Personal Information Protection
Private Sector Privacy Legislation
Personal Information Protection Policy
Counselling Support Centre Online
Personal Information Protection Policy
At Counselling Support Centre Online, we are committed to providing our clients and students with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients and students, protecting their personal information is one of our highest priorities.
While we have always respected our clients and students, privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Alberta’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how AB businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients students and members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients and students’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients, students and members personal information and allowing our clients, students, and members to request access to, and correction of, their personal information.
Personal Information –means information about an identifiable individual [E.g., including name, age, home address and phone number, marital status, religion, income, credit history, medical information, education, employment information]. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Counselling Support Centre Online complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client, student and member voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client, student and member information that is necessary to fulfill the following purposes:
To verify identity;
To identify client, student and member preferences;
To open and manage an account;
To deliver requested services
To provide direct or indirect supervision (please see attached consents to audio/visual recording)
To provide counselling services;
To enrol the client in a therapy program;
To contact our clients, students and members for feedback on services provided
To ensure a high standard of service to our clients, students and members;
To meet regulatory requirements.
To assess suitability for tenancy;
To collect and process payments for counselling services;
Policy 2 – Consent
2.1 We will obtain client, student and member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided by electronic consent or written consent and can be revoked at any time. Or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, student and member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client, student, and member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client, student and member does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, students, and members can withhold or withdraw their consent for Counselling Support Centre Online to use their personal information in certain ways. A client’s, student’s and member’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client, student, and member in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, student’s, and member’s knowledge or consent in the following limited circumstances:
When the collection, use or disclosure of personal information is permitted or required by law.
In an emergency that threatens an individual's life, health, or personal security.
When the personal information is available from a public source (e.g., a telephone directory).
When we require legal advice from a lawyer.
To protect ourselves from fraud.
To protect student counsellors’ vulnerable status
To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using Personal Information
3.1 We will only use client, student and member personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as:
Fill in any related purposes for which your organization uses or discloses personal information. Examples that may be applicable to your organization, include:
To conduct client, customer, member surveys in order to enhance the provision of our services;
To contact our [clients, customers, members] directly about products and services that may be of interest
To book, change, cancel appointments.
3.2 We will not use or disclose client, students and member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, student and member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client, student and member personal information to make a decision that directly affects the client, student and member, we will retain that personal information for at least 5 years so that the client, student, and member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, student and member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client, student, and member personal information is accurate and complete where it may be used to make a decision about the client, student, and member or disclosed by consent to another organization.
5.2 Clients, Students, and Members may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’, students’, and members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client, student, and member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client, student, and member personal information is appropriately protected:
Locked filing cabinets for any physical copies
Online encrypted app sites that follow Information and Privacy bylaws and guidelines. For the Counselling Support Centre Online our service app provider is Jane©App and their privacy and security Policy can be found here: https://jane.app/legal/privacy-policy. We adhere to the same privacy guidelines as does our online provider.
All accounts of practitioners will be password protected and any digital files will be encrypted as well as password protected. This includes recordings made or housed by service partner apps, such as Zoom. See zoom’s recording policies here: https://explore.zoom.us/docs/ent/privacy-and-security.html
Student counsellors who record a session using offline device will use the recording for supervision and then delete the recording once supervision has been completed.
Students will provide a written consent to perform any recording or holding of data.
6.3 We will use appropriate security measures when destroying client’s, student’s and member’s personal information such as deleting digital files, and shredding any physical copies of client’s, students, and member’s personal information. For
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients, Students, and Members Access to Personal Information
7.1 Clients, Students, and Members have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell clients, students, and members how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client, student, and member of the cost and request further direction from the client, student, and member on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client, student, and member in writing, providing the reasons for refusal and the recourse available to the client, student, and member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Counselling Support Centre Online’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients, Students, and Members should direct any complaints, concerns or questions regarding Counselling Support Centre Online’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, student, and member may also write to the Information and Privacy Commissioner of Alberta.
Contact information for Counselling Support Centre Online’s Privacy Officer or designated individual:
Ryan James, M.Ed, CCC., RCC