External Privacy Policy

At Reconnect from Grief, we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Reconnect from Grief collects from or about you, how we use and to whom we disclose that information.

Reconnect from Grief has adopted a series of Privacy Policies in order to address the specific privacy concerns of certain groupings of individuals. This Privacy Policy applies to the personal information of all individuals with special additional protections afforded to individuals who have entered a counseling contract with Reconnect from Grief and are receiving counseling services from Anne DeButte.

Privacy Policy Effective for Canada

It is the policy of Reconnect from Grief to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

What is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.

What is Personal Health Information?

Personal health information includes oral or written information about an individual, if the information:

  • relates to the individual’s physical or mental health, including family health history;
  • relates to the provision of health care, including the identification of persons providing care;
  • is a plan of service for individuals requiring long-term care;
  • relates to payment or eligibility for health care;
  • is the individual’s health number; or
  • identifies an individual’s substitute decision-maker.

Any other information about an individual that is included in a record containing personal health information is also included in the definition.

It does not include information about an individual if the information could not reasonably be used to identify the individual although such information might still be confidential and protected under our counseling services contract.

How do we use your Personal Health Information?

Reconnect from Grief adheres strictly to the current legislation governing personal privacy for health information in Ontario (Personal Health Information Protection Act).

The information that we collect is used to:

  • Ensure we can contact you
  • Provide counselling services to you
  • Maintain accountability as a service provider
  • Ensure safety, legal and ethical standards are met
  • Assess the quality of services provided and the effectiveness of outcomes

All clinical files and data are the sole property of Reconnect from Grief and are stored in a secure location or on a secure server. Any questions or concerns can be addressed directly to the Privacy Officer, who is the Owner, Anne DeButte.
Confidentiality Policy

All notes, records and communications created by Reconnect from Grief during your involvement as a client are kept secure and confidential and can be shared only with your written consent and as agreed to in our counselling services contract with you. Reconnect from Grief keeps a record of all appointments/counseling sessions, whether by phone or in person or by exchange of email messages. Information may be shared within Reconnect from Grief for case management and quality assurance purposes. Any information about a client is kept within the organization in strictest confidence.

There are a few exceptions to confidentiality when the law requires that our records be disclosed under strict conditions. In the following situations the law requires that reports be made and/or information released:

  • Suspected child abuse
  • Any life threatening danger to a client or to a third party (threat of suicide, threat towards others)
  • Court orders and subpoenas

When Do We Disclose Your Personal Information other than Personal Health Information?

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist Reconnect from Grief in the provision of services to you; and third parties whose services we use to conduct our business. For example, personal information contained on a personal cheque used to pay us for our services will be processed through our bank.

Your Consent Is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be express, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will advise you of that purpose before such use or disclosure and obtain your consent to do so.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may withdraw your consent at any time, but the withdrawal cannot be retroactive. The withdrawal may also be subject to legal or contractual restrictions and reasonable notice.

All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing. Generally, your information is kept at our corporate offices in Ottawa, Ontario (see address information below).

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance.

If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or have any concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by email. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website here and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on September 23, 2014.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Reconnect from Grief any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.