This statement describes our policies and procedures on collection, use, retention, and disclosure of your personal health information. It also informs you about your access to records of your personal health information.
What is Personal Health Information?
The practice of psychology in BC is regulated under provincial Freedom of Information and Protection of Privacy Act (FOIPPA) and Personal Information Protection Act (PIPA; 2003). As such, all identifiable information collected by a psychologist about an individual in the course of practicing psychology is considered “personal health information” under the relevant Act. This includes your name and contact information, and pertinent information collected and/or recorded in the course of providing services to/about you.
Collecting Your Personal Health Information
Your personal health information is typically collected directly from you, except: (a) when you have provided consent to obtain such information from others; (b) when the law requires or allows us to collect information without your consent (e.g., urgent situations, when information is needed to prevent potential harm); and/or (c) in third party consultation services where the referring third party sends us records in their possession about you, or direct other parties to provide records to us.
We collect only information from you we believe is needed to: (a) render psychological services requested of us; (b) maintain contact with you for service-related purposes; and (c) prevent harm (e.g., emergency contact). Information collected from and/or about you for any other purpose (e.g., research, program evaluation) will first require your informed consent. You are at liberty to decline consent if you do not wish to provide this latter type of information. Such refusal would have no impact on your psychological services.
By law and in accordance with our professional requirements, we must keep a record of our professional services involving you. Such records include information you provide to us or authorize us to procure, results of any assessments, consent forms, session notes, billing information, contact logs, and correspondence pertaining to you. You have rights regarding access to your record and disclosure of information from your record (see below), regardless of the form in which the information is recorded. At this office, such information is recorded in hard copy and/or electronic form.
Use of Your Personal Health Information
The primary use of your personal health information at this office is to render psychological services to, or about, you. This includes carrying out all of the functions reasonably necessary to provide such professional services (e.g., clinical and/or related professional service planning and monitoring, record maintenance, billing).
Hard copy paper and/or electronic information are secured in a locked or restricted area at all times, electronic records are password protected. Paper information is transmitted through sealed, addressed envelopes. Electronic information is transmitted through non-encrypted emails with your consent. Faxing is used to transmit or receive confidential client information only when necessary.
The College of Health and Care Professionals of BC (CHCPBC), which regulates the practice of psychologists in BC in the public interest, may access and inspect client records as part of their work.
Note: We use collection agencies for retrieval of unsettled accounts. We provide the barest personal information to permit such recovery of fees owed by the person or agency owing the delinquent fees. Ask us about the kind of information we provide to collection agencies for delinquent fee retrieval. Fees not paid in full within 30 days of the invoice date attract interest charges.
Disclosure of Your Personal Health Information
With a few exceptions, your personal health information will not be disclosed to persons outside this practice without your knowledge and expressed consent. Exceptions include: (a) as required/permitted by law (e.g., imminent risk of serious bodily harm to a person; professional or legal consultation, mandatory reporting of a minor or vulnerable adult in need of protection; mandatory reporting of a regulated health professional alleged to have committed misconduct; (b) a lawful court order; and (c) release of records to the third party which requested your participation in psychological services with us. These exceptions are known as “limits of confidentiality.” If there are other limits of confidentiality specific to you or your situation, we will discuss them with you before proceeding with your service, or as they come up.
Note: the law requires any disclosure of your personal health information is limited to information reasonably necessary for the purpose of the disclosure. Professional ethical standards also require that any information that might cause significant harm to someone not be disclosed, unless required by law.
When consenting to the disclosure of your personal health information, you may restrict us from sharing all or any part of your information. However, if in our opinion the information is reasonably necessary for another health service provider to provide appropriate services, we may be required to inform the other provider(s) about your refusal to give us consent to provide some such information.
Right of Access to Your Personal Health Information
With some 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 levy an administrative fee for record processing). If the physical record contains personal health information about another individual, that individual’s information must be severed from the record before you may access the record. Other exceptions include access to raw data from psychological assessments, copyright-protected psychological test materials, information provided in confidence by a third party, and information that could result in serious harm to someone’s treatment or recovery, or serious bodily harm to someone.
If you believe that information in your record is not accurate, you have the right to request a correction. This applies to factual information and not to our professional opinion(s). Your request to correct the record must be written and we require at least 30 days to review your request. Where we agree there is a factual error, we will make the necessary correction in the form of an addendum, and notify recipients to whom we may have sent the information. If there is not an agreement to correct the record as requested, you may file a notice of disagreement into your record and we will forward that notice to all persons and organizations to whom we may have sent the information.
Retention and Destruction of Personal Health Information
We must retain personal health information for a limited period to ensure that we may respond to questions you might have about the services provided, and for our accountability to external regulatory bodies. The CHCPBC requires that client records be kept for at least seven years past the date of last contact for adults, and seven years after the age of majority in the case of minors. We expunge paper records containing personal information through shredding, and electronic information through deletion, and physical destruction of the hardware containing such electronic information.
Do you have a Question or Concern?
These privacy policies and procedures have been developed in accordance with the laws, and relevant professional regulations and ethical standards for psychologists in British Columbia. Further details of the applicable laws, regulations, and ethical standards may be found at the websites of the relevant BC agency (www.bclaws.gov.bc.ca), and the CHCPBC (www.chcpbc.org).
We are available to respond to your questions about this Privacy Statement.
If you have concerns about our professional services at NeuroBehavioral Specialists, please contact us to discuss and resolve those concerns. If you remain unsatisfied, you may contact the provincial psychology regulatory body:
The College of Health and Care Professionals of BC
402 – 3795 Carey Road,
Victoria BC V8Z 6T8