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Privacy Policy

Ms. Cook is committed to protecting your privacy and ensuring the confidentiality of your personal health information. Please read this Privacy Policy carefully. It explains how Ms. Cook collects, uses, handles, discloses, and safeguards your information in compliance with privacy legislation, including the OntarioPersonal Health Information Protection Act (“PHIPA”) andCanada’s Anti-Spam Legislation (“CASL”).

Website

Information about Ms. Cook’s services are available on the website https://donnacook.com (the “Website”), which is hosted by WordPress. WordPresscollects non-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. You can learn more about WordPress’s privacy policy here:https://wordpress.org/about/privacy/.

The Website may include links to other websites. Ms. Cook is not responsible for the content or privacy practices of other websites, social media platforms, or apps that may be linked.

Contacting Ms. Cook

If you choose to contact Ms. Cook by phone, email, or by selection “Log In” (which will link you to https://aws-portal.owlpractice.ca/donnamariecook/booking , please see part F below for further information regarding Owl Practice), your personal information will be kept confidential, even if you do not become a client of Ms. Cook’s. “Personal information” or “PI” includes any factual or subjective information, recorded or not, about an identifiably individual. Ms. Cook will only use this information to respond to a request for further information about Ms. Cook’s services. Ms. Cook will not disclose your personal information for other reasons without your express consent, unless permitted or required by law to do so. If you have questions about how Ms. Cook manages your personal information, including what information is in her custody and control and how you can access it, please contact her by email at [email protected].

Website visitors email should keep in mind that there are security risks associated with electronic communications, and refrain from sharing sensitive personal information through this function. Ms. Cook will respond using more secure means of communication to respond to your request for contact and to provide information about her services.

Social Media

“Social Media” is the term commonly given to websites and online tools which allow users to interact with each other in some way – by sharing information, opinions, knowledge and interests. There are many prominent examples of Social Media platforms, including Facebook, Twitter, YouTube, LinkedIn, and blogging sites, among many others.Ms. Cook uses social media platforms for informational purposes only. Ms. Cook’s social media posts are not clinical advice and is not intended to/does not create a therapist-client relationship. Ms. Cook’s posts are general in nature and do not apply to or represent any individual. If you interact on our social media platforms (commenting, liking, sharing, etc.),your confidentiality may be compromised.

To maintain professional boundaries, Ms. Cook will not follow or interact with clients on social media. To protect your privacy, Ms. Cook does not communicate with individuals through her professional social media accounts. Please DO NOT sent personal or personal health information to Ms. Cook via social media. If you have a question or concern about something that Ms. Cook has posted, please contact her at[email protected] or through Owl Practice.

Personal Health Information

“Personal health information” or “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 you when used alone or with other information. Once you become Ms. Cook’s client, any information that identifies you as our client will also be considered PHI. Where the term “information” is used, it refers to both PI and PHI.

Ms. Cook is the health information custodian of your PHI, including records related to your sessions with her. Please contact Ms. Cook if you have any questions about your records.

Collection and Use of PHI

The types of PHI that Ms. Cook may collect may include your name, date of birth, address, phone number, OHIP number, health history, and records of the care provided to you. Ms. Cook may collect, use, and disclose PHI for the following purposes:

  • to provide you with psychotherapy services
  • to create account on the Owl Practice platform (which is discussed below) for secure email and teletherapy services
  • to obtain payment for services provided (i.e., from you, WSIB, your private insurer, or others)
  • to conduct quality improvement and risk management activities
  • to comply with her regulatory obligations to the College of Social Workers and Social Service Workers of Ontario (the “College”)
  • for other purposes permitted by law

Ms. Cook will collect, use, and disclose only as much PHI as is needed to achieve these purposes.Ms. Cook will not collect personal health information if other information in her custody will serve the purpose of the collection. Ms. Cook will not collect more information than is reasonably necessary to meet the purpose of the collection (i.e. providing psychotherapy services).

Your Choices

If you have provided consent to our collection, use or disclosure of PHI, you can withdraw your consent at any time by telling Ms. Cook using the contact information set out below. If you withdraw your consent on a go-forward basis, Ms. Cook may not be able to provide services to you if she cannot meet professional obligations related to record keeping.

Electronic Medical Record and Teletherapy

If you request services from Ms. Cook, you will be asked to establish an individual user account (“Account”) through a third-party software provider named “Owl Practice”. This can be accessed by selecting the ”Log In” tab on the top right-hand corner of the Website, which will redirect you to the Owl Practice sign-in page (https://aws-portal.owlpractice.ca/donnamariecook/booking).

Owl Practice is a secure, web-based practice management system used to store and manage client records. This includes information such as client appointments, billing documents, session notes, contact details, and other client-related information and documents. The Owl Practice system is encrypted, has servers exclusively owned and operated privately, and access to the system is granted only on an as-needed basis and governed by their strict confidentiality policy. Additionally, all data in their system is routinely backed up to ensure the privacy and protection of sensitive client information and to assist us with PHIPA compliance.

