Personal Information Protection Policy

At Dr. Lior Ben Avraham Counselling, we are committed to providing our clients and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about clients, protecting your personal information is one of our highest priorities.

We use the guideline suggested in British Columbia’s Personal Information Protection Act (PIPA) to protecting personal information. PIPA sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients and customers of why and how we collect, use and disclose your personal information, obtain your consent where required, and only handle your personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.

Definitions

Personal Information – Means information about an identifiable individual (E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information). Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Policy 1 – Collecting Personal Information

1.1

Unless the purposes for collecting personal information are obvious and the client voluntarily provides their personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2

We will only collect client’s information that is necessary to fulfill the following purposes:

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To verify identity, we may collect full name, home address, home and or telephone number and birth date;

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To identify how clients and customers are using Dr. Lior Ben Avraham Counselling website, I may use google analytics that tracks and reports website traffic. Google Analytics is used to track website activity such as session duration, pages per session and the bounce rate of individuals using the site, along with the information on the source of the traffic. Please note that google analytics provides only aggregated data and only shows a unique user ID and does not share personal information, usernames and IP addresses;

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To understand the financial and insurance needs of my clients and customers, I may ask the client or costumer to disclose their financial income and or insurance coverage to determine a sliding-scale rate;

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To open and manage a new client or a customer profile on the Jane App. As a new client or costumer, during the intake procedure, Dr. Lior Ben- Avraham Counselling will collect your name, your last name, and email address in order to generate a link to start a profile in the Jane App. Then, clients are requested to complete their profile information independently. Profile information includes legal, chosen name (if applicable), full address, phone number, emergency contact, and other information related to counselling services;

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To provide ethical clinical social work counselling services;

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To ensure a high standard of service to our clients;

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To meet regulatory requirements, we will verify that you are the person who are requesting counselling, that you live in the province of BC (Dr. Lior Ben- Avraham is unable to provide clinical social work counseling services to people outside the province of BC), and that you provided valid contact information (e.g., telephone number) for phone sessions or for emergency purposes.

Policy 2 – Consent

2.1

We will obtain clients’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2

Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client or customer voluntarily provides personal information for that purpose.

2.3

Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of their personal information being used for mail-outs, the marketing of new services or products, and the client does not opt-out.

2.4

Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Dr. Lior Ben Avraham Counselling to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict Dr. Lior Ben Avraham ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.

2.5

We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:

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When the collection, use or disclosure of personal information is permitted or required by law;

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In an emergency that threatens an individual's life, health, or personal security. If a client intends to take harmful action against another human being (such as homicide or causing serious bodily injury), or against themselves (such as suicide).

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In any actual or suspected acts of abuse or neglect of a minor (a person under 19 years of age) including physical abuse, sexual abuse, neglect, and/or emotional abuse. Acts of abuse or neglect against a vulnerable adult (such as an elder, or a person with a cognitive or developmental disability) may also need to be reported.

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When we require legal advice from a lawyer;

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For the purposes of collecting a debt;

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To protect ourselves from fraud;

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To investigate an anticipated breach of an agreement or a contravention of law.

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Consultation and Supervision. As part of ethical practices, Dr. Lior Ben Avraham meets regularly with a supervisor for the purpose of supervision and or consultation. Information about you may be discussed in confidence, without revealing your identity, with other counselling professionals for the purpose of consultation and providing you with the best possible service.

Policy 3 – Using and Disclosing Personal Information

Your identity, all interactions which take place in the setting of counselling are strictly considered confidential. This includes requests by email or telephone, all interactions with Dr. Lior Ben Avraham, any scheduling or appointment notes, all session content records and any progress notes that Dr. Lior Ben Avraham takes during your sessions. Exceptions to Confidentiality are listed above on section 2.5.

3.1

We will only use or disclose client’s personal information where necessary to fulfill the purposes identified at the time of contacting and receiving counseling services from Dr. Lior Ben Avraham.

3.2

We will not use or disclose client’s personal information for any additional purpose including third parties, family members, significant other, or friends, unless we obtain a written consent from the client to do so.

