Privacy Policy

1. Introduction and Overview

Garnet Counselling (“we,” “us,” “our”), operated by Andrew Garnet MSW, RSW, is committed to protecting the privacy and confidentiality of your personal information. This policy describes practices intended to meet obligations under:

• The Personal Health Information Protection Act (PHIPA), S.O. 2004, c. 3 (Ontario)
• The Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5 (Federal)
• The Ontario College of Social Workers and Social Service Workers (OCSWSSW) Standards of Practice and Code of Ethics
• The Accessibility for Ontarians with Disabilities Act (AODA), S.O. 2005, c. 11

This policy explains our practices; simply visiting the website does not constitute consent to every collection, use, or disclosure described here. Where consent is required, Garnet Counselling seeks consent appropriate to the information and purpose. This website does not operate an inquiry form, newsletter signup, or analytics service.

2. Information We Collect

2.1 Information You Provide Directly

• Contact information (name, email address, phone number)
• Appointment booking information (collected via Jane App)
• Information you share in intake forms or correspondence
• Payment information (processed securely by Jane App's payment system)

This website does not collect inquiry or newsletter information. Visitors may choose to call, open an email in their own email application, or use Jane's separate booking service. Do not include symptoms, diagnoses, treatment history, or other health details in ordinary email. Personal information provided through telephone, email, or Jane is handled according to the applicable purpose, consent, professional obligations, and vendor terms.

2.2 Personal Health Information (PHI)

Personal health information — including information about your physical or mental health, your health history, and information related to the provision of health services to you — is collected only as required for the provision of therapeutic services. This information is subject to the heightened protections of PHIPA.

2.3 Website Information

When you visit our website, hosting infrastructure may record standard technical logs such as IP address, browser type, and requested pages for security and delivery purposes. Garnet Counselling does not currently operate analytics, advertising pixels, behavioural profiling, or cross-site tracking on this website.

3. How We Use Your Information

We collect and use your personal information only for the following purposes:

• Scheduling and managing your appointments
• Providing counselling and therapeutic services
• Processing payments and managing insurance/direct billing claims
• Communicating with you about your care
• Maintaining clinical records as required by law and professional standards
• Complying with legal obligations (including mandatory reporting requirements)

We do not sell, rent, or trade your personal information to third parties for commercial purposes.

4. Confidentiality of Therapeutic Services

The therapeutic relationship is founded on confidentiality. Andrew Garnet, as a Registered Social Worker governed by the OCSWSSW, protects information in accordance with applicable law and professional obligations. Information shared in therapy sessions will not ordinarily be disclosed without authorization, subject to legal and professional exceptions explained during informed consent, including:

• Where there is a serious and imminent risk of harm to you or an identifiable third party
• Where there is a reasonable suspicion of child abuse or neglect (mandatory reporting under the Child, Youth and Family Services Act)
• Where ordered by a court of law
• Where required by other applicable legislation

5. Jane App — Third-Party Booking and Records Platform

Appointment booking and clinical records management is conducted through Jane App. Garnet Counselling is responsible for configuring and using the service appropriately and periodically verifying its contractual privacy, security, storage, retention, and breach-notification terms. Jane's own Terms of Service and Privacy Policy also apply when you use its service.

6. Virtual Sessions — Security and Privacy

Virtual therapy uses a video platform selected and configured with privacy safeguards. Platform limitations, identity and location verification, emergency procedures, and limits of confidentiality are reviewed during informed consent. Sessions are not recorded by the practice unless a separate purpose and express prior consent have been documented. Clients should attend from a private location where they cannot be overheard.

7. Data Retention

Clinical records are retained for a minimum of 10 years following the last service date (or, for clients who were minors at the time of service, until age 28), as required by the OCSWSSW Standards of Practice and applicable law. Website contact inquiries are retained for up to 12 months.

8. Your Rights Under PHIPA and PIPEDA

You have the right to access your personal health information, request correction of inaccurate information, withdraw consent to the collection or use of your information (subject to legal and professional obligations), be informed of how your information is being used, and file a complaint with the Information and Privacy Commissioner of Ontario.

To exercise any of these rights, please contact Andrew Garnet directly at andrew@garnetcounselling.com or 365-363-0472.

9. Website Cookies and Tracking

This website does not currently set analytics or advertising cookies and does not use cross-site tracking pixels. The embedded Jane booking service, map, or other third-party pages may apply their own privacy and cookie practices when loaded or opened.

10. AODA and Accessibility

Garnet Counselling is committed to providing accessible services to all individuals in accordance with the Accessibility for Ontarians with Disabilities Act (AODA). Our website is designed to meet WCAG 2.1 Level AA standards. If you require accommodation, please contact us at andrew@garnetcounselling.com.

11. Security Measures

Website safeguards include HTTPS/TLS in production, restrictive security headers, no website inquiry or newsletter forms, no website analytics, and a practice of keeping health details out of ordinary email. Administrative safeguards and vendor configurations are reviewed separately; no internet transmission or storage system can be guaranteed completely secure.

12. Children's Privacy

This website is not intended for individuals under the age of 18. Andrew does not currently accept clients under 18 years of age through this practice.

13. Links to Third-Party Websites

This website may contain links to third-party websites (such as Jane App). We are not responsible for the privacy practices of those websites. We encourage you to review their privacy policies.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. A policy update does not replace any consent required by law for a new collection, use, or disclosure of personal information.

15. Contact and Privacy Complaints

For any privacy-related questions, concerns, or requests, please contact:

Andrew Garnet MSW, RSW
Garnet Counselling
10 Milner Business Court, Scarborough, Ontario
Email: andrew@garnetcounselling.com
Phone: 365-363-0472

If you are unsatisfied with our response, you may contact the Information and Privacy Commissioner of Ontario at ipc.on.ca or 1-800-387-0073.