By making an Account, you agree that you will not create more than one Account or create an Account for anyone other than yourself. You also acknowledge and agree that you will:

  1. provide true, accurate, current and complete information as required when enrolling for an Account; and
  2. each time you log on, maintain and promptly update such Account Information to keep it true, accurate, current and complete.

If you intentionally provide any information that is untrue, inaccurate, not current or incomplete, or if Ms. Cook has reasonable grounds to suspect that such you have intentionally provided information is untrue, inaccurate, not current or incomplete, Ms. Cook reserves the right to transition your treatment to another health care provider outside of Ms. Cook and refuse any future request(s) for services.

You are responsible for maintaining the confidentiality of your Account password and username (if any) and any other security information related to your Account. Ms. Cook will not be liable for any loss that you incur as a result of anyone accessing and using your Account either with or without your knowledge.

If you do not agree with the Owl Practice Terms, the Owl Practice Privacy Policy, or this Privacy Policy, you should not sign up for an Account. If you have concerns about using Owl Practice, please let us know. Please be aware that Ms. Cook may not be able to provide services without using Owl Practice.

Your PHI will be stored in your medical record on the Owl Practice and may be accessed by those providing you with services or for administrative reasons.

Contents of Client Record

The laws and standards that govern Ms. Cook’s services require that she keep a client record.

All client records must include:

  1. Identifying information regarding the recipient of services (individual, family, couple, group, agency, organization, community); Depending on the nature of the services provided, identifying information may include:
    1. name, address, telephone number of each client(s);
    2. date of birth of each client(s);
    3. where available, name, address, and telephone number of a person(s) to be contacted in case of emergency;
    4. name, address, telephone number(s) of the main contact person or position, if different from; and
    5. sponsors, funders, accountability.
  2. The date, initiator, purpose of the social work or social service work referral, where relevant, and, if significant, the setting of the first professional encounter with the client;
  3. Where applicable, the key elements of the contract or working agreement, namely: client, contracted services, provider of services, fee, reimbursement schedule, and time period for completion of services;
  4. The time period of involvement if not specified in (c);
  5. The date of completion/termination, where relevant, and if significantly different from (c), an explanation for the difference;
  6. Particulars of the social work or social service work process, as applicable:
    1. the history obtained by the registrant;
    2. assessment, diagnosis, formulation and plan;
    3. treatment and other interventions, e.g. facilitation, advocacy, transfer of skills, development of action plans;
    4. outcome or results and evaluation;
    5. referrals made by the registrant;
    6. recommendations; and
    7. other services, e.g. verbal and/or written reports/briefs/analyses, research studies and/or their individual components, presentations/speeches/lectures, management related services, stakeholder consultations and professional opinions
  7. Consents, releases or authorizations pertaining to the intervention or the communication of information about the client;
  8. Fees and charges administered, if any.

Disclosure of PI or PHI to Third-Parties

Your privacy is protected by professional standards and applicable privacy legislation. Ms. Cook will not sell or disclose your information to third parties without your consent, except as described below or as required or permitted by applicable law.

Exceptions to Confidentiality and Privilege

Ms. Cook may be required or permitted by law to disclose information if she:

  1. Suspects that a child is at risk of abuse or neglect.
  2. Suspects that a person who lives in a retirement home or long-term care facility is at risk of abuse or neglect.
  3. Suspects that a client has been sexually abused by their health care provider.
  4. Suspects that a client could be a danger to themselves or to another person.
  5. When the law or the courts requires Ms. Cook to disclose it (such as with a court order).
  6. If the College is investigating Ms. Cook’s practice.
  7. If Ms. Cook’s records are audited by the Canada Revenue Agency.
  8. If payments are made by a third-party provider (e.g., extended health care benefit provider, WSIB, MVA, VAC), the third-party provider may need information about you to pay for Ms. Cook’s services. They may also need to see your records to show that you had the treatment that they paid for. This information may include: the type(s), cost(s), date(s), and providers of any services received and/or attendant diagnoses, if applicable.

Access and Correction

Ms. Cook has an obligation to maintain client records that are as accurate and complete as possible.You have the right to seek access to your records and to ask Ms. Cook to correct a record if you believe it is inaccurate or incomplete. Usually, a correction is made by adding information to the file and not by deleting or destroying the information. Ms. Cook cannot correct records made by other professionals.

Because these are professional records, they can be misinterpreted and/or upsetting to untrained readers. Ms. Cook recommends that you review them together or let her summarize them so that the contents are not misunderstood. You are entitled to receive a copy of your records unless Ms. Cook believes that seeing them would be emotionally damaging, in which case she will discuss them with you or send them to another mental health professional of your choosing.

Confidentiality and Consent for Clients Under 16

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 are able to consent to on your own. If you are capable of making a decision, your choice supersedes that of your parent or guardian. If you are 16 years of age or older, Ms. Cook will not share any information about you without your permission unless one of the other exceptions listed above apply.

