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 Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with:

• 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

By using this website or accessing our services, you consent to the practices described in this policy.

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)

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, standard server logs may record your IP address, browser type, and pages visited. We do not currently use third-party analytics that identify individual users.

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 any third party for commercial purposes. Ever.

4. Confidentiality of Therapeutic Services

The therapeutic relationship is founded on confidentiality. Andrew Garnet, as a Registered Social Worker governed by the OCSWSSW, maintains the strictest professional confidentiality. Information shared in therapy sessions is protected and will not be disclosed without your express written consent, except in the following legally mandated circumstances:

• 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, a Canadian health practice management platform. Jane App stores data on servers located in Canada, is compliant with PHIPA and PIPEDA, and uses industry-standard encryption. By booking an appointment through Jane App, you also agree to Jane App's Terms of Service and Privacy Policy.

6. Virtual Sessions — Security and Privacy

Virtual therapy sessions are conducted via a PHIPA-compliant, end-to-end encrypted video platform. No session is recorded without your prior written consent. We recommend that you attend virtual sessions from a private location where you 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 uses minimal cookies necessary for basic functionality. We do not use advertising cookies, cross-site tracking pixels, or sell data to advertisers. You may disable cookies in your browser settings; this may affect website functionality.

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

We implement reasonable administrative, technical, and physical safeguards to protect your personal information, including HTTPS/TLS encryption, PHIPA-compliant booking and records management through Jane App, and password-protected electronic communications.

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. Changes will be posted on this page with an updated effective date. Continued use of our services after changes constitutes acceptance of the revised policy.

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.