Confidentiality and Privacy Policy

Confidentiality and Privacy Policy

JILLIAN HOSEY MSW RSW protects and respects the confidentiality of all information entrusted to herself, except as permitted or required by law, and in accordance with all municipal, provincial and federal legislation.

The following is considered confidential information:

  • All matters/documentation relating to clients.
  • All contracts.
  • All Human Resources files and proceedings.
  • All financial information, status and statements.
  • All information or documentation labelled “Confidential” by JILLIAN HOSEY MSW RSW, or listed as such by separate memorandum, or email that advises confidential status.

This information may be related to, without being limited to, personal information of any kind about clients as well as information about the operations of JILLIAN HOSEY MSW RSW (e.g., personnel matters, internal financial procedures, contractual information, and intellectual property of JILLIAN HOSEY MSW RSW).

Respect for JILLIAN HOSEY MSW RSW’s confidentiality and privacy policy is of utmost importance.  Confidential information shall not be used for any purpose other than its reasonable use in the normal performance of social work and psychotherapy duties.

Requirement of Confidentiality

In accordance with PHIPA (Personal Health Information Act), JILLIAN HOSEY handles sensitive personal client information in a confidential and appropriate manner. JILLIAN HOSEY MSW RSW will take all reasonable precautions to safeguard the confidentiality of such information (e.g., ensuring confidential material is kept locked when not being used; shielding computer screens with confidential information from unauthorized viewing; taking special precautions when transporting confidential documents).

Privacy Statement

JILLIAN HOSEY MSW RSW collects and uses personal information about her client in order to:

  • Provide quality treatment plans and services to clients.
  • Provide information to other people or organizations with client consent (for example, making a referral for service).
  • Review client files to ensure high quality of service and documentation.

JILLIAN HOSEY MSW RSW may also collect, use and share personal information with consent or as permitted or required by law or contract.

Client Privacy

JILLIAN HOSEY MSW RSW is committed to protecting the privacy of her clients and ensuring that:

  • the personal information she receives from clients is kept safe, secure, confidential, accurate and up to date;
  • clients understand why their personal information is collected by her;
  • JILLIAN HOSEY MSW RSW obtains client consent before collecting, using, sharing or releasing client information, except as set out in this policy or permitted or required by law;
  • only the personal information necessary for the purposes listed above is collected from clients, unless otherwise consented to by the client or permitted or required by law;
  • access to client information is limited to JILLIAN HOSEY MSW RSW only;
  • any external agents to whom JILLIAN HOSEY MSW RSW releases information have a need to know and only use and disclose client information for the purposes for which it was originally provided;
  • clients are able to withdraw their consent at any time to the collection, use and disclosure of their personal information;
  • clients have access to their record, except where JILLIAN HOSEY MSW RSW is entitled to refuse an access request, and are able to copy or correct their record and ask questions about JILLIAN HOSEY MSW RSW’s privacy policies and procedures;
  • all legal and regulatory requirements regarding client information are met and maintained.

Procedures

Obtaining Consent for the Collection, Use and Disclosure of Personal Information

  1. As JILLIAN HOSEY MSW RSW’s services may involve collaboration and consultation with other wellness professionals, JILLIAN HOSEY MSW RSW will request informed, written consent to discuss the following with new clients:
    • the nature and extent of consultation and collaboration with JILLIAN HOSEY MSW RSW which the new client is accessing;
    • the personal information that JILLIAN HOSEY MSW RSW may collect;
    • the purposes for which JILLIAN HOSEY MSW RSW collects, uses and shares personal information, as listed above.
  2. Client’s rights and responsibilities including rights related to keeping client’s personal information private will be reviewed with all new clients at their first appointment following intake.
  3. Clients will be asked to sign an electronic form on Jane App indicating that JILLIAN HOSEY MSW RSW’s privacy policies have been discussed and that the client consents to the collection, use and sharing of personal information for the purposes listed in this policy.
  4. Consent will be that of the individual and must be knowledgeable, relate to the personal information and not be obtained through deception or coercion. A consent to the collection, use or sharing of personal health information about an individual is knowledgeable if it is reasonable in the circumstances to believe that the individual knows, (a) the purposes of the collection, use and/or disclosure, as the case may be; and (b) that the individual may give or withhold consent.

