinion is reported to the identified person or agency (e.g., an insurance company, Workplace Safety and Insurance Board, psychological/legal reports, no-fault automobile insurance, The Children's Aid Society, and rehabilitation companies).

Although rare in occurrence, there are instances when Dr. Lazarovitz may collect and disclose personal information without your expressed consent. For example, in the event of an emergency (you would be notified of this in writing as quickly as possible) or if it is believed that you would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from a client and Dr. Lazarovitz has no reason to believe that the message is not genuine).

Information Requests About Available Services From Members of the General Public

For members of the general public, the main purpose for collecting personal information (e.g., contact numbers) is to inform them about the range of psychological services available from Dr. Lazarovitz and to provide a referral to another health professional appropriate to their needs.

Additional Reasons for Collecting Your Personal Information

Like most organizations, Dr. Lazarovitz also collects, uses, and discloses personal information for purposes related to or secondary to the above stated purposes. The most common examples include:

• To invoice clients for services that was not paid for at the time, to process credit card payments or to collect unpaid accounts.

• Psychologists are regulated by The College of Psychologists of Ontario who may inspect client records as part of their regulatory duties in the public interest. The College of Psychologists maintains its own strict privacy standards. In addition, as a professional, Dr. Lazarovitz will report serious misconduct, incompetence, or incapacity of other Regulated Health Practitioners as required by law, even if they belong to another organization.

• Some costs of services are paid for by third parties (e.g., private insurance, WSIB, automobile insurance, First Nations and Inuit Health Branch, Canadian Forces, CUPE). Third-party payers must have your consent or legislative authority to direct Dr. Lazarovitz to collect and disclose to them personal information that confirms client entitlement to this funding (e.g., Canadian Forces identification, First Nations identification).

Protecting Your Personal Information

Dr. Lazarovitz appreciates the importance and responsibilities of protecting your personal information. The following steps have been taken to protect your rights:

• Paper information is stored in a secure (locked) or restricted area.

• Electronic hardware is secured in a locked or restricted area at all times. In addition, passwords are used on computers.

• Paper information is transported in sealed, addressed envelopes or boxes by reputable courier services.

• Electronic information is transmitted through secured computer software only to people and agencies that have a privacy policy.

Limits to Protection of Private Information

There are a few limits to the protection of private information. They include: legally mandated disclosure to The Children's Aid Society, The College of Psychologists of Ontario and Court orders to release information, search warrants for a file in a criminal or legal case, and subpoenas.

Retention and Destruction of Personal Information

• As required by The College of Psychologists of Ontario, client information must be kept for a specified amount of time. Because clients may have questions about services or recommendations after they have been received or clients may return months or years later to resume counselling services, client information is retained for a minimum of 10 years following the last contact. This is to ensure that psychologists can respond appropriately to client questions and provide these services. For clients who are seen prior to the age of 18, records are retained for 10 years following their 18th birthday.

• If Dr. Lazarovitz's professional practice were sold, none of the client records would be transferred to or accessed by the new owners.

• Dr. Lazarovitz can also inform you of the arrangements which have been made with respect to your personal information in the event that he is no longer able to continue to provide service.

• Electronic information is destroyed by deleting it. Should the hardware be replaced or discarded, the hard drive will be destroyed. Alternatively, some or the entire client file may be sent to the client. Personal information that is not part of the permanent counselling file is shredded.

You Can Look at Your Information

With a few exceptions, you have the right to see what personal information is held about you. Often, all you have to do is ask, and Dr. Lazarovitz can help you identify what records he might have about you. He will also try to clarify any information you do not comprehend (e.g., short forms / abbreviations, technical language, etc.). Proof of identity may be requested prior to providing you with the information. There may be a small processing fee for such a request. Your request will be best addressed in writing. If access cannot be granted, you will be notified of this within 30 days (if at all possible) with an explanation as to why your request was denied.

If you believe that a mistake has been made regarding your information, you have the right to ask for a correction. This applies to factual information and not to any professional opinions that may be stated. You may be asked to provide documentation indicating a mistake in the file. When a mistake is validated, the file will be corrected and anyone whom was sent this false information by Dr. Lazarovitz will be notified of the error. If a disagreement is declared regarding the information in your file, a brief statement from you on the point will be placed in your file. In addition, Dr. Lazarovitz will forward this statement to anyone else who received the earlier information from him.

Questions or Concerns

Due to the importance of protecting your privacy and Dr. Lazarovitz's adherence to The Canadian Code of Ethics for Psychologists, this policy is more stringent that the legislation requires.

Should you have any questions or concerns about this Privacy Policy, or wish to make a formal complaint, you may make it in writing to Dr. Lazarovitz. He will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal written decision with reasons in writing.

As noted above, this policy is made under the Personal Information Protection and Electronic Documents Act and The Ontario Personal Information Act. These are complex Acts and provide some additional exceptions to the privacy principles that are too detailed to outline here.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsperson for privacy disputes. The Office of the Privacy Commissioner of Canada can be reached at:

112 Kent Street, Ottawa, Ontario, K1A-1H3;
Telephone: (613) 995-8210 or 1-800-282-1376
Fax (613) 947-6850
TTY (613) 992-9190
www.privcom.gc.ca
The Ontario Information and Privacy Commission can be reached at 1-800-387-0073.