Privacy Policy for Personal Information

Introduction

Therapy Online is committed to protecting the privacy of people whose personal information is held. All clients of our services, professional helpers, and visitors to our web sites must be treated with personal human care, outstanding ethics, and integrity. We undertake to honour or exceed the legal and ethical requirements of information privacy that apply in Canada through responsible information management practices. Any personal information provided to Therapy Online is collected, used and disclosed in accordance with the ethical codes of the counselling profession and the Personal Information Protection and Electronic Documents Act of Canada.

What is Personal Information?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Last name
• First name
• Street Address (home)
• Telephone number
• E-mail address
• Credit card information
• Age
• City
• Province (State)
• Country
• Postal (Zip) Code
• Telephone Area code
• Time Zone
• Best times to call
• Occupation
• PrivacEmail^TM  and Pro.PrivacEmail^TM login ID
• How clients found out about our services
• Visits to our web sites

Personal information also includes

• opinions, evaluations, comments, social status, or disciplinary actions; and
• employee files, credit records, loan records, medical/counselling records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs)

What kind of information is being collected?

If you visit a Therapy Online web site to browse, read pages, or download information, we will gather and store certain information about the visit. The following information is automatically collected and stored:

The Internet Protocol Address and domain name used. The Internet Protocol address is a numerical identifier assigned either to your Internet service provider or directly to your computer. This address can be translated to determine

• the domain name of your service provider (e.g. gov.bc.ca, xcompany.com or yourschool.edu);
• The type of browser and operating system;
• The date and time of the visit; and
• The web pages or services accessed.

Information collected automatically is used for purposes such as assessing system performance, improving web services and web site management. Therapy Online does not use this data to determine your identity unless required to do so as part of an internal investigation or other law enforcement purpose.

Information Collected Directly From You

Therapy Online does not collect personal information about you unless you voluntarily provide it to use specific services. Personal information collected, used, disclosed and retained by Therapy Online will only be used by authorized staff to fulfill the purpose for which it was originally collected, or for a use consistent with that purpose unless you expressly consent otherwise.

If you provide credit card information, your credit card number and purchase information is provided to the banking merchant and will appear on your credit card statement. This is necessary to complete the transaction.

What safeguards are in place?

Therapy Online protects your personal information by making careful security arrangements against such risks as unauthorized access, collection, use, disclosure or disposal. Security measures have been integrated into the design, implementation and day-to-day operating practices as part of Therapy Online’s continuing commitment to the protection of personal information it holds.

When clients wish to transmit personal information we always encourage them to use our secure systems to transmit that information in an encrypted format. The Therapy Online site uses the industry standard 128-bit SSL (secure socket layer) encryption on all web-based forms. Our PrivacEmail^TM web-based email system, including its web-based forms, uses 2048-bit encryption.

In addition to our encryption standards, clients' Therapy Online account information is password-protected so that only clients, their counsellors, and the counsellors' supervisors have access to this personal information.

We urge clients NOT to disclose their PrivacEmail password to anyone. We also instruct clients to sign out of the PrivacEmail web site and close their browser window when communications are complete. This helps keep client personal information safe.

Therapy Online does not warrant the security of confidential material that becomes insecure because of actions that clients may take or that is a result of software that Therapy Online did not supply. Examples of security breaches that we do not warrant include, but are not limited to:

• leaving confidential material on a computer screen for others to see
• storing confidential material on the computer used by a client
• use of monitoring software (for example, by an employer)

While we strive to protect clients' personal information, no data transmission over the Internet is guaranteed to be 100% secure. Thus, Therapy Online cannot ensure or warrant the security of any information during transmission to or from our site, and clients submit information to us at their own risk. However, we do our best to ensure the highest level of security on our systems.

Use of Client Personal Information

Therapy Online's primary use of clients' personal information is the provision of professional online counselling. Personal information is also required in order to enable potential clients to create a PrivacEmail^TM account so that they can contact Therapy Online in a secure manner.

Client Confidentiality

All personal information provided by clients is kept strictly confidential in accordance with professional codes of counselling ethics. Therapy Online uses security measures for its Internet systems to protect client/counsellor communications and storage of personal information. Therapy Online will not share client personal information with any third party, with the following exceptions:

1. In order to give clients the best possible services, Therapy Online's counsellors are regularly supervised by other qualified counsellors. Supervision involves the counsellor releasing client personal information to the supervisor.

2. All Canadian citizens (including counsellors) are required by law to report any suspicion of risk of child abuse or neglect. If we believe that a child is at risk of being abused, has already been abused, or that someone who previously abused children is still a threat (for example if they still work in a day care) we must report the information to appropriate child protection authorities or police.

3. If we believe that a person's life may be in danger, we will report the situation to appropriate authorities. This applies to cases of potential suicide and homicide.

