Privacy Policy and Public Privacy Statement

1. Privacy responsibility

For clinical records created or received through Tender Threads clinic systems, Tender Threads Counselling & Psychotherapy is the health information custodian. Treating clinicians and authorized personnel handle personal health information as agents of Tender Threads only to the extent required for their assigned duties. Each clinician remains professionally accountable for the care they provide and the adequacy of their clinical documentation.

Our Privacy Officer is:

Anasztázia Mátrai
Privacy Officer
Tender Threads Counselling & Psychotherapy
Ontario, Canada
Email: info@tenderthreadstherapy.ca
Telephone: (289) 672-2445

Privacy questions, access requests, correction requests, and complaints may be sent to the Privacy Officer. Please write “Privacy Request” in the subject line and do not include detailed clinical information in ordinary email.

2. Information we collect

Depending on how you interact with us, we may collect:

1. Contact and identifying information, including your name, pronouns, date of birth, email address, telephone number, address, province or territory, and emergency contact information.
2. Inquiry and matching information, including who is seeking services, general areas of concern, therapist preferences, preferred appointment format, and availability.
3. Clinical information, including health history, treatment goals, assessments, consent records, treatment plans, progress notes, communications, referrals, and information relevant to safe care.
4. Appointment and financial information, including appointment history, fees, payment status, receipts, and insurance related information that you ask us to include or disclose.
5. Website and technical information, including Internet Protocol address, browser or device type, pages visited, date and time of access, and security or server logs.
6. Communications sent through email, telephone, website forms, Jane, or another approved channel.

We limit collection to information reasonably necessary for the identified purpose.

3. How we collect information

We may collect information directly from you, from a parent, guardian, or authorized substitute decision maker, from a referring professional with appropriate authority, from your treating clinician, or automatically through limited website technologies and server logs.

A referral source does not automatically receive information about whether you became a client or about your care. Information is returned to a referral source only with your consent or where permitted or required by law.

4. Why we use information

We may use information to:

1. Respond to inquiries and help identify an appropriate clinician.
2. Determine service eligibility, jurisdiction, clinical fit, and virtual care safety.
3. Schedule consultations and appointments.
4. Provide psychotherapy and maintain clinical records.
5. Process payments and prepare receipts.
6. Communicate about appointments, care, and clinic administration.
7. Support clinical supervision, quality assurance, and continuity of care.
8. Operate, secure, and improve clinic systems and the website.
9. Meet legal, regulatory, insurance, accounting, and professional obligations.
10. Respond to emergencies or circumstances in which disclosure is permitted or required by law.

Tender Threads does not sell or rent personal information.

5. Consent

We seek meaningful consent for the collection, use, and disclosure of personal information unless the law permits or requires otherwise. Express consent is obtained for virtual psychotherapy and for disclosures that require express consent.

You may withdraw or limit consent, subject to legal, professional, or contractual restrictions and reasonable notice. Withdrawing consent may affect our ability to provide a service. Withdrawal does not require the destruction of records that must lawfully be retained.

For minors and people who may require a substitute decision maker, capacity and authority to consent are assessed according to applicable law and the circumstances. Confidentiality and its limits are explained before care begins.

6. Who may receive information

Information may be accessed or disclosed only as reasonably necessary to:

1. Your treating clinician and authorized clinic personnel performing assigned duties.
2. A clinical supervisor in accordance with your consent, applicable law, and professional standards. Identifying information is limited when reasonably possible.
3. Service providers supporting scheduling, secure forms, clinical records, virtual sessions, website hosting, email, payments, backups, or technical security.
4. A person or organization you authorize, including another health professional, insurer, lawyer, school, or family member.
5. A regulator, court, law enforcement body, child protection authority, or another person where disclosure is permitted or required by law.
6. Emergency services or another appropriate person where disclosure is legally permitted to address a serious safety risk.

Access is limited according to role and purpose. People handling information for the clinic are expected to comply with applicable confidentiality and privacy requirements.

7. Jane and other service providers

Tender Threads uses Jane for functions that may include scheduling, forms, secure client communication, clinical records, virtual appointments, payments, and receipts.

We may also use website hosting, email, payment, security, and other technology providers. Some providers may process information outside Ontario or outside Canada. Information processed in another jurisdiction may be subject to lawful access under the laws of that jurisdiction. Tender Threads remains responsible for selecting appropriate providers and applying safeguards required by applicable law.

Information entered directly into a provider’s interface may also be subject to that provider’s user facing privacy terms. This does not remove the responsibilities of Tender Threads or the applicable health information custodian.

8. Website forms, email, and social media

General website forms and ordinary email are not appropriate for detailed clinical information or urgent messages. Please provide only the information needed for us to contact you. We may ask you to continue a sensitive conversation through Jane or another approved secure method.

Clinic email, website forms, and social media accounts are not continuously monitored. We do not provide psychotherapy through public comments or social media direct messages. Information shared directly with a social media platform is also governed by that platform’s privacy practices.

9. Cookies and website analytics

Our website may use essential technologies and limited server logs to operate, maintain, and secure the website. We do not use inquiry content or clinical records for behavioural advertising.

If optional analytics or advertising cookies are introduced, we will update this Policy and provide any notice and choice required by applicable law before activating them. We do not intentionally use website activity to create mental health advertising profiles.

10. Safeguards

We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information. These include limiting access according to assigned roles, using approved clinic systems, maintaining confidentiality requirements, and taking reasonable steps to prevent unauthorized access, use, disclosure, copying, modification, loss, or disposal.

No electronic system or method of transmission can be guaranteed completely secure. Clients should use a private location, secured device, and trusted network when accessing virtual services.

11. Retention and secure disposal

Clinical, appointment, and financial records are retained for at least 10 years from the last interaction with the client or for 10 years from the client’s eighteenth birthday, whichever is later. Records may be retained longer where another applicable law, professional requirement, complaint, investigation, or legal hold requires it.

Website inquiries and other administrative information are kept only as long as reasonably necessary for their purpose and applicable legal obligations. When information is no longer required, it is securely deleted, destroyed, or deidentified.

12. Access and correction

You may submit a written request to access or correct personal information in the custody or control of Tender Threads. We may verify your identity and authority before responding.

For requests governed by Ontario privacy law, we respond as soon as reasonably possible and generally within 30 calendar days. A permitted extension of up to 30 additional days may apply, with written notice. Different timelines may apply under another applicable privacy law.

Access or correction may be limited in circumstances permitted by law. Where permitted, a reasonable cost recovery fee may apply. An estimate will be provided before a fee is charged.

13. Privacy incidents

If personal information is lost, stolen, or accessed, used, or disclosed without authorization, we will investigate, take reasonable containment and corrective measures, and notify affected individuals, regulators, or other parties where required by law.

14. Privacy complaints

Please contact the Privacy Officer first so the concern can be reviewed and addressed.

A person may also make a complaint to the privacy authority with jurisdiction over their information. For Ontario personal health information, contact:

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Telephone: 416 326 3333 or 1 800 387 0073
Website: ipc.on.ca

For matters governed by federal privacy law, complaint information is available from the Office of the Privacy Commissioner of Canada at priv.gc.ca.

A concern about a Registered Psychotherapist’s professional conduct may also be directed to the clinician’s regulatory college.

15. Policy changes

We may update this Policy when clinic practices, technologies, or legal requirements change. The current version and effective date will be posted on this page. Material changes will be communicated when required by law.