Introduction
C.J.
Brown & Associates Inc. is committed to protecting the privacy
of people whose personal information is held.. Any personal information
provided to C.J. Brown & Associates Inc. 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
• Age
• City
• Province
• Country
• Postal Code
• Telephone Area code
• Best times to call
• PrivacEmailTM and Pro.PrivacEmailTM login ID
• Visits to PrivacEmail web site.
If
you visit our C.J. Brown & Associates Inc. E-Therapy web site
to browse, read pages, or download information, we will gather
and store certain information about the visit.
Information
collected automatically is used for purposes such as assessing
system performance, improving web services and web site management.
C.J. Brown & Associates Inc. 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
C.J
Brown & Associates Inc. does not collect personal information
about you unless you voluntarily provide it to use specific services.
Personal information collected, used, disclosed and retained by
C.J. Brown & Associates Inc. 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.
What
safeguards are in place?
C.J.
Brown & Associates Inc. 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 C.J. Brown &
Associates Inc.’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 C.J. Brown & Associates Inc. E-Therapy
site uses the industry standard 128-bit SSL (secure socket layer)
encryption on all web-based forms. Our PrivacEmailTM web-based
email system, including its web-based forms, uses 2048-bit encryption.
In
addition to our encryption standards, clients' C.J. Brown &
Associates Inc. E-Therapy account information is password-protected.
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.
C.J.
Brown & Associates Inc. 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 C.J. Brown &
Associates Inc. did not supply. Examples of security breaches
that we do not warrant include, but are not limited to:
Use
of Client Personal Information
C.J.
Brown & Associates Inc.’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 PrivacEmailTM account so that they can contact
C.J. Brown & Associates in a secure manner.
Client
Confidentiality
One
of the foundations of your Employee Assistance Program is the
assurance of confidentiality for those employees utilizing the
service.
All
personal information provided by clients is kept strictly confidential
in accordance with professional codes of counselling ethics. Discussions
with C. J. Brown & Associates Inc. staff and/or counsellors,
as well as records of employees’ use of the program, will
not be shared with employers, family members, or any other person/organization
unless written permission is received from the client.
C.J.
Brown & Associates Inc. uses security measures for its Internet
systems to protect client/counsellor communications and storage
of personal information. C.J. Brown & Associates Inc. will
not share client personal information with any third party, with
the following exceptions:
Exceptions
to client confidentiality are as follows:
1)
when disclosure is required to prevent clear and imminent danger
to the client or others
2)
when legal requirements demand that confidential material be revealed
3)
when a child is in need of protection.
Also,
in the event that we are subject to a review by an independent
evaluator, confidentiality will continue to be maintained, as
no information with personal identifiers will be shared with the
evaluator.
All
individuals who access their E-Therapy services are requested
to sign a “Statement of Understanding” form that outlines
our confidentiality policy.
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.
How
long is information retained?
The
length of retention will vary in relation to the nature of the
service. C.J. Brown & Associates Inc. will securely store
all records containing personal information, including online
counselling transcripts, for a period of three to 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
Nancy Jobin, Clinical Director, njobin@cjbrown.on.ca, 1-800-461-2292.
Links
to other sites
Visitors
should be aware that C.J. Brown & Associates Inc. 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. C.J. Brown & Associates Inc. is not responsible
for the privacy practices or content of external websites.
All
hyperlinks from C.J. Brown & Associates Inc. 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 C.J. Brown
& Associates Inc. 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. C.J. Brown & Associates Inc.
E-Therapy site 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 Nancy Jobin, Clinical Director, njobin@cjbrown.on.ca,
1-800-461-2292, if you have a complaint or concern about your
personal information, or for more information about this privacy
policy.
Distribution
of Unsolicited Information
C.J.
Brown & Associates Inc. 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, C.J. Brown & Associates Inc. 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, and technical updates. C.J. Brown & Associates
Inc. will not send unsolicited messages regarding any third party
commercial offers or advertisements.
Policy
Changes
C.J.
Brown & Associates Inc. 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 C.J. Brown & Associates 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
C.J.
BROWN & ASSOCIATES INC. DISCLAIMS ALL RESPONSIBILITY OR LIABILITY
FOR ANY DAMAGES CAUSED BY VIRUSES CONTAINED AT OR WITHIN THE C.J.
BROWN & ASSOCIATES INC. SITE OR WITHIN ANY ELECTRONIC FILES
SENT FROM THE C.J. BROWN & ASSOCIATES INC. SITE.
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If
at any time you believe that C.J. Brown & Associates Inc.
has not adhered to these principles, please contact
us immediately.
