Privacy Policy

Effective: August 17, 2025

Flourishing Mind Counselling respects and is committed to protecting the privacy and confidentiality of your personal health information (PHI) in accordance with the Personal Health Information Protection Act (PHIPA) of Ontario.

1. What Information We Collect

We collect personal health information such as your name, contact details, health history, presenting concerns, session notes, and other information shared during the course of therapy.

2. Why We Collect Your Information

Your information is collected to:

• Provide counselling and psychotherapy services
• Maintain accurate treatment records
• Contact you regarding appointments or care
• Process payments (if applicable)
• Comply with legal and regulatory obligations

3. How We Store and Protect Your Information

Your information is stored using secure electronic systems with access restricted to authorized personnel. We take reasonable steps to ensure your data is:

• Encrypted in transit and at rest
• Accessed only on a need-to-know basis
• Regularly backed up and monitored

4. Use of Electronic Service Providers (ESPs)

We use trusted electronic service providers (ESPs) such as Google Workspace and Google Cloud Platform to securely manage information like encrypted emails, scheduling, video calls, and document storage. These providers act only on our behalf and do not access or use your information for their own purposes.

5. Storage Outside of Canada

Some personal health information may be stored or processed on servers located outside of Canada (e.g., in the United States). While these providers are contractually bound to maintain confidentiality and security, your information may be subject to the laws of the foreign jurisdiction.

6. Your Rights

Under PHIPA, you have the right to:

• Access your personal health information
• Request corrections to your record
• Withdraw consent (subject to legal and clinical limits)
• Ask how your information has been shared

7. Health Information Custodianship, Contingency Planning, and Contact for Privacy Inquiries

At Flourishing Mind Counselling, each therapist operates as an independent Health Information Custodian (HIC) under Ontario's Personal Health Information Protection Act (PHIPA). This means your personal health information is collected, used, and stored solely by your therapist, who is fully responsible for its protection and privacy.

While Flourishing Mind Counselling provides shared administrative and booking systems, access to your personal health information is restricted to your therapist unless you provide written consent or it is required by law. The practice may have access to limited non-clinical information (such as appointment dates and payment records) for administrative purposes, but not to your clinical notes or therapy records.

Each therapist has a contingency and succession plan in place. In the event a therapist is unable to continue providing services due to illness, death, loss of license, or other unforeseen circumstances, a designated qualified successor HIC will assume custodianship of your records. This ensures your records are securely maintained, transferred, or destroyed in accordance with PHIPA and applicable regulatory requirements.

If you have questions or concerns about how your personal health information is handled, please contact your therapist directly. They are responsible for maintaining your privacy and can address any requests regarding your information.