Auren Wellness Inc. (“Auren Wellness,” “we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of the personal health information of every individual who receives services from us. This Privacy Policy explains how we collect, use, disclose, and protect personal health information (“PHI”) in accordance with the Personal Health Information Protection Act, 2004 (Ontario) (“PHIPA”) and other applicable legislation, including the Regulated Health Professions Act, 1991 (“RHPA”), the Psychotherapy Act, 2007, the Social Work and Social Service Work Act, 1998 (“SWSSWA”), and the Child, Youth and Family Services Act, 2017 (“CYFSA”).
By accessing services at Auren Wellness, you acknowledge that your personal health information will be handled as described in this Policy.
Auren Wellness Inc. is the health information custodian responsible for the personal health information collected in connection with the psychotherapy and social work services we provide. As custodian, we are accountable for ensuring that PHI in our custody and control is protected and used only for permitted purposes.
Auren Wellness Inc.
1 Centrepointe Dr., Unit #404
Ottawa, Ontario K2G 6E2
Auren Wellness has designated a Privacy Officer who is responsible for overseeing our compliance with PHIPA and this Policy, responding to privacy-related inquiries and complaints, and ensuring staff and contractors are trained in privacy obligations.
Privacy Officer Contact Information:
Name/Title: Privacy Officer, Auren Wellness Inc.
Email: david@aurenwellness.ca
Mailing Address: 1 Centrepointe Dr., Unit #404, Ottawa, Ontario K2G 6E2
If you have any questions, concerns, or requests related to your personal health information, please contact our Privacy Officer using the information above.
We collect only the personal health information that is reasonably necessary to provide you with safe, effective, and coordinated care. This may include:
We do not collect PHI beyond what is necessary for the purposes described in this Policy.
We collect, use, and disclose personal health information for the following purposes:
The primary purpose for collecting PHI is to provide psychotherapy and social work services, including conducting clinical assessments, developing and implementing individualized treatment plans, monitoring progress, and ensuring continuity and quality of care.
We use PHI to process fees for service, submit insurance or benefits claims on your behalf (with your consent), and maintain accurate financial records.
We may use or disclose PHI to comply with legal obligations, including mandatory reporting requirements under the CYFSA, court orders, or other legal processes as required by law.
PHI may be reviewed on a de-identified or aggregate basis for internal quality improvement purposes. Clinical supervision, which is a professional and regulatory requirement for therapists, may involve limited discussion of case information in a confidential context.
With your consent, we may communicate with other health care providers involved in your care to ensure coordinated and effective treatment.
We collect personal health information directly from you, or with your express knowledge and consent, including:
We will not collect PHI from sources other than you without your knowledge, unless permitted or required by PHIPA.
PHIPA permits health information custodians to share PHI, without express consent, among members of your “circle of care” — that is, health care providers who are directly involved in your care and who need the information to provide health care to you. Auren Wellness may share limited PHI with other treating health professionals involved in your care on this basis, unless you instruct us otherwise.
Beyond the circle of care, we will only disclose your PHI with your express written consent. This may include sharing records with your family physician, a specialist, another mental health provider, or an insurance company.
In certain circumstances, we are required or permitted by law to disclose PHI without your consent. These include, but are not limited to:
We will disclose only the minimum amount of PHI necessary to satisfy the legal or safety obligation.
We may share PHI with third-party service providers who assist us in operating our practice, including our practice management system provider. All such service providers are required to protect PHI in a manner consistent with PHIPA and our contractual obligations. They are not permitted to use PHI for any purpose other than providing services to Auren Wellness.
Auren Wellness offers psychotherapy and social work services via secure telehealth (video) platforms in addition to in-person sessions. Please be aware of the following when participating in virtual sessions:
We use video conferencing platforms that are designed to meet applicable privacy and security standards. However, the security of your connection also depends on your own device, internet connection, and physical environment. We encourage you to participate in virtual sessions from a private location using a secure, password-protected network.
Your use of virtual session services constitutes your acknowledgment of and consent to the particular privacy considerations associated with telehealth, including the inherent limitations of online communication. Your therapist will discuss these with you prior to your first virtual session.
Virtual sessions are not recorded by Auren Wellness without your express written consent. If any recording is made, it will be treated as PHI and stored securely in accordance with this Policy.
Auren Wellness uses Owl Practice, a cloud-based practice management system, to store and manage electronic health records, scheduling, billing, and client communications.