Policy 4 – Retaining Personal Information

4.1

Record Keeping — The standards of the counselling profession require that we keep client treatment records. Dr. Lior Ben Avraham Counselling respects and upholds a client’s right to privacy and to the protection of your personal information. We keep brief records, noting mainly that you have met with Dr. Lior Ben Avraham, what happened in session, and the topics you discussed. We aim to include the most minimal information possible in your notes, to decrease possible harm that may occur on the very low chance your file is legally requested by outside parties. Should you wish, you are entitled to receive a copy of your records. If you do want to see your records, we will offer for you to review them with the presence of Dr. Lior Ben Avraham so you can discuss the contents. We will keep your records for 7 years after you reach the age of 19. If you are 19 years of age and older, we will keep your records for 7 years upon completion of your counselling services at Dr. Lior Ben Avraham Counselling. Your personal information will be collected, used and disclosed in accordance with PIPA.

4.2

Subject to policy 4.1, we will retain client, customer, member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1

We will make reasonable efforts to ensure that client’s personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.

5.2

Clients may request access or correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. Dr. Lior Ben- Avraham has 30 days to respond to your request.

5.3

If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required on the electronic file or paper file along with a notice that a correction has been made. This correction will be signed and dated. If the correction is not made, we will note the clients’ correction request in their file.

Policy 6 – Securing Personal Information

6.1

We are committed to ensuring the security of client’s personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2

The following security measures will be followed to ensure that client’s personal information is appropriately protected:

Dr. Lior Ben Avraham counselling uses a Vancouver-based online platform called “Jane.” Jane offers the ability to schedule your sessions, keep your record secure, and facilitate your session via a highly secure video call. In terms of security, per Jane’s Guide Book, “Jane complies with applicable legal and regulatory requirements as well as best practices. This includes Jane's compliance with all Canadian Privacy laws, GDPR, HIPAA, and Standard Codes of Practice across multiple health professions.” If you’d like more detailed information about the privacy in the Jane system, please visit https://jane.app/guide/privacy-and-security/is-jane-pipeda-compliant, and https://jane.app/guide/privacy-and-security/privacy-compliance-for-clinics-in-british-columbia

It is important to let you know that due to the nature of online counselling, there is always the possibility that unauthorized persons may attempt to discover your personal information. Dr. Lior Ben Avraham will take every precaution to safeguard your information but cannot guarantee that unauthorized access to electronic communications could not occur. Please be advised to take precautions with regard to authorized and unauthorized access to any technology used in counselling sessions. Be aware of any friends, family members, significant others or co-workers who may have access to your computer, phone or other technology used in your counselling sessions. Should a client have concerns about the safety of their email, Dr. Lior Ben Avraham can arrange to encrypt email communication with you. Dr. Lior Ben Avraham uses the G-Suite email service, which is consistently leading the industry in encryption and security, but we still recommend that you don’t email sensitive health related information. The email correspondence between yourself and Dr. Lior Ben Avraham will be copied into your file, so Dr. Lior Ben Avraham can provide the best and most seamless care possible.

It is also important to understand that all technology, even that which meets privacy and confidentiality parameters and safeguards, always has some potential to be jeopardized. It is important that you mention any unique concerns you may have related to the Jane platform, regarding potential risk, or unintended access/disclosure to Dr. Lior Ben Avraham.

6.3

We will use appropriate security measures when destroying client’s personal information such as shredding document and or deleting electronically stored information.

6.4

We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Clients Access to Personal Information

7.1

Clients have a right to access their personal information, subject to limited exceptions such as:

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If Dr. Lior Ben Avraham is under the impression that disclosing your personal file would result to harm to you or another party, Dr. Lior Ben Avraham has the right under PIPA to refuse the release a copy of the file.

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If you received couple counselling and one party request a copy of their record, both parties must provide their consent to release marital/couples counseling records. If one party does not provide consent, records will not be released.

7.2

A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. Clients are asked to submit a written request to Dr. Lior Ben Avraham to access their entire personal file or a portion of it. Dr. Lior Ben Avraham encourages clients to engage in a dialog about releasing and or sharing such information prior to the disclosure of client’s personal record.

7.3

Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.

7.4

We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5

A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request. Fees for organizing and preparing your personal record are are billed in 15-minute intervals according to client’s current fee at Dr. Lior Ben Avraham Counselling.

7.6

If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.

Privacy Policy contact

If you have any questions about this policy, please contact Dr. Lior Ben Avraham Counselling directly at lior@drliorbenavraham.com or at (604) 305-4830.

Call: (604) 305-4830