Client Withholding, Limiting or Withdrawing Consent

  1. Clients are informed of their responsibility to provide relevant information as a basis for receiving services and participating in service decisions.
  2. Clients have the right to stipulate who will have access to their personal information. This means that they can withhold, limit or withdraw their consent to the collection, use or disclosure of personal information. The request may cover all or a specific part of a client’s record. When this happens, JILLIAN HOSEY MSW RSW will implement the following “lockbox” procedure.
    • Electronic Records: JILLIAN HOSEY MSW RSW Receives the Client’s Request to Withhold, Limit or Withdraw Their Consent Will
      • Record the verbal instructions by the client in an activity note in the client’s electronic record.
      • Scan any written instructions by the client into the client’s electronic record.
    • Paper Records: If the Client Also has a Paper File
      • The client’s file (either in whole or in part depending on the client’s instructions) to which access is to be limited will be placed inside an envelope that will be sealed with the instructions from the client stapled to the outside of the file.
      • If the client’s request is to withdraw consent, the file will be safeguarded by JILLIAN HOSEY MSW RSW.
  3. In cases where the withholding, limiting or withdrawal of consent will limit or prevent JILLIAN HOSEY MSW RSW from continuing to deliver services, JILLIAN HOSEY MSW RSW will discuss with the client the consequences of their withholding, limiting or withdrawal of consent.

Disclosure Without Consent Including Responding to Summons/Subpoenas/Court Orders and Requests from Police

  1. JILLIAN HOSEY MSW RSW will not disclose the personal information of clients without their consent, except where:
    • It is believed the client or someone else is in imminent danger of serious physical harm (Duty to Report);
    • A child under the age of 16 is at risk of or has been abused or neglected);
    • A client has reported being abused or assaulted by a healthcare practitioner;
    • JILLIAN HOSEY MSW RSW is subpoenaed or is otherwise served with a court order, summons, warrant or a similar requirement issued by a person who has jurisdiction to compel the production of information in a proceeding (such as a proceeding held in, before or under the rules of a court, a tribunal, a commission, a justice of the peace, a coroner, a committee of a College within the meaning of the Regulated Health Professions Act, 1991, a committee of the Ontario College of Social Workers and Social Service Workers under the Social Work and Social Service Work Act, 1998 or an arbitrator) or  it is otherwise permitted or required by law.
  2. If JILLIAN HOSEY MSW RSW is served with a warrant, summons, subpoena, order or similar requirement issued in a proceeding, JILLIAN HOSEY MSW RSW will immediately advise the client.
  3. In general, where an order, summons, warrant, subpoena or other requirement to produce documents has been served on JILLIAN HOSEY MSW RSW, JILLIAN HOSEY MSW RSW will:
    • make every attempt to respond in a way that is respectful of the order or other requirement, while at the same time taking steps to preserve the client’s right to confidentiality;
    • make an exact copy of the file to remain at JILLIAN HOSEY MSW RSW and deliver the documents to the court or other proceeding in a sealed enveloped marked “private and confidential”.
  4. Where JILLIAN HOSEY MSW RSW discloses personal information without the client’s consent, the client will be notified of such disclosure as soon as reasonable, practical, safe and/or legally possible in the circumstances.

Release of Information to Third Parties With Client Consent

  1. Personal information, whether all or part of a client record, will not be released to third parties without the written consent of the client or the client’s substitute decision maker, where applicable, except for being contained within the Jane App belonging to JILLIAN HOSEY MSW RSW. Clients are required to complete the JILLIAN HOSEY MSW RSW Consent for the Release of Information Form or the Consent for the Exchange of Information Form, depending on the nature of the request. Consents provided on these forms are valid for 90 days from when authorization is given if it is for a one-time release of information or one year when a contracted or cooperating service provider requires the release of information for ongoing service provision, unless otherwise limited or withdrawn by the client in advance of that date. JILLIAN HOSEY MSW RSW may disclose a client’s personal information, provided that the disclosure, to the best of JILLIAN HOSEY MSW RSW’s knowledge, is for a lawful purpose.
  2. Reports from third parties contained in a client record may not be released without the written consent of the third party. Clients will be encouraged to pursue access to this information directly with the third party.
  3. In exceptional circumstances, where written consent is not possible, the oral consent of the client to the release of personal information will be accepted and will be recorded in the client’s file.
  4. In response to requests to release information to third parties, JILLIAN HOSEY MSW RSW will determine if the reason to release information is valid, ensure that the client understands the purpose for which the information is being released and to whom the information is being released. JILLIAN HOSEY MSW RSW will also explain that JILLIAN HOSEY MSW RSW cannot guarantee the confidentiality of the information once it has been released.

Safeguarding of Personal Information

  1. Client information stored electronically is protected by password on Jane App. Access to the JILLIAN HOSEY MSW RSW’s electronic database is limited on a need to know basis for added security.
  2. Client information collected in hard copy form is stored in locked cabinets accessible only by JILLIAN HOSEY MSW RSW.
  3. Access to client information will be limited to those who need to know the information for the purposes set out in the client’s consent or as otherwise permitted or required by law.
  4. JILLIAN HOSEY MSW RSW will never leave client personal information, in paper or electronic form, unattended or exposed to anyone other than the client.
  5. JILLIAN HOSEY MSW RSW will not send confidential personal information to clients by email without the client’s prior consent (please see JILLIAN HOSEY MSW RSW’s email policy)
  6. Client information will not be transmitted via email to third parties.
  7. Web based therapy will use a PHIPA compliant, encrypted website to protect client privacy and confidentiality.
  8. When disposal is permitted or required, records of client personal information will be disposed of in a secure manner such that reconstruction of the records is not reasonably foreseeable in the circumstances.