4. Courts of law have the power to demand that we release client records if clients are involved in a court case in which their relationship to Therapy Online is somehow relevant.

Therapy Online's counsellors ability to fulfill their obligations as described in 1, 2 and 3 above are limited by the information that clients provide them.

Clients Urged to Update Information

Clients are asked to update their address, telephone number, and e-mail address, whenever such changes occur by notifying their counsellor of the changes from within their PrivacEmail account. Failure to do so releases Therapy Online from our ethical/legal obligation to warn of life threatening situations.

How long is information retained?

The length of retention will vary in relation to the nature of the service. Therapy Online will securely store all records containing personal information, including online counselling transcripts, for a minimum period of 18 months and a maximum period of five years.

How can I access and correct my personal information?

You can review any personal information collected about you by simply requesting it in writing. You may request changes or annotate your personal information if you believe it to be inaccurate by submitting a written request describing the error. Please contact Dan Mitchell.

Links to other sites

Visitors should be aware that Therapy Online's web sites may include links to web sites operated by government agencies, non-profit organizations and private businesses. When you link to another site, this privacy policy will not apply, however, you may be subject to the privacy policy of that new site, if one exists. Therapy Online. is not responsible for the privacy practices or content of external websites.

All hyperlinks from Therapy Online’s web site are screened for appropriateness and for compatibility with our ethical standards. However, we have no control over the third parties whose hyperlinks we allow on our site. These third parties may change their web site content without notice. Clients or visitors who link to any other site do so at their own risk and Therapy Online will not be responsible or liable for any damages in connection with linking.

Cookies

A cookie is a small file stored on your computer by your web browser when using some internet sites. Therapy Online uses temporary cookies to facilitate your transactions. These cookies exist in your browser's temporary memory only and are deleted when you close your browser.

Please contact Dan Mitchell if you have a complaint or concern about your personal information, or for more information about this privacy policy.
 

Distribution of Unsolicited Information

Therapy Online will not send clients any unsolicited information, including e-mail, except as follows:

1. When clients establish and use their secure PrivacEmail account, they can use the "e-mail notification" function of the PrivacEmail system to deliver them a non-secure e-mail notification message whenever a new message arrives in their PrivacEmail inbox. These notifications do not contain any information that would enable a third party to identify that the e-mail came from a counselling agency.

2. Occasionally, Therapy Online may send unsolicited notices to PrivacEmail and Pro.PrivacEmail accounts. These notices, if sent, will allow us to provide counselling follow-up or request evaluation of our services, or to announce important service changes, new features, technical updates and news about other Therapy Online products and services. Therapy Online will not send unsolicited messages regarding any third party commercial offers or advertisements.

Policy Changes

Therapy Online reserves the right to change its privacy policy without notice at any time. However, such changes, if made, will adhere to all pertinent legal and ethical specifications. If we make changes to our privacy policy, we will post those changes on our Web site for clients to review.

Disclaimers

Security of Client Passwords

Clients are held responsible for maintaining the secrecy of their passwords and/or any account information. Clients are also solely responsible writing down and securely storing their passwords. For security reasons, neither Therapy Online nor PrivacEmail keeps any backup record of client passwords. If a PrivacEmail password is forgotten, the account becomes inaccessible; all information stored therein is lost.We encourage clients to be careful and responsible whenever they are online, and especially when engaged in online counselling.

General Disclaimer

THERAPY ONLINE SHALL NOT BE HELD RESPONSIBLE FOR DAMAGE OR LOSS OF ANY KIND DUE TO CLIENTS' USE OF SOFTWARE AND/OR ANY OTHER PRODUCT OR SERVICE PURCHASED AT THERAPY ONLINE. OUR MAXIMUM LIABILITY TO CLIENTS IS THE AMOUNT THEY PAID FOR THE SERVICES. THERAPY ONLINE DISCLAIMS ALL RESPONSIBILITY OR LIABILITY FOR ANY DAMAGES CAUSED BY VIRUSES CONTAINED AT OR WITHIN THE THERAPY ONLINE SITE OR WITHIN ANY ELECTRONIC FILES SENT FROM THE THERAPY ONLINE SITE.

Trademarks and Copyrights

Therapy Online^TM, TherapEmail^TM, Virtually Solve It^TM, VSI^TM, eSupervision^TM, eTraining^TM, PrivacEmail^TM, Pro.PrivacEmail^TM, the Therapy Online^TM logo, both PrivacEmail^TM logos (the small padlock/envelop/featherpen logo and the full-sized logo) are trademarks or registered trademarks of Worldwide Therapy Online Inc.. The contents of this Web site are Copyrighted, 1995-2006, Worldwide Therapy Online Inc., unless otherwise specified. All Rights Reserved. All other product names and company logos are the trademarks of their respective owners.

Last revised: September 09, 2010