Privacy Policy
Transformation Counselling
Effective Date: 2016-01-01
Last Updated: 2026-10-25
Introduction
Transformation Counselling (operated by 1000513282 ONTARIO INC. and 1000940839 Ontario Inc.) ("we", "us", "our") provides counselling, psychotherapy, psychological and nurse practitioner services in Ontario. We take your privacy and the confidentiality of your health information seriously.
We are a health information custodian under Ontario's Personal Health Information Protection Act, 2004 (PHIPA). This policy is our written public statement of our information practices. It explains what personal health information we collect, why we collect it, how we use and share it, how we protect it, and the choices and rights you have.
This policy applies to all of our locations:
Waterloo: 22 King St S, Units 103 and 404, Waterloo, ON N2J 1N8
Kitchener: 72 Victoria St S, 3rd Floor, Kitchener, ON N2G 4Y9
Cambridge: 188 Main St, Cambridge, ON
Cambridge: 73 Water St N, Cambridge, ON
Ottawa: 1 Rideau St, 7th Floor, Ottawa, ON K1N 8S7
Online (virtual) services
It also covers personal information we collect through our website, online booking, email and text message communications.
1. Our Privacy Officer
We have named a Privacy Officer who is responsible for our compliance with PHIPA and for answering your questions and concerns about privacy.
Privacy Officer: Tyler Ford
Email: admin@transformationcounselling.com
Phone: (519) 954-4900
Mail: 22 King St S, Unit 404, Waterloo, ON N2J 1N8
2. Information We Collect
We collect only the information we need to provide you with care and to run our practice. This may include:
Identifying and contact information: name, preferred name, date of birth, address, phone number, email address, and emergency contact.
Health information: your reasons for seeking care, intake and assessment information, session notes, treatment plans, assessment results, and other information about your health and care.
Billing and payment information: fees, invoices, payments, receipts, insurance or benefits provider details, and payment method details. Card numbers are handled by our payment processors and are not stored by us in full.
Communication preferences: whether you have opted in to email or text message reminders and updates.
Website information: basic technical information collected when you visit our website or book online, such as browser type, pages visited and booking details.
3. How We Collect Information
We collect information directly from you whenever possible, including through our intake and consent forms, online booking, sessions with your clinician, and when you contact us. With your consent, or where permitted by law, we may also collect information from others, such as a referring doctor, another health care provider, a parent or guardian, a substitute decision-maker, or your insurer.
4. How We Use Your Information
We use your personal health information to:
provide, plan and coordinate your care;
book, confirm and remind you of appointments;
bill for services and process payments, including direct billing to your insurer or benefits provider when you ask us to;
communicate with you about your care, your account and our services;
manage, evaluate and improve our services, including quality improvement and training of our clinicians;
meet our legal, regulatory and professional obligations, including record-keeping standards set by our clinicians' regulatory colleges;
de-identify information, as described in Section 7; and
for other purposes permitted or required by law.
5. Consent
When you receive care from us, we rely on your implied consent to collect, use and share your information with others who are directly involved in your care, unless you tell us otherwise. For most other purposes, we ask for your express consent.
You may withdraw or limit your consent at any time by contacting our Privacy Officer, subject to legal limits. For example, you can ask us not to share certain information with other providers. This is sometimes called a "lockbox". If withdrawing consent affects our ability to provide care, this may not be possible and we will explain this to you.
PHIPA allows us to use and disclose information without your consent in certain limited situations, such as when required by law, to reduce a significant risk of serious harm to you or others, or to de-identify information (see Section 7).
6. When We Share Your Information
We do not sell or rent your identifiable personal health information. We share identifiable information only as follows:
With your consent, for example with your family doctor, another provider, or your insurer or benefits provider for direct billing or claim verifications. In the event that you dispute a payment, we may need to disclose your file(s), emails, signed agreements, personal records or other information to comply with payment dispute requests. For example, if you dispute a credit card payment that you have made with us, our payment processor and your bank may require that we provide proof that the transaction is not fraudulent including such information.
With our service providers (agents), who act on our behalf and only under our instructions. These include our practice management and electronic records systems (such as Jane App and OwlPractice), video session platforms, payment processors, email and text message providers, and IT and accounting providers. They must protect your information and may use it only to provide services to us.
When required or permitted by law, for example to comply with a court order or subpoena, to report suspected child abuse or neglect, to reduce a significant risk of serious bodily harm, or to respond to our regulatory colleges.
Some of our service providers may store or process information outside Ontario or Canada, including in the United States. When this happens, your information is protected by contract, but it may be subject to the laws of that jurisdiction.
7. De-identified Information
PHIPA permits us to use personal health information, without your consent, for the purpose of modifying it to conceal your identity ("de-identifying" it). We want to be clear and open about how we do this and what happens to de-identified information afterward.
How we use de-identified information. Transformation Counselling and/or agents acting on its behalf may use personal information and personal health information, including health records, to generate de-identified and/or aggregated information that does not contain any information that, either alone or with other information, could identify an individual. We may use de-identified and/or aggregated information for research purposes, analytics, measuring business performance, measuring clinician performance, internal training purposes, for activities to improve the quality of care for you and others, and to evaluate and improve our services.