It is Ms. Cook’s policy to request an agreement from your parent(s) or legal guardian that they agree to avoid unnecessary review of records and involvement in your treatment before she provides any services. If they agree, Ms. Cook will only provide them with general information about your work together, unless she believes there is a significant risk that you will seriously harm yourself or someone else. In this case, Ms. Cook may need to disclose information to reduce this risk of harm, but she will disclose the minimum information needed to do so.

If your parent or legal guardian requests information about you, Ms. Cook’s policy is to discuss the request with you and try to arrive at an agreement about what information is provided to them. Ms. Cook may also provide a written summary answering their question instead of providing direct access to your records.

Family Law Issues

Parents with joint custody have equal authority as substitute decision makers for their child, but a parent with only a right of access/parenting time only has authority if the parent with custody/decision making authority is not available. The hierarchy of substitute decision makers is provided in theHealth Care Consent Act.

It is Ms. Cook’s policy that for children and youth under the age of 16, where parents are no longer married or cohabiting and have joint custody of the child, she will obtain the consent of both parents prior to the child receiving services (unless the client is capable of providing consent for themselves).

Safeguards

Ms. Cook implements administrative, technical, and physical measures that are reasonable in the circumstances to safeguard the information in her custody and control against theft, loss, disposal and unauthorized access, use, copying, modification, and disclosure.

Temporary paper records are transcribed or scanned into your Owl Practice client record after your appointment, which is stored in secure data centres in Canada and protected by encryption, user account and password controls, restricted access by service providers and logging, auditing, and monitoring of all access to electronic records of PHI. Once your PHI is digitized, Ms. Cook will securely destroy the paper record through shredding and secure disposal.

Retention

Ms. Cook retains your information only for as long as necessary to carry out the purposes discussed in this Privacy Policy or to meet any legal, medico-legal, or business requirements. PHI that forms part of your medical record will be retained for 15 years, or for 15 years following your 18th birthday.

Ms. Cook may also create and retain de-identified or anonymized personal information for internal use to improve the provision of services and business operations.Disposal

Ms. Cook will take reasonable steps to ensure secure and permanent destruction of PHI records following the retention period and following digitizing of paper records. If a third-party is retained to dispose of this information, Ms. Cook 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. Ms. Cook keeps a record of all PHI that has been destroyed, including the date, how the information was disposed of, and to whom the information relates. Digital information will be disposed of through permanent deletion.

Privacy Breach Management

Privacy breaches may occur when a person contravenes a rule under PIPEDA or PHIPA; when information is collected, used, or disclosed without authorization; and/or where information is lost, stolen, or accessed by someone without authorization. Examples of privacy breaches include, but are not limited to:

  • Collection of information without legal authority (i.e., without consent or where not required for the purpose for which the information was provided) or by unauthorized means (i.e., use of cell phone, video camera, or other unauthorized recording equipment or data storage device to collect PHI);
  • Unauthorized use of information (i.e., where someone with access to files accesses PHI of a family member or other patient without a “need to know”);
  • Disclosure of information through loss or theft (i.e., theft of computer or equipment or data storage device, cyber-attack) or error (i.e., misdirected fax or email, interception of unencrypted electronic data);
  • Unauthorized or unsecured disposal of information (i.e., disposing of PHI in garbage or recycling, intentionally or unintentionally);
  • A courier package is not delivered to the correct address;
  • A report is filed in the wrong client’s record; and/or
  • Someone talks about a patient with someone who is not involved in the patient’s care and treatment, without the express consent of the patient or their substitute decision maker.

If Ms. Cook learns that a client’s information has been stolen, lost or subject to unauthorized use, access, disclosure, copying or modification, she will immediately take steps to manage the breach, including notifying anyone else who should be involved in addressing the breach (such as Owl Practice staff or legal counsel).

Ms. Cook’s first priority will be to identify and contain the breach, and then to take steps to correct it and to minimize chances of similar breaches in the future. Ms. Cook will notify any client whose information may have been stolen, lost, or accessed in an unauthorized manner, at the first reasonable opportunity. Ms. Cook will also advise clients of their right to contact the Information and Privacy Commissioner of Ontario (“IPC”). Ms. Cook will then investigate the breach and take any reasonable steps to resolve it. Finally, Ms. Cook will consider whether a report to the IPC is required.

Updates to the Privacy Policy

Ms. Cookmay update this Privacy Policy periodically to reflect changes to the law and her privacy practices. If Ms. Cook makes material changes to her privacy practices, she will let you know.

Questions or Concerns?

If you have questions or want to make a complaint about Ms. Cook privacy practices, please contact: [email protected].

You also have the right to complain to the IPC at the address below if you have concerns about Ms. Cook’s privacy practices or how your PI or PHI has been handled:

  • Information and Privacy Commissioner/Ontario
  • 2 Bloor Street East, Suite 1400, Toronto, Ontario M4W 1A8
  • Telephone: Toronto Area: (416) 326-3333; Long Distance: 1 (800) 387-0073 (within Ontario)
  • TDD/TTY: (416) 325-7539
  • Fax: (416) 325-9195
  • www.ipc.on.ca

Implemented on April 11, 2025. Last reviewed by Ms. Cook on April 11, 2025.

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