Privacy Policy of Cobb Counselling Inc.

Privacy Policy

Privacy is in important principle in all operations of Cobb Counselling Inc.. Every effort is taken to safeguard the privacy of individuals in the collection, use, storage, and disclosure of personal information. This document describes the privacy policy of Cobb Counselling Inc..

What is Cobb Counselling Inc.

Cobb Counselling Inc. is a private practice owned by Dr. Nathan Cobb, who is a Registered Marriage and Family Therapist with a Ph.D. in Marriage and Family Therapy, and is also a Registered Psychologist.

Dr. Cobb uses a number of consultants and agencies that may, in the course of their duties, have limited access to the personal information held by Cobb Counselling Inc.. These consultants and agencies include bookkeepers and accountants, lawyers, computer consultants, credit card companies, financial institutions, marketing personnel and website managers. As much as reasonably possible, Dr. Cobb restricts their access to any personal information held in confidence by Cobb Counselling Inc.. He also has their assurance that they will follow appropriate privacy principles.

What is Personal Information?

Personal information refers to information about an identifiable individual. Personal information includes information that relates to an individual's personal characteristics (e.g., name, date of birth, home address and telephone number), health (e.g., presenting problem, health history, health services received by the individual, social situation) or activities, views and opinions (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.

Use of Personal Information

Our primary purpose in obtaining personal information is to provide psychological assessment, counselling and consulting services to individuals, couples, and families in a responsible and professional manner. For example, information may be collected about a client’s health history, family history, physical and psychological condition, and social situation to help assess what their needs are, advise them of their treatment options and help them to receive the treatment they choose.

It would be rare for Cobb Counselling Inc. to collect such information without the client's express consent, but this might occur in an emergency (e.g., the client is unconscious) or where it is believed the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from a client and there is no reason to believe that the message is not genuine).

A secondary purpose of obtaining personal information is to establish a baseline of health and social information. This allows identification of changes occuring over time as part of the provision of psychological services.

A third purpose is to advise the general public or previous and ongoing clients of special events, resources or services (e.g., seminars or the development of a new service) that are available through Cobb Counselling Inc. and to make such services or resources accessible to the public. Only that personal information necessary for this purpose is collected. (For example, a first name and email address would be the only required information for a newsletter subscription. No other personal information would be necessary to receive free newsletters.)

A related purpose is to advise the general public or previous and ongoing clients of resources that are independent of Cobb Counselling Inc.. Previous or ongoing clients have previously given consent to receive such information.

A fourth purpose for collecting personal information is to invoice clients for services that were not paid for at the time of the visit, to process credit card payments, or to collect on unpaid accounts.

A fifth purpose is to advise clients that their service should be reviewed (e.g., to ensure the service is still relevant to their needs).

If you choose at any time to provide personal information such as your name, contact information (i.e. email address or telephone number) or any other personal information via email, online form, paper-and-pencil format, or otherwise, be assured that this information will never be given out, sold to advertisers, or used for any purpose other than what you intend.

Method of Collecting Personal Information

Personal information is collected from clients or members of the general public by various means including verbal exchange (i.e. over the telephone or in face-to-face meetings), paper-and-pencil forms, voicemail, email, and online forms (i.e. order forms, contact forms, online questionnaires, etc.).

Cobb Counselling Inc. does not collect any private, personally identifiable information about you without your knowledge. This web site collects only the personal information you provide and only uses that information for the purpose you provided it (e.g., to respond to email, to register for a course, to subscribe to a newsletter, to provide feedback about progress, etc.). No personal information whatsoever is required or requested in order for you to access the information and services on this website. No one accessing this website will ever be required to subscribe to any newsletters or services.

Some online feedback forms provide clients of Cobb Counselling Inc. with the opportunity to give personal information about their perceptions of the counselling experience. These forms use anonymous ID numbers rather than the client's name for identification purposes. Use of these forms is voluntary and any information submitted is stored directly on the webhost's secure server. These forms are also available in paper-and-pencil format if a client prefers.

Individuals associated with Cobb Counselling Inc. will contact you only: a) in response to a question or suggestion initiated by you, b) in accordance with your prior consent to be contacted, (i.e. to complete feedback evaluations about the process of counselling, or to receive newsletters or promotions for upcoming events such as workshops, etc.), or c) as necessary to conduct the normal business affairs associated with the provision of services that you have initiated (i.e. scheduling matters, collecting on overdue accounts, reminders about upcoming appointments, follow-up to services being provided, etc.).

If, at any time in the future, any of the current privacy policies should change, you will be clearly and openly informed of any information being requested and the intrusiveness of any such information will be kept to a minimum.

Disclosure of Personal Information

Cobb Counselling Inc. will not reveal your personal information to any other person or agency without your written permission, with some exceptions to this policy which are outlined below. Before exchanging any information with a third party, you will be consulted first about what information is to be exchanged.

There are certain situations which may require Cobb Counselling Inc. to disclose your personal information in accordance with ethical and legal requirements and standard business practices.

