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Privacy Policy

The protection of your private personal information (PI) is one of the priorities at this website of The Dr. Malak Psychology Group. Due to the nature of the business of The Dr. Malak Psychology Group, they are required to collect essential Personal Identifiable Information (PII) as dictated by law. Additionally, The Dr. Malak Psychology Group is committed to collecting, using and disclosing your PII responsibly, and only to the extent necessary for the goods and services The Dr. Malak Psychology Group provides to you. This document describes how The Dr. Malak Psychology Group’s privacy policies are in alignment with PHIPA, PIPEDA, the Digital Privacy Act, and Freedom of Information and Protection of Privacy (FIPP) in addition to The Dr. Malak Psychology Group’s own strict privacy policies & procedures.

 

PHIPA:    The Provincial; (Ontario) Personal Health Information Protection Act was established in Ontario in 2004. This legislation governs the collection, use and disclosure of personal health information, which is confidential data regarding a patient's mental and physical health.

 

FIPPA:    The Provincial; (Ontario) Freedom of Information and Protection of Privacy Act

purpose:

(a) to provide a right of access to information under the control of institutions in accordance with the principles that,

     (i) Information should be available to the public,

     (ii) necessary exemptions from the right of access should be limited and specific, and

     (iii) decisions on the disclosure of government information should be reviewed  independently of the government; and

(b) to protect the privacy of individuals with respect to personal information about themselves held by institutions and to provide individuals with a right of access to that information.  R.S.O. 1990, c. F.31, s. 1.

 

PIPEDA:   The Federal; (Canada) Personal Information Protection and Electronic Documents Act sets the ground rules for how private-sector organizations collect, use, and disclose personal information in the course of for-profit, commercial activities across Canada. PIPEDA generally applies to personal information held by private sector organizations that are not federally-regulated, and conduct business everywhere in Canada.

 

Digital Privacy Act:     The Federal; (Canada) The requirement for "valid consent" to the collection, use and disclosure of personal information. Every organization that collects, uses and discloses personal information in the course of commercial activity in Canada (with a few exceptions) must follow new mandatory data breach record-keeping, reporting and notification rules or face significant non-compliance consequences.

What Is Personal Information (PI)/ Personally Identifiable Information (PII)?

Personal information is information about an identifiable individual. PII includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).

 

What Is NOT Personal Information?

What is not considered to be Personal Information is business-related information (e.g., an individual's business address, business title, business email address and business telephone number), all of which are not protected by privacy legislation.

 

Your Personal Information:

The Dr. Malak Psychology Group is required to collect PII information in regards to yourself which will include; legal name, date of birth, and place of residence; basically all contact information in addition to an emergency contact with their contact information, in order to provide you with optimal service. There will be requirements to provide your age, health history, current health condition(s), assessment results or diagnoses from other health providers; health services provided to or received by you.

 

Currently The Dr. Malak Psychology Group, support personnel (accountants, legal representatives, IT techs) and administrative staff, etc; are all required to uphold The Dr. Malak Psychology Group’s strict policies and procedures in addition to the stringent protection and management of your confidential PII.

 

In the course of doing business, The Dr. Malak Psychology Group may use a number of consultants, agencies and resources that may, in the course of their duties, have access to your personal information. Including but not limited to; computer consultants & technicians; office security; legal service providers; etc. The Dr. Malak Psychology Group proactively restricts access to your PII and has engaged these resources and possibly others under strict contracts to ensure they follow appropriate privacy policies and procedures which are required by law to protect your PII.

 

Collection of Personal Information: Primary Purposes

About Patients/Clients (Patients)

Like all health service providers, The Dr. Malak Psychology Group may collect, use and disclose PII in order to serve you the patient.

  • The primary purpose; for collecting personal information, is to provide The Dr. Malak Psychology Group services and treatments. For example, The Dr. Malak Psychology Group may collect information on health history, including family history, physical condition, physical function and social situation in order to assess what your health needs are and to advise you of your options.

  • The secondary purpose; is to obtain a baseline of health and social information to facilitate the provision of ongoing optimum health services, and identify changes that are occurring over time. In the event, The Dr. Malak Psychology Group should need to collect such information without the patient's express consent, as might occur in an emergency (e.g., the patient is unconscious) or where The Dr. Malak Psychology Group reasonably believes the patient would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message to us, from you the patient and The Dr. Malak Psychology Group has no reason to believe that the message is not genuine due to the reasonable nature of it).

