PIPA defines Personal Information as “information that can identify an individual,” and “information about an identifiable person.”

 

I collect such information only as needed and as is relevant to the provision of counselling services as requested by you. This personal information may be used to provide counselling services, information, or resources, or otherwise communicate with you during your time in therapy.

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This policy will outline examples of collected information & the rationale for collection.

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Initial Session

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Prior to your initial session, I will provide you a link to set up a profile in the Jane App, where your address, date of birth, and other information relevant to counselling & payment is requested and inputted by you.

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This is to ensure that:

• Clients seeking counselling are a resident of BC, where my British Columbia Association of Clinical Counsellors (BCACC) registration is valid.

• Clients are contactable for phone sessions if requested, or outside of the session if needed, such as during emergencies.

• Clients can receive communication from the Jane App booking software, such as receipts and appointment reminders. Clients can update their communication preferences in their profile in the Jane App.

• Credit card information is on file to pay for sessions. Clients who would prefer to not have their credit card on file are welcome to contact me & I can remove this requirement from their profile.

 

During Counselling

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You have the right to decide how much you would like to share about your personal situation, past or present. The purpose of sharing this information includes providing counselling & collaborating with you on your hopeful outcomes/treatment plan.

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I write brief notes after each session summarizing our conversation. The purpose of these notes is to keep track of notable themes or topics. Notes are kept brief to respect your privacy, and are stored in the Jane App.  Further information about the protection of this information can be found below.

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Newsletter & Social Media

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Clients who wish to optionally receive the Ciara Harte Counselling email newsletter would manually enter their email address via my website to allow the newsletter to be delivered to their inbox, and is done at their own discretion. Email addresses are never sold or shared, and individuals can unsubscribe at anytime.

 

I use Wix to create & deliver the newsletter—you can read more about their security information here.

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Please note that I do not accept “Friend Requests” or “Follow” clients (current or former) on any form of social media. Clients are welcome to follow my counselling-related Instagram account at their own discretion. If clients message me on my counselling-related Instagram account, I am not able to respond. This is to respect your privacy as well as my own.

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Email

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You have the option of communicating with me via email. I use Google Workspace, which utilizes encryption as part of their security/privacy strategy. You can read more about their encryption information here.

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That being said, there is no guarantee in complete security when transmitting personal information over the internet. For the protection of your privacy, please do not email information you would not be comfortable discussing in a public space.

Additionally, please be aware that email communication pertaining to information beyond scheduling must be added to your client file.

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If emails are the preferred means of communication, clients are accepting the risks associated with transmitting information in this way.

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The Counselling Office

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While my office is private, it is located on a business floor with other independent offices, and has a shared waiting room. Upon entering and leaving the building, clients may or may not see others in the elevator or waiting room. I have a minimum of 10 minutes scheduled in between sessions to reduce the likelihood of clients crossing paths in the building.

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I keep all confidential paperwork in a locked filing cabinet in my locked office until such time as I am able to upload the paperwork to your profile on Jane App (e.g. consent forms, reports shared or provided by you). Once uploaded, paper copies will be shredded.  

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Please note I also have a home office for phone and video sessions. This is a single-use room with a door that is closed during sessions, where our private conversations cannot be overheard by others.

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Disclosure of Personal Information

Confidentiality

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Client confidentiality is of utmost importance to me—this includes your identity, attendance in counselling, and all personal information communicated by you in correspondence and in session.

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Confidentiality between therapist and client will only be broken if:

● I have reason to believe that a child under 19 years of age or a vulnerable adult has been, or is likely to be, at risk of abuse, neglect, or is otherwise in need of protection.

● I have reason to believe that a client shows intent to seriously harm themselves or others

● The counselling record is subpoenaed by the court

 

Excluding the above conditions, all information exchanged during session will remain confidential to protect client privacy.

