Accountability

 

Kylie Smith, Registered Psychotherapist (RP), is the Health Information Custodian and is responsible for personal health information (PHI) collected through this practice.

 

All policies, procedures, and safeguards are designed to ensure compliance with PHIPA and professional regulatory standards.

 

Privacy Contact:

Name: Kylie Smith

Email: kylie@ttyltherapy.ca

Phone: 905-745-5711

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 Identifying the Purpose of Collection

 

Personal health information is collected for the following purposes:

 

• To provide psychotherapy assessment, treatment, and care;

• To develop and maintain clinical records;

• To communicate with you regarding appointments, services, and service-related notices;

• To process payments and insurance documentation (if applicable);

• To create aggregated statistical date and other aggregated and/or inferred non-personal information, which we may use to provide and improve our respective services;

• To comply with legal and professional obligations.

 

You will be informed of the reason for collecting your information before or at the time of collection, and consent is obtained as part of your intake process.

 

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Consent

 

Your knowledge and consent are required for the collection, use, and disclosure of your personal health information, except where permitted or required by law.

 

Age of consent

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TTYL Psychotherapy offers services for adults age 18+ and does not knowingly collect personal information from children under the age of 13 in compliance with the Personal Health Information Protection Act (PHIPA, 2004). Additionally, the website is also not intended for anyone under the age of 18. If information from a child under 13 is discovered without parental consent, it will be deleted immediately, and concerns can be reported to kylie@ttyltherapy.ca

 

Consent may be:

 

• Expressed (written or verbal), or

• Implied (for routine care within the therapeutic relationship)

 

You may withdraw or limit consent at any time, subject to legal or contractual restrictions. This may affect the ability to provide services.

 

Consent is never obtained through deception or misrepresentation.

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Limiting Collection

 

Only information that is necessary and relevant to providing psychotherapy services is collected. This information may include:

 

• Contact information

• Login information

• Health history and mental health concerns

• Treatment notes and assessments

• Billing and payment information

• Communication and Correspondence (i.e. emails, text messages, etc.)

• Comments, reviews, feedback

 

You are not required to provide information beyond what is necessary to receive services.

 

When you interact with our website as part of the process and aim to contact us or book an appointment, we collect personal information you give use such as your name, address, phone number, and email address. Your personal information will be used for the specific reasons stated above only. In addition, we collect the internet Protocol (IP) address used to connect your computer to the Internet; login; email address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. 

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Limiting Use, Disclosure, and Retention

 

Your information is used only for the purposes identified above and TTYL Psychotherapy does not sell or rent your personal information. Information may be shared with trusted affiliates, service providers, legal representatives, or business successors when necessary to provide services, enforce agreements, complete business transitions, or comply with legal obligations and protect legal rights.

 

Information is not disclosed without your consent except when required or permitted by law, including:

 

• Risk of serious harm to you or others

• Suspected abuse or neglect of a child

• Court order or subpoena

• Regulatory or legal reporting requirements

 

Consultation & Supervision

 

Your therapist reserves the right to consult with professional supervisors and/or peer consultants for clinical support. Identifying details are minimized wherever possible. Clinical supervision is a contractual relationship in which a clinical supervisor engages with a supervisee to discuss the direction of therapy and the therapeutic relationship; promote the professional growth of the supervisee; enhance the supervisee’s safe and effective use of self in the therapeutic relationship; and safeguard the well-being of the client while maintaining confidentiality of the client.

 

Retention

 

Client records are retained for:

 

• 10 years after the last session, or

• 10 years after a minor client turns 18,

 

in accordance with regulatory standards.

 

After this period, records are securely destroyed (see Section 7).

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Accuracy

 

Efforts are made to ensure your information is accurate, complete, and up to date. You may request corrections to factual errors in your record.

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Safeguards

 

Personal health information is protected through administrative, physical, and technological safeguards appropriate to its sensitivity.

 

These include:

 

• Password-protected electronic systems

• Encrypted platforms (where applicable)

• Secure record storage

• Limited access to files

• Secure destruction of records (shredding or secure digital deletion)

 

When records are no longer required, they are destroyed in a way that prevents reconstruction or retrieval.

 

The TTYL Psychotherapy website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.

 

While some website data is transmitted securely (e.g., via SSL), email is not considered a secure method of communication and should be used at your own risk. The website also uses software tools to monitor site performance, security, and traffic patterns.

 

Our website uses cookies for important reasons, such as: 

• To provide a great experience for visitors

• To identify registered members (users who registered to our site)

• To monitor and analyze the performance, operation, and effectiveness of Wix’s platform

• To ensure our platform is secure and safe to use

 

Cookies are small pieces of data stored on a site visitor's browser. They are typically used to keep track of the settings users have selected and actions they have taken on a site.

 

Advertising and Social Media Policy

 

TTYL Psychotherapy uses social media to share general educational content and promote services, but interactions on these platforms do not create a therapeutic relationship and are not a substitute for therapy. These accounts are not monitored for clinical communication, and individuals should not share personal health information or seek support via comments or DMs—clients should contact TTYL directly via phone or email, and anyone in crisis should seek emergency care. Following these accounts may also impact personal privacy, as others may see public follower lists. Given the importance of confidentiality within the therapeutic relationship, it is my intention to not accept friend contact requests from clients (past or present) on social media or to follow clients on social media. If you post on any of my social media pages, people may make assumptions about our connection (I will not reveal how I know you).

 

For your information, your therapist is not allowed to solicit or post testimonials from clients, former clients, or other persons regarding a therapist’s practice, nor is your therapist able to respond to testimonials provided from clients, former clients, or other persons to protect confidentiality. For more information, please read expectations about advertising outlined in CRPO Professional Practice Standard 6.2, Advertising.

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Openness

 

This Privacy Policy is available upon request and posted on the practice website. Clients may ask questions about privacy practices at any time.

 

Policy Changes

TTYL Psychotherapy may update this privacy policy and will post changes on this page. Significant updates may also be communicated directly to active clients and/or by email or website notice. Users are responsible for keeping contact information current and reviewing the policy periodically.

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Individual Access

 

You have the right to:

 

• Request access to your record

• Request copies of your information

• Request correction of inaccurate or incomplete information

 

Requests must be made in writing. Access may be limited only in situations permitted by PHIPA (e.g., risk of harm).

 

 

Challenging Compliance

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If you have concerns about how your information has been handled, you may contact:

 

• Kylie Smith

  • kylie@ttyltherapy.ca

  • (905)745-5711

 

Concerns will be reviewed and responded to promptly. If unresolved, you may contact:

 

• Information and Privacy Commissioner of Ontario (IPC)​

 

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Questions about Privacy?

Any questions about client privacy, should be directed to Kylie Smith, the TTYL Psychotherapy Privacy Officer.