First, when the cost of goods or services provided by Cobb Counselling Inc. to clients is paid for by third parties (e.g., WSIB, private insurance, EAP Companies), these third party payers often have your consent or legislative authority to direct Cobb Counselling Inc. to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.

Second, in cases where a person is subject to a foreseeable and imminent risk of bodily harm or death, a duty exists to protect the safety of such person(s). This means Cobb Counselling Inc. may need to disclose confidential information to appropriate authorities or individuals who can intervene on behalf of the person(s) at risk. The person(s) at risk may be a client of Cobb Counselling Inc. or may be someone associated with the client who is at imminent risk of bodily harm or death because of a client's actions.

Third, as it is required by law to notify the appropriate authorities about child or elder abuse/neglect.

Fourth, confidential client records can be subpoenaed by a court of law.

Fifth, there are exceptions that apply to personal information disclosed by minors. Parents or legal guardians of a minor have right of access to information about their dependent during provision of services. There are exceptions to this rule (i.e. such as in the case of mature minors or when all parties agree ahead of time to the confidentiality of information disclosed) that are to be discussed on a case-by-case basis, as applicable.

Finally, Dr. Cobb’s professional activities are regulated by the College of Alberta Psychologists who may inspect records and interview staff as part of their regulatory activities in the public interest. External regulators have their own strict privacy obligations. Sometimes these reports may include personal information about clients, or other individuals to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review files and interview staff as a part of their mandates. In these circumstances, Dr. Cobb may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to Cobb Counselling Inc..

Protection of Personal Information

Paper information is either under supervision or secured in a locked or restricted area.

Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. Encryption keys are used on wireless access terminals.

Paper information is transmitted in sealed, addressed envelopes or boxes by reputable companies (e.g., Canada Post).

Where possible, electronic information is transmitted either through a direct line or is anonymized or encrypted. Email is not utilized to transmit personal information unless it can be encrypted, unless it is requested by a client who has given consent to its use, or unless it is sent in response to a direct question or concern emailed to Cobb Counselling Inc.. In the latter case, great care is still taken to transmit only personal information that is necessary to the request and to consider more secure means of communicating highly sensitive information.

Electronic information is stored on secure computer hardware and is password protected.

Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this privacy policy.

Retention of Personal Information

Cobb Counselling Inc. retains personal information for some time to ensure that any questions you might have about the services provided can be addressed and to ensure that Cobb Counselling Inc. remains accountable to external regulatory bodies.

Cobb Counselling Inc. is required to keep client files for ten years following the client's last contact or if the client was less than eighteen years of age at the time of the last contact, for ten years following the day the client would have become eighteen.

Any personal information relating to general correspondence (i.e., with people who are not clients), such as newsletters, seminars and marketing activities are kept for about six months after the newsletter ceases publication, or after an individual terminates their subscription to a newsletter (i.e. seminar participants are given the opportunity to voluntarily join a mailing list for newsletters) or after a seminar or marketing activity is over. However, an individual’s contact information will be destroyed immediately if asked.

Paper files containing personal information are destroyed by shredding. Electronic files containing personal information are destroyed by deleting them. When the hardware is discarded, the hard drive is physically destroyed.

Access and Correction

It is the policy of Cobb Counselling Inc. that clients have a legal and moral right to know what information is contained about them in their record. Clients shall have access to information which can be identified as pertaining to them (and only them) and which is stored in the client record, with the exception of information that is believed to be harmful or that is confidential about or from third parties. Cobb Counselling Inc. will need to confirm your identity and legal right to have access to the information. In some cases, this may include requiring identification and or proof that a legal designate has legal authority to make decisions on behalf of the client. Cobb Counselling Inc. reserves the right to charge a nominal fee for such requests.

Clients may be asked to put their request for access to information in writing. If it is not possible to give clients access to their record, they will be notified within 30 days if at all possible, and provided with the reason, as much as possible, as to why they cannot be given access.

If you believe there is a mistake in the information about you that Cobb Counselling Inc. has on file, you have the right to ask for this information to be corrected. This applies to factual information and not to any professional opinions that your therapist may have formed. You may be asked to provide documentation that our files are wrong. If changed, a statement of changed information is included in the record and anyone to whom we sent this information will be notified of the change. If the request for a change is declined, you may file a notice of disagreement in the record.

If You Need More Information

For more information about our privacy policies and procedures, please contact Dr. Nathan Cobb at:

200C Haddon Road SW
Calgary, AB T2V 2Y6
Telephone: 403-255-8577
Fax: 403-255-8570

If you wish to make a formal complaint about our privacy practices, you may make it in writing to Dr. Nathan Cobb. He will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

If you have a concern about the professionalism or competence of our services we would ask that you discuss your concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to the regulatory body, the College of Alberta Psychologists.

This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out in this privacy policy.

This policy will go into effect on September 1, 2006. Cobb Counselling Inc. reserves the right to change the terms of this privacy policy and to make new policy provisions effective for all personal information maintained by Cobb Counselling Inc..

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 ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

112 Kent Street
Ottawa, Ontario
K1A 1H3
Telephone: 1-800-282-1376
Fax: 613-947-6850
www.privcom.gc.ca



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