Privacy Policy

Effective date: January 22, 2026
Organization: Breakthrough Counselling & Psychotherapy Services
Contact (Privacy Officer): Almarine Thomas, RP, almarine@breakthoughcps.com, 

1151 North Rover Rd, Ottawa, ON, K1K3W5 

1) Who we are & which laws apply

We are a private psychotherapy practice in Ontario. We are a health information custodian (HIC) under Ontario’s Personal Health Information Protection Act, 2004 (PHIPA). PHIPA establishes the guidelines for collecting, using, disclosing, retaining, and protecting personal health information (PHI), as well as the rights you have over your PHI. PHI includes any information in oral or recorded form (including written, audio or video) about an individual’s physical, cognitive, and/or emotional health, health care history, or health care treatment that could identify an individual when used alone or with other information. Once you become our client, any information that identifies you as our client will also be considered PHI.

We may also handle personal information (PI) that is not PHI (e.g., payment details, website usage data). For those activities, Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) applies.

As a regulated practice, we also follow the College of Registered Psychotherapists of Ontario (CRPO) Professional Practice Standards for confidentiality, consent, record-keeping, electronic practice, fees, and advertising. 

2) What information we collect

We collect only the PHI/PI that we need to provide safe, ethical care and run our practice. This information may include:

• PHI for clinical care: contact details; consent forms; health/mental-health history; presenting concerns; risk/safety information; session notes; treatment plans; referrals; reports; communication related to clinical care; and other health information that you share with us or that we collect from third parties with your consent. 
• Administrative/financial: appointment history, invoices, receipts, payment method (e.g., last 4 digits, transaction ID), insurance information (if you request direct billing). 
• Website & communications: messages you submit via forms; email or text correspondence that is administrative in nature; technical data such as IP address, device/browser, and cookies/analytics (see “Cookies & analytics”). 

3) Why we collect information (purposes)

We may collect PHI/PI for the following purposes:

• Provide/coordinate care (assessment, treatment, consultation, referrals). 
• Administer our practice (scheduling, billing, accounting, quality assurance). 

• Fulfill legal/professional obligations (record-keeping, regulatory standards, responding to authorized requests). 
• Communications you request (confirmations, reminders, information about your care). 

We limit our collection to what is necessary for these purposes and do not use your PHI for marketing purposes. 

4) Your consent choices (express & implied)

Under PHIPA, we generally need your consent to collect, use, and disclose PHI. Consent may be implied within your circle of care to provide/coordinate health services, or express (written/verbal) in specific situations (for example, disclosures outside the circle of care, to insurers/employers, for fundraising/marketing, or as otherwise required by law). You may withhold or withdraw consent subject to legal limits, and we’ll explain any implications of this choice for your care. 

For non-PHI activities that are commercial in nature (e.g., payment processing, website forms), we follow PIPEDA’s consent requirements and principles. 

If you are under 16 years of age, your parent(s) or legal guardian may give or refuse consent to disclose information on your behalf, unless the information relates to treatment that you have decided to participate in on your own.  If you are 16 years of age or older, we will not share any information about you without your permission unless one of the other exceptions listed below apply.

5) When we may disclose information

We will not disclose your PHI without your consent unless permitted or required by law, for example:

• Imminent risk of serious harm to you or others;
• Child protection or abuse/neglect reporting;
• Court orders/subpoenas or other legal requirements;
• Regulatory/quality assurance matters; or
• Public health reporting as required.

We disclose only what’s necessary and inform you where the law allows. 

6) Virtual care, electronic communications & your choices

We offer in-person, video, phone, and secure messaging. Electronic communication can carry privacy risks. We employ reasonable administrative, physical, and technical safeguards (e.g., encrypted platforms, strong access controls), and we obtain informed consent for electronic health care practices. You may choose in-person or alternative options at any time. 

Email & SMS: We avoid sending PHI via unencrypted email/text unless you request it and understand the risks, or there is no practical alternative. 

Social Media: We use social media platforms for informational purposes only. Content on these platforms is not clinical advice and is not intended to/does not create a therapist-client relationship. If you interact on our social media platforms (commenting, liking, sharing, etc.), your confidentiality as a client may be compromised. To maintain professional boundaries, we do not follow or interact with clients on social media platforms. Please only contact us via email or phone. 