Client records stored in Owl Practice may be hosted on servers located in Canada or the United States. Where data is stored or processed outside of Canada, it may be subject to the laws of that jurisdiction. Auren Wellness has reviewed Owl Practice's privacy and security commitments and is satisfied that it provides an appropriate level of protection for PHI.
Access to Owl Practice is limited to authorized personnel, including the Privacy Officer, administrative staff, and the independent contractor therapist assigned to your care. Access is controlled through individual user accounts, unique credentials, and role-based permissions. Shared or generic logins are not used.
Owl Practice maintains access logs that record who has accessed client records and when. These logs are reviewed periodically and are available upon request in accordance with your rights under PHIPA.
Auren Wellness maintains physical, administrative, and technical safeguards appropriate to the sensitivity of PHI, including:
Despite these safeguards, no system is entirely immune from unauthorized access. In the event of a privacy breach that creates a real risk of significant harm to you, we will notify you as required by PHIPA.
We retain client records for a minimum of ten (10) years from the date of the last service provided, or as otherwise required by PHIPA, the RHPA, the Psychotherapy Act, 2007, and the SWSSWA.
Where the client was a minor (under 18 years of age) at the time services were provided, records will be retained until the later of: (a) ten (10) years from the date of the last service, or (b) the client's 28th birthday. This is consistent with applicable regulatory standards.
When records are no longer required to be retained, they will be destroyed in a secure manner that ensures PHI cannot be reconstructed or accessed. Electronic records will be securely deleted and paper records will be shredded.
Destruction of records will be suspended if we become aware of a legal proceeding, complaint, investigation, or other matter that may require the records to be preserved.
As a client of Auren Wellness, you have the following rights under PHIPA with respect to your personal health information:
You have the right to request access to your health records held by Auren Wellness. We will respond to an access request within 30 days of receipt, or notify you if additional time is required.
If you believe that your health record contains an error or omission, you have the right to request that it be corrected. If we agree that a correction is warranted, we will make it and notify any person to whom the incorrect information was previously disclosed. If we do not agree, we will note your request for correction in the record.
You have the right to withdraw consent to the collection, use, or disclosure of your PHI at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may affect our ability to continue providing services to you. We will explain the consequences of withdrawal before acting on your request.
You have the right to request a record of who has accessed your PHI held in our electronic systems. We will provide this information to the extent it is available through our practice management system's audit logs.
You have the right to complain about our privacy practices. See Section 13 below.
To request access to your health records or to request a correction, please contact our Privacy Officer in writing:
Your request should include:
We may ask you to verify your identity before responding to your request. We will not charge a fee to process a routine access or correction request, though we may charge a fee for requests that require extraordinary effort to fulfill, and will notify you of any fee in advance.
If you believe that Auren Wellness has not complied with PHIPA or this Policy, we encourage you to contact our Privacy Officer first so that we can attempt to resolve your concern:
We will acknowledge your complaint promptly and provide a written response within 30 days. We will investigate your concern, take corrective action where warranted, and notify you of the outcome.
If you are not satisfied with our response, or if you prefer to file a complaint directly with the regulator, you have the right to make a complaint to the Information and Privacy Commissioner of Ontario (IPC):
Auren Wellness delivers psychotherapy and social work services through independent contractor Registered Psychotherapists (“RPs”) and Registered Social Workers (“RSWs”). For the purposes of PHIPA, these independent contractors act as agents of Auren Wellness Inc. in their provision of services to Auren Wellness clients.
As agents, all independent contractor therapists:
This structure does not limit or diminish the independent professional and ethical obligations of each therapist under their respective regulatory college standards.
Auren Wellness may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational circumstances. We will post the revised Policy on our website at www.aurenwellness.ca and update the “Last Reviewed” date at the top of this document.
If a change materially affects how we handle your PHI, we will take reasonable steps to notify you directly (for example, by email or notice at the time of your next appointment) and to obtain any additional consent required.
Your continued use of our services after the effective date of a revised Policy constitutes your acceptance of that Policy.
This Policy is governed by and interpreted in accordance with the laws of the Province of Ontario and the laws of Canada applicable therein, including PHIPA.
Questions about this Privacy Policy may be directed to our Privacy Officer at david@aurenwellness.ca or by mail to 1 Centrepointe Dr., Unit #404, Ottawa, Ontario K2G 6E2.