Notice to Clients of Theft, Loss, Unauthorized Access, Use of Disclosure of Client Information

  1. JILLIAN HOSEY MSW RSW will immediately report any theft, loss, unauthorized access, use or disclosure of personal information of JILLIAN HOSEY MSW RSW to clients immediately upon becoming aware of this either verbally or via email.
  2. In the event of such theft, loss, unauthorized access, use or disclosure of personal information of JILLIAN HOSEY MSW RSW’s client, JILLIAN HOSEY MSW RSW will immediately launch an investigation into the breech and notify the client as soon as possible.
  3. Oral contact with the clients will be logged in the client record and will be followed up by a letter, which will be included in the client record.
  4. In the case of former clients, contact will be made orally, if possible, and also in writing, at the last known address for the client recorded in JILLIAN HOSEY MSW RSW’s database.

 

Client Access to and Correction of Personal Information

  1. Clients wishing to review their records should contact the JILLIAN HOSEY MSW RSW and request access to their file in writing.
  2. Within 30 days of any such request, an appointment will be made for the client to review his/her personal information in a confidential manner on JILLIAN HOSEY MSW RSW’s premises, in the presence of JILLIAN HOSEY MSW RSW. Up to 60 days may be required in the case of complex searches for records. Clients may bring a support person to this appointment if they wish. Clients will show a copy of picture identification to verify their identity. In exceptional circumstances (e.g., a client is unable to come to the JILLIAN HOSEY MSW RSW office due to health issues), a copy of the record may be sent by registered mail to the individual with consent and verification of their identity. Where indicated, safety precautions related to the receipt of the file will be reviewed with the client and documented in the record prior to its release.
  3. JILLIAN HOSEY MSW RSW is required to retain client personal information that is the subject of a request for access for as long as necessary to allow the client to exhaust any recourse under the Personal Health Information Protection Act, 2004 that he or she may have with respect to the request.
  4. Clients who wish an explanation of their records may contact JILLIAN HOSEY MSW RSW.
  5. Clients will not be permitted to access third party records without the consent of the third party. In such cases, JILLIAN HOSEY MSW RSW will direct the client to obtain the requested information directly from the third party.
  6. Clients wishing to correct information in their file shall provide the correction in writing to JILLIAN HOSEY MSW RSW. The written correction will be included in the client’s record and, within three weeks of receipt, JILLIAN HOSEY MSW RSW will notify the client of its response to the correction.
  7. In instances where clients request a copy of their record, they will be required to sign a form acknowledging that JILLIAN HOSEY MSW RSW retains no responsibility for the record once it is released.

Inquiries and Complaints

  1. Questions, comments or complaints about JILLIAN HOSEY MSW RSW’s privacy policies and procedures or about the collection, use or disclosure of personal information may be made directly to JILLIAN HOSEY MSW RSW to come to a fair and equitable resolution.

Legal

This agreement will not supersede any legal obligation to disseminate information when required to do so in a court of law.

Privacy Policy

JILLIAN HOSEY MSW RSW is committed to providing website users with a website which respects their privacy. In particular, the protection of confidential member information is of paramount importance to JILLIAN HOSEY MSW RSW. In this context, the Social Work and Social Service Work Act, 1998 provides for the confidentiality of information related to the administration of the Act.

Through this website and Jane App, JILLIAN HOSEY MSW RSW only obtains specific personal information from you, such as your name, phone number or e-mail address, if you supply such information (by, for example, sending us an e-mail, submitting an inquiry, or providing such information in a secure portion of the site).  Additional information, such as reason for seeking services, will be requested to be provided in an intake form via Jane App, however, clients can refuse to provide this information online at anytime.  JILLIAN HOSEY MSW RSW requires all clients to read, review, and acknowledge the consent forms presented in the request for intake information through Jane App.

JILLIAN HOSEY MSW RSW will not trade, sell or rent your personal information. JILLIAN HOSEY MSW RSW takes precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction. You can help by also taking precautions to protect your personal information when you are on the Internet. For example, change your passwords often using a combination of letters and numbers.

JILLIAN HOSEY MSW RSW regularly reviews her information-handling practices. If you have any questions or comments in this regard, please use contact:

JILLIAN HOSEY MSW RSW
55 Eglinton Ave East, Suite 507
Toronto, Ontario
M4P 1G8
647-830-6340
jillhoseymsw@gmail.com