  • Psychologists are regulated by the College of Psychologists of Ontario;

  • Who may inspect your records as a part of their regulatory activities, and in the public interest.

    • As part of The Dr. Malak Psychology Group Duty of Care requirement(s);

      • The Dr. Malak Psychology Group is mandated to report serious misconduct, incompetence or incapacity of any practitioner.

  • Various government agencies (e.g., Canada Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review your files as a part of their mandates.

    • In these circumstances, The Dr. Malak Psychology Group may consult with professionals (e.g., legal representatives, or accountants) who investigate the matter on their behalf.

    • The cost of some goods/services provided by The Dr. Malak Psychology Group to patients is paid for by third parties (e.g., WSIB, or private insurance).

      • These third-party payers often have your consent or by the legislative authority to direct us to collect and disclose to them certain information in order to demonstrate patient entitlement to their funding.

  • The Dr. Malak Psychology Group also provides ongoing services for many patients over a period of months or years for which previous records are essential resources.

  •     The Dr. Malak Psychology Group will retain patient information for a minimum of ten years after the last contact/entry or ten years after the patient reaches or would have reached, the age of eighteen or as is mandated by the current laws or regulatory bodies.

  •     Patients or other individuals The Dr. Malak Psychology Group has dealt with may have questions about their goods or services after they have been received years later.

  • If The Dr. Malak Psychology Group's practice or its assets were to be sold, the purchaser would conduct a "due diligence" review of The Dr. Malak Psychology Group records to ensure that it is a viable business which has been honestly portrayed. This due diligence may involve some review of the accounting and service files. The purchaser would not be able to remove or record personal information. Additionally, before being provided access to the files, the purchaser must provide a written promise/agreement to keep all PII confidential. Only reputable purchasers who have already agreed to purchase the organization's business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

  •  

    Members of the General Public;

    The Dr. Malak Psychology Group’s primary purpose for collecting a limited amount of your personal information including your email address; is to provide notice of appointments or other services.

  • Upon your request, The Dr. Malak Psychology Group will remove any reasonable personal information from the contact list. The Dr. Malak Psychology Group does not use, share, sell, or in any way distribute your information in any manner other than its original intended use as was provided by you.

  •  

    Collected Personal Information: Related and Secondary Purposes

    The Dr. Malak Psychology Group will also collect, use and disclose information for purposes related to or secondary to the primary purposes and only in compliance with Government Regulations. The most common examples of the related and secondary purposes are as follows, and only upon your consent, would The Dr. Malak Psychology Group share essential information with third parties to provide you with their services under the following circumstances, to name but a few;

  • invoice patients for goods or services that were not paid for at the time they were provided, to process credit card payments or to collect unpaid accounts.

  • advise patients that their product or service should be reviewed (e.g., to ensure a product is still functioning properly and appropriate for their then current needs and to consider modifications or replacement).

  • advise patients and others of special events or opportunities (e.g., a seminar, development of a new service, the arrival of a new product).

  • additionally; external consultants (e.g., auditors, legal service providers, practice consultants, voluntary accreditation programs) may conduct audits and reviews for continuous quality improvements.

  • You can decline at any time, or discontinue the participation of some of these related or secondary purposes, (e.g., by declining to receive notice of special events or opportunities, and by paying for your services in advance).

  •  

    Protecting Your Personal Information

    The Dr. Malak Psychology Group understands the importance of protecting all private information. For that reason, The Dr. Malak Psychology Group has taken the following steps:

  • Paper information is either under constant supervision or secured in a locked or restricted area.

  • Digital information is secured by passwords & electronic hardware either constantly under supervision or secured in a locked or restricted area at all times. In addition; strong passwords are used on all computers.

  • When paper information is transferred, it is in sealed, envelopes or boxes, and by reputable bonded courier companies.

  • Electronic/Digital information is transmitted either through a direct line (fax), is anonymized and/or is encrypted.

  • The Dr. Malak Psychology Group is trained to collect, use and disclose personal information only as necessary to fulfill the duties, in accordance with this strict privacy policy and the guidelines of Government Regulations.

  • External consultants and agencies with access to your personal information must enter into privacy agreements with The Dr. Malak Psychology Group, or sign confidentiality agreements prior to any transfer of private information or access to any PII in the course of providing their services to The Dr. Malak Psychology Group.

  • Unauthorized or unnecessary access to any personal information is prohibited.

  •  

    Retention and Destruction of Personal Information

    The Dr. Malak Psychology Group is required to retain personal information for various time frames in accordance with Government Regulations. Additionally, to ensure that The Dr. Malak Psychology Group can answer questions you might have about the services provided and for their own accountability to external regulatory bodies.