7) Our service providers (agents) & cross-border data

We use trusted “agents” to help deliver our services:

• Jane practice management software, electronic record, telehealth platform, payment processor, etc. 
• Psychotherapy Matters Virtual Collaboration (PMVC) for psychiatric consultation (when applicable). 
• Klarify AI Scribe to assist with documenting services (a specific consent form will be provided).

We ensure appropriate privacy and security contracts and limit access to staff/agents who need it. Some providers may process data outside Ontario/Canada; when they do, we assess safeguards and will disclose locations on request. You can ask us about our current vendors and data flows at any time. 

8) How we protect your information (safeguards)

We maintain layered safeguards appropriate to a psychotherapy practice, including:

• Policies, training, confidentiality agreements for staff/agents;
• Access controls (role-based access, strong authentication), audit logs for electronic records;
• Encryption in transit and at rest where feasible;
• Secure storage and minimum retention consistent with CRPO standards and PHIPA;
• Vendor due diligence and contractual protections; and
• Breach response procedures, including required notification to you and, where applicable, to Ontario’s Information and Privacy Commissioner (IPC). 

9) Record retention & location

Clinical, appointment, and financial records are retained and stored in accordance with PHIPA and CRPO record-keeping standards. We are the HIC for our records. We keep records in Ontario/Canada, whenever feasible and will tell you if your records are stored elsewhere. 

10) Disposal

When PHI is disposed of, we will take reasonable steps to ensure secure and permanent destruction of these records. Where a third party is retained to dispose of this information, we will enter into a written agreement with the third party that sets out the requirements for secure disposal and require the third party to confirm in writing that secure disposal has occurred. We keep a record of all PHI that has been destroyed, including the date and how the information was disposed of, and to whom the information relates.

11) Your rights

Under PHIPA, you have the right to:

• Be informed about why and how we handle your PHI;
• Access your health record (with limited exceptions) and receive a copy;
• Request corrections to inaccurate/incomplete information;
• Instruct us not to use/disclose your PHI for health care purposes (a “lockbox,” subject to legal limits);
• Withdraw consent (subject to legal/contractual restrictions and reasonable notice);
• Be notified of theft, loss, or unauthorized use or disclosure of your PHI; and
• Complain to the IPC if you believe your rights were not respected.

To exercise any of these rights, contact our Privacy Officer (see end of policy).

Under PIPEDA (for PI), you also have rights to access, correction, and to challenge our compliance with the 10 Principles. 

12) Cookies, analytics & website forms

Our website may use essential cookies to operate and optional analytics to understand site usage. We seek consent for non-essential cookies where appropriate and provide a way to update your preferences. Data collected via website forms is used only to respond to your inquiry, schedule, or provide requested information.

Our website is hosted by Bluehost. Please see their privacy policy for more information about their information practices: https://www.newfold.com/privacy-center 

13) Psychiatric consultation (PMVC) & collaborative care

If you are eligible for and choose psychiatric consultation through PMVC, we will share only the PHI reasonably necessary for assessment and care, with your consent, and we will document disclosures in your record. 

14) Fees for access & copies

PHIPA allows reasonable fees to access or copy records. We will tell you any fees in advance and provide a breakdown upon request. 

15) How to ask questions or make a complaint

• To our Privacy Officer: 

Almarine Thomas

almarine@breakthroughcps.com

• To the IPC (Ontario): 

Information and Privacy Commissioner of Ontario, 

2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8

1-800-387-0073 

ipc.on.ca

• To the Office of the Privacy Commissioner of Canada (PIPEDA matters): 

Office of the Privacy Commissioner of Canada

30 Victoria Street, Gatineau, Quebec, K1A 1H3 

819-994-5444

priv.gc.ca

We will respond promptly and aim to resolve concerns. 

16) Changes to this policy

We may update this policy to reflect legal or practice changes. The effective date at the top shows when it last changed. Significant changes will be posted on our website and, where appropriate, communicated directly.

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