Privacy Policy for Individual Counselling

Privacy of personal information is extremely important to me. I am committed to collecting, using and disclosing personal information responsibly in my practice, and only to the extent necessary for the services I provide. I aim to be open and transparent about how I handle personal information.

What is personal information?

Personal information is information about an identifiable individual. Personal information includes information that relates to personal characteristics (e.g., gender, age, income, home address or phone number, race, family structure, health [e.g., health history, health conditions, health services received] or their activities and views [e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual]). Personal information is different from business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

External groups I work with

I interact with a number of healthcare providers and agencies that may, in the course of their duties, have limited access to personal information I hold. These include an accountant, a digital scheduling and file storage company, credit card companies, and lawyers. I restrict their access to any personal information I hold as much as reasonably possible. I also have their assurance that they follow appropriate privacy principles.

Collection of personal information: Primary purposes

For Clients

Like all Registered Dietitians, I collect, use, and disclose personal information in order to serve my clients. The primary purpose for collecting personal information about you is to provide you with dietetic services. I collect information about your health and diet history, physical condition and function, and social situation in order to assess what your needs are, to advise you of your options, and then to provide the health care you choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services I can identify changes that are occurring over time. It would be rare for me to collect such information without the client’s express consent, but this might occur in an emergency (e.g., the client is unconscious) or where I believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from a client and I have no reason to believe that the message is not genuine).

For Students and Interns

For students and dietetic interns, the primary purpose for collecting personal information is to ensure I can contact them in the future and for necessary work-related communication. Examples of the type of personal information I collect for those purposes include home addresses and telephone numbers. It is rare for me to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., a pandemic-related outbreak) or to investigate a possible breach of the law. If students or interns wish a letter of reference or an evaluation, I will collect information about their work-related performance and provide a report as authorized by them.

Collection of personal information: Related and secondary purposes

Like most organizations, I also collect, use, and disclose information for purposes related to my primary and secondary purposes. The most common examples of these are listed below.

To invoice clients for services that were not paid for at the time, to process credit card payments, or to collect unpaid accounts.
I review client files for the purpose of ensuring that I provide high-quality services.
Registered Dietitians are regulated by the College of Dietitians of Ontario, who may inspect my records and interview me as part of their regulatory activities in the public interest.
I will report serious misconduct, incompetence or incapacity of other practitioners, and will report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern.
Like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review my files as part of their mandates. In these circumstances, I may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to me.
The cost of some services provided to clients is paid for by third parties (e.g., private insurance companies). These third-party payers often have client consent or legislative authority to direct me to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.

You can choose not to be part of some of these related or secondary purposes (e.g., by paying for your services in advance). I do not, however, have control over some of these related or secondary purposes (e.g. external regulation).

Protecting Personal Information

I understand the importance of protecting your personal information. For this reason, I have taken the following steps:

No personal information is recorded on paper, and no paper records are kept.
Electronic hardware is secured in a locked room at all times. Passwords are used on all devices.
Electronic information is transferred through an encrypted platform (Jane app).
Any students or interns are trained to collect, use, and disclose personal information only as necessary to fulfill their duties and in accordance with this privacy policy. Informed client consent is always required for a student or intern to access the client’s file.
External consultants and agencies with access to personal information must enter into privacy agreements with me.

Retention and destruction of personal information

I need to retain personal information for some time to ensure that I can answer any questions clients might have about the services provided and for my own accountability to external regulatory bodies. However, I do not keep personal information longer than necessary, in order to protect client privacy. I keep files for around ten years; after that, I destroy electronic information by deleting it and, when the hardware is discarded, I ensure that the hard drive is physically destroyed.

Clients can look at their information

With only a few exceptions, you have the right to see what personal information I hold about you. Often all you have to do is ask, so that I can help you identify what records I have containing your personal information. I will also try to help you understand any information you do not understand (e.g., abbreviations). I will need to confirm your identity before providing access. I reserve the right to charge a nominal fee for such requests. If there is a problem, I may ask you to put the request in writing. If I cannot give you access, I will tell you within 30 days and give the reason, as best I can, as to why I cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions I may have formed. I may ask you to provide documentation to show that my files are inaccurate. Where we agree on any error, I will make the correction and notify anyone to whom I sent this information. If we disagree on information in your file, I will still agree to add a brief statement from you on the point, and I will forward that statement to anyone else who received the earlier information.

If you have a question about this privacy policy, you can reach me at:

#328-427 Princess St., Kingston, ON. K7L 5S9.

hello@thekiwird.com

If you have a concern about the professionalism or competence of my services or my mental or physical capacity, you are entitled to complain to my regulatory body:

College of Dietitians of Ontario

5775 Yonge St.

North York, ON

M2M 4J1

PHONE: (416) 598-1725

This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA). That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at

112 Kent Street, Ottawa ON, K1A 1H3

PHONE: 1-800-282-1376