Sale or licensing of de-identified information. We may enter into agreements to sell or license de-identified and/or aggregated data sets to third parties, such as data science, research and analytics companies. These organizations may use the information for purposes such as:
generating insights into treating and preventing illness, including mental health conditions;
analyzing the costs, benefits and financial management of health care (health economics);
evaluating the safety and effectiveness of treatments, drugs and devices in patients (post-marketing surveillance);
evaluating and improving health services, care delivery and client outcomes;
statistical analysis and population health research; and
developing, training, testing and improving software, analytics, workflows and other technology tools.
How we de-identify. Before any information is provided to a third party, it is de-identified by us or by an agent acting on our behalf and under our instructions. This includes removing direct identifiers (such as names, contact details, dates of birth, and client, insurance and payment card numbers), generalizing details that could single someone out, and assessing the risk of re-identification so that information is only released where that risk is very low.
How it is protected afterward. Our agreements with these organizations:
prohibit any attempt to re-identify individuals or to link the information with other data to identify anyone;
require these obligations to bind their employees, contractors, sub-processors and anyone they share or license the information to;
require appropriate security safeguards, restricted access and confidentiality; and
require them to notify us of any breach or of any identifiable information received in error.
8. How We Protect Your Information
We use administrative, technical and physical safeguards to protect your information against theft, loss and unauthorized access, use, copying, change or disclosure. These include:
confidentiality agreements and privacy training for all staff, clinicians and contractors;
access limited to people who need the information to do their jobs;
secure, password-protected and encrypted systems;
locked storage for any paper records, which are also digitized and store in our secure systems; and
secure destruction of records when they are no longer needed.
If your personal health information is stolen, lost, or used or disclosed without authority, we will notify you as soon as reasonably possible and, where required, report it to the Information and Privacy Commissioner of Ontario.
9. How Long We Keep Your Information
We keep your records for a minimum of as long as required by law and by the required standards of our clinicians' regulatory colleges. In general, this is at least 10 years after your last visit or, for clients who were under 18, at least 10 years after their 18th birthday, whichever is later. We will keep your records on file after any required minimum amount of time, to ensure you can have secure access to copy of any health records in the future. De-Identified data may be stored and used by us, permanently, for business purposes, compliance, training, accounting, as required by third-party agreements and payors (i.e. benefits payors, banks), and any other business purpose.
10. Your Right to Access and Correct Your Information
You have the right to see and get a copy of your personal health information, with limited exceptions set out in PHIPA. To make a request, contact our Privacy Officer. We will respond within 30 days, or tell you if we need more time as PHIPA allows. We may charge a reasonable fee permitted by law.
If you believe your information is inaccurate or incomplete, you may ask us to correct it. If we do not agree to make the correction, you may attach a statement of disagreement to your record.
11. Questions and Complaints
If you have a question or concern about how we handle your information, please contact our Privacy Officer first. We will do our best to resolve it.
You also have the right to make a complaint to the Information and Privacy Commissioner of Ontario:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8
Phone: 1-800-387-0073
Website: www.ipc.on.ca
12. Our Website and Online Booking
Our website is hosted by Squarespace and our online booking is provided through Jane App. These services may use cookies and similar technologies to make the site work, remember your preferences, and help us understand how the site is used. You can control cookies through your browser settings. Information you enter when booking online is handled according to this policy.
13. Email and Text Message (SMS) Communications
Purpose. If you opt in, we may send you appointment reminders, scheduling and booking help, account and balance updates, customer service messages, and occasional updates about our services.
Consent. We only send text messages and emails after you opt in, for example on your consent form, during intake or when booking online. You can withdraw your consent at any time by replying STOP to any text message, using the unsubscribe link in any email, or contacting us. Opting out will not affect your care.
Message frequency. Typically one message per appointment reminder, billing or scheduling messages as needed, and up to 2 to 4 update or marketing messages per month.
Fees. Message and data rates may apply, depending on your mobile carrier and plan.
Keywords.
STOP: Opts you out. You will receive a reply confirming you will no longer receive messages, and that you can reply START to opt back in.
START: Opts you back in. You will receive a reply confirming your subscription, with STOP and HELP instructions. Message and data rates may apply.
HELP: You will receive a reply with our contact details. You can also call (519) 954-4900 or email admin@transformationcounselling.com.
Carriers. Mobile carriers are not liable for delayed or undelivered messages.
No sharing of mobile information. We do not share or sell your mobile phone number, text message opt-in data or consent with any third party for their marketing or promotional purposes. Text message opt-in data is never included in the de-identified information described in Section 7.
14. Changes to This Policy
We may update this policy from time to time. The current version will always be posted on our website with its effective date. If we make a significant change to how we use or share information, we will make reasonable efforts to let our clients know.
15. Contact Us
Transformation Counselling
22 King St S, Unit 404, Waterloo, ON N2J 1N8
Phone: (519) 954-4900
Email: admin@transformationcounselling.com
Website: transformationcounselling.com