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When working with adults or mature minors, I cannot respond to requests from concerned family members or friends about clients’ attendance or the content of counselling sessions. In Canada, a client under the age of 19 who is mature enough to and does fully understand the nature of therapy (including benefits and risks) can legally provide their own consent to therapy. The child in that instance can give consent without a parent or guardian’s knowledge or approval.

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Please note that additional information may be required at times to provide clients with best informed care. This may include information from physicians, schools, or other mental health professionals you may have worked with. Client written consent is required prior to the receipt or release of any information, and consent can be revoked in writing at any time.

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From time to time, I consult with my colleagues and supervisors on individual cases in order to provide the best care to you; however, identifying information is never shared without your expressed written consent.

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If you access funding through First Nations Health Authority, Crime Victims Assistance Program, or the Autism Funding Unit, I can submit directly to these programs for payment. This requires submitting your name as well as the dates of our counselling sessions & associated fees. No other information is disclosed without written consent from you.

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If we meet in public, it is your choice to acknowledge me. If you do, I will return the hello. The risk of saying hello to me is that even though I will not introduce you to the people I am with, they may conclude you are/were a client of mine.

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Protection of Personal Information

 

Your privacy is important to me—I take great care to protect your information.

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I securely store client information using the online practice management system “Jane App,” a North Vancouver-based company which has secure servers in Eastern Canada. Jane data is stored on secure SOC 2-audited servers using 256 bit encryption. You can read more about their security here.

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I also use the Jane App for online video appointments. Jane uses industry-standard privacy and security measures, and you can review Jane’s telehealth information here. 

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Computer Use

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I use my computer to conduct video sessions, correspond via email, receive payments & issue receipts, write session notes, publish my newsletter, update my website, and perform other administrative tasks related to running my private practice. My computer is password-protected, stored in a secure location, and I use private Wi-Fi connections when working.

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All “apps” and websites that I use to run my practice (e.g. Jane App, Google Workplace, Wix) are password-protected and two-factor authenticated.

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Phone

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I use my smart phone to access voicemail, return phone calls, conduct phone sessions, access my email and Jane App, and respond to text messages. My phone is password protected via fingerprint ID and passcode.

 

Voicemail

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I am rarely able to answer my phone directly, so most calls will go to voicemail. While all efforts are taken to protect your privacy, I ask that clients use their discretion about what information is shared in this medium.

 

Text Messages

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Like email, text messaging is not considered a private means of communication. Please be aware that text communication pertaining to information beyond scheduling must be added to your client file.

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If texting is the preferred means of communication, clients are accepting the risks associated with transmitting information in this way.

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Accessing and Correcting your Personal Information

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Clients have a right to view or receive a copy of their file, or portions of the file, if this information is still available. Upon receiving a written request for this information, I have 30 days to respond to your request (unless I am out of the office or recently returned after an extended period away).

 

As per PIPA, any information either given by third parties, or about third parties that is contained in the file, is required to be blacked out, to preserve the third party’s privacy. Requests that take longer than 15 minutes to organize are billed according to the payment agreement (signed prior to the beginning of counselling).

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If you have undertaken family counselling, and one or more parties wants copies of the file, the written and signed consent of all parties is required in order to release the information.

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If I believe that the release of your file would result in harm to either you or another party, I have the right under PIPA to refuse the release a copy of the file.

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If, in the course of your review, you have discovered factual information that you have deemed to be inaccurate, I will put a correction on the electronic file. I cannot make corrections to clinical assessment/impressions unless this assessment has changed in the light of the corrections.

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Disposing of Your Personal Information

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Any paper files not stored in the Jane App are subject to shredding after a 7-year period. Should any technology require disposal (for example, an old and inefficient computer) that contains personal information, such technology is only disposed of once the hard drive is destroyed.

 

 Privacy Policy Changes 

 

The information above is subject to periodic revision and changes. The current version will always be posted at this page on ciarahartecounselling.com.  If you have any questions about this policy, please contact me directly through phone or email.

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