     

    The Dr. Malak Psychology Group will retain patient information for a minimum of ten years after the last contact/entry or ten years after the patient reaches, or would have reached, the age of eighteen. Otherwise, if you ask, The Dr. Malak Psychology Group will remove "reasonable" contact information right away. The Dr. Malak Psychology Group will keep any personal information relating to general correspondence (e.g., with people who are not patients) newsletters, seminars and marketing activities for approximately six months after the newsletter ceases publication or a marketing activity is over. Paper files containing personal information are destroyed by shredding. The Dr. Malak Psychology Group destroys electronic information by deleting it and, prior to the hardware being discarded; the memory device or hard drive is physically destroyed.

    You Can Look At Your Information

    Under the Privacy Act; you have the right to see what personal information The Dr. Malak Psychology Group has in the files regarding you, within reason, and the provisions of the governing bodies, or law. Often all you have to do is contact The Dr. Malak Psychology Group Information Officer. Who will need to confirm your identity before providing you with this access? 

     

    The Dr. Malak Psychology Group reserves the right to charge a nominal fee for each of these requests. Please put your request in writing. If The Dr. Malak Psychology Group cannot give you access, they will inform you by letter or email within 30 days and provide you with the reason why they cannot give you access.

     

    If you believe there is an error in The Dr. Malak Psychology Group information regarding you; you have the right to request it to be corrected. This request can only apply to factual information, not financial information and not to any professional opinions. You will be required to provide documentation to support your request for the correction of the files. In the event The Dr. Malak Psychology Group does agree that there was an error in the file on you, they will make the correction and notify those to whom they have been authorized by you to send this information originally. If The Dr. Malak Psychology Group does not agree that there was an error, they will still agree to include a brief statement from you on the point in the file and they will forward a copy of that statement to those who received the earlier information.

     

    Cookies Notice

    Your Privacy

    When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device, and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because I respect your right to privacy, you can choose not to allow cookies. However, blocking some types of cookies may impact your experience of the site and the website services I am able to offer.

    Strictly Necessary Cookies / Always Active

    These cookies are necessary for the website to function and cannot be switched off in the systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

    Performance & Analytics Cookies / Not in Use

    The Dr. Malak Psychology Group does not implement this type of cookie.

    Personalization Cookies / Active: Personalization Cookies

    These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services I have added to the pages. If you do not allow these cookies, then some or all of these services may not function properly.

    Targeting Cookies / Active: Targeting Cookies

    These cookies may be set through the site by third-party partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

    Do You Have a Request or a Question?

    Questions about the Privacy Policy should be sent to us via the contact form below, or to;

     

    Information Officer: Dr. Malak Abu Shakra

    The Dr. Malak Psychology Group

    Executive Director & Clinical Psychologist

    567 Roehampton Ave, Suite #29

    Toronto, ON M4P 1S5

     

    The Dr. Malak Psychology Group will, to the best of their ability, attempt to answer any questions or concerns you might have or provide direction as to where your answers can possibly be found. If you wish to make a formal complaint regarding these privacy practices; you may make it in writing to Dr. Abu Shakra the Information Officer (contact information above). Receipt of your complaint will be acknowledged and investigated promptly and you will be provided with a formal decision and reasons in writing.

     

    If you have a concern about the professionalism or competence of The Dr. Malak Psychology Group, please discuss those concerns with Dr. Abu Shakra first. If The Dr. Malak Psychology Group cannot satisfy your concerns, you are entitled to contact the regulatory body (the following information lists are maintained on a best-efforts basis) as follows:

     

    Notice: the following list is maintained on a best-efforts basis

     

    College of Psychologists of Ontario

    www.cpo.on.ca

    This policy is made under the (PHIPA) Personal Health Information Protection Act, the (PIPEDA) Personal Information Protection and Electronic Documents Act, and the Digital Privacy Act. All are complex and provide some additional exceptions to the privacy principles that are too detailed to set out here, and as a result, there are some rare exceptions to the commitments The Dr. Malak Psychology Group has set out above.

     

    For more Privacy information and inquiries;

     

    Notice: the following list is maintained on a best-efforts basis

     

    The Privacy Commissioner of Canada

    https://www.priv.gc.ca/en/contact-the-opc/

     

    The Information and Privacy Commissioner of Ontario

    https://www.ipc.on.ca/about-us/contact-us/

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