Privacy Policy (Effective August 22, 2024; Updated February 6, 2025)
Your provider, Nicole Lacy, Registered Psychotherapist, (“Nicole Lacy Psychotherapy and Counselling Services” “Nicole Lacy, MSEd, RP” “Nicole” or “her” or “she”) is bound by applicable privacy laws including Ontario’s Personal Health Information and Protection Act, as well as professional standards and ethics, to safeguard the privacy and confidentiality of your information.
By using Nicole’s Services, you agree to the collection, use, and disclosure of personal information in accordance with this Privacy Policy. It applies to all personal information collected by Nicole when you use her resources or services (collectively, the “Services”).
What personal information does Nicole collect?
When you use Nicole’s Services, she may collect or receive personal information (including personal health information) about you to provide her Services and operate her business. She collects the following personal information:
Information you provide to Nicole directly
You may provide your personal information to Nicole when you use her Services, including when you make an appointment, meet with Nicole for sessions, contact Nicole with inquiries, or otherwise access her Services. This information may include:
Contact information, such as your name, email address, phone number, and mailing address;
Health information, such as your health history, individual’s family health history, information about your physical/mental health condition and physical/mental health function
Demographic information, such as your age, and gender;
Information Nicole generates about you, including her clinical observations or opinions and information relating to your use of her Services.
Nicole may collect other information that you choose to provide to her, or that she collects with your consent.
Information received from you as part of your communications
When you use the Services, complete electronic forms, communicate with Nicole or contact her by email or phone, Nicole may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; information that you voluntarily provide to Nicole; the nature of your communication; the purpose of the interaction, and the action she took in response to your inquiry or request.
For what purposes does Nicole use personal information?
Nicole may use personal information that she collects or receives about you for various purposes.
To provide you with her Services
Nicole uses your personal information to provide you with her Services. Specifically, she may use your personal information to: (i) assess your mental health needs; (ii) provide counselling sessions, psychotherapy sessions and treatment programs; (iii) provide you with consultation; (iv) communicate with healthcare providers, including physicians, nurses, therapists and pharmacists and other organizations if you provide your consent for and prior to the disclosure; and (v) invoice you for services rendered, to process credit card or other bank payments, or to collect unpaid fees.
To maintain, improve, and personalize her Services
Nicole uses your personal information for her everyday business operations such as auditing and administration of her Services. Your information may also be used to help Nicole improve her Services. She also uses your information to personalize your experience.
To communicate with you
Nicole uses your personal information to:
communicate with you;
distribute health care information to you; and
respond to inquiries and requests from you.
In the event you contact Nicole, she uses certain information to respond to your questions and assist you with any issues that may arise in your use of her Services.
To plan, administer and manage the internal operations of Nicole Lacy Psychotherapy & Counselling Services
Nicole may use your personal information to plan, administer and manage the internal operations of Nicole Lacy Psychotherapy & Counselling Services.
To meet accreditation standards
Nicole may use your personal information to meet accreditation standards including the College of Registered Psychotherapists of Ontario.
To maintain legal and regulatory compliance
Nicole’s Services are subject to certain laws, regulatory and/or professional obligations, which may require her to process your personal information. For example, she processes your personal information to fulfill her professional obligations, or as necessary to manage risk as required under applicable law.
For other purposes permitted or required by law
Nicole may use personal information for other purposes disclosed to you at the time she collects or receives the information with your consent or as permitted or required by law.
When and to whom does Nicole disclose personal information?
Your personal information is not shared with third parties without your permission, except as described below.
Service providers: Nicole may transfer (or otherwise make available) personal information to service providers (including affiliates acting in this capacity) who perform services on her behalf. For example, Nicole may use service providers to provide back-up, process payments, or store data (i.e., Jane App, Zoom for Healthcare, Hushmail, Doxy.Me). Personal information may be maintained and processed by her service providers in Canada or other jurisdictions. Nicole’s service providers are given the information they need to perform their designated functions, and Nicole does not authorize them to use or disclose personal information for their own purposes.
Disclosures authorized or required by law: There are limited situations where Nicole is legally required or authorized to disclose your personal information without your consent. In certain circumstances, Nicole is required or permitted by law to disclose your personal health information without your consent. For example, your consent to collection, use and disclosure of your personal health information is not required in the following circumstances (without limitation):
for the purposes of contacting a family member, friend or substitute decision-maker if you are injured, ill or incapacitated and unable to give consent personally;
it is necessary for the purpose of eliminating or reducing a significant risk of serious bodily harm to a person or group of persons;
when there is reasonable suspicion of child abuse or neglect;
in order to comply with a Court order or police warrant;
such other exemptions permitted or required by law.
Disclosures with consent: Nicole may disclose your personal information in other circumstances with your consent.
You can withdraw your consent to have your information shared with other parties at any time, except where the disclosure is required by law.
What are your rights?
Nicole aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.
This section lists the privacy-related rights (“Rights”) Nicole extends to you. Your right to know and right to deletion are not absolute and are subject to certain exceptions.
Right to Know – You have the right to know the personal information Nicole collects, uses, and discloses about you.
Right to Deletion – You have the right to request that Nicole deletes any personal information she has collected from you or maintains about you. Nicole may save personal information when permitted by applicable law including, without limitation, when the information is needed for a legal purpose.
Right to Correction – You are free to request correct of your personal information where you believe there is an error or omission. You are entitled to require that a statement of disagreement be attached to your information reflecting any correction that you requested but not made by Nicole. You are also entitled to require that any person to whom the personal information has been disclosed within the year before your request be notified of the correction or statement of disagreement.
You must send a written request to access or correct your personal information which may include a fee. Your written request must contain sufficient detail to enable Nicole to identify and locate the record. To request your personal information, please send an email to Nicole Lacy, MSEd, RP at nicolelacy@hushmail.com and she will process your request.
Nicole will contact you if your request is deficient or she needs to clarify the information you are requesting. Nicole will also need to verify your identity before processing requests for your personal information.
How secure is your information?
Safeguards are in place to protect the security of your information. These safeguards include a combination of physical, technological and administrative security measures that are aimed at protecting personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Please note, however, that while Nicole believes her security measures are appropriate, no security measures can guarantee absolute security of information.
How long does Nicole keep information?
Nicole will retain your personal information for as long as your account is active or as needed to provide you Services. Nicole will also retain and use your personal information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.
What if Nicole transfers your personal information to another jurisdiction?
Your information, including personal information, may be transferred to — and maintained on — computers located outside of your province, country or other jurisdiction where the data protection laws may differ than those from your jurisdiction.
Nicole is based in Canada and, regardless of where you use her Services, the information collected as part of that use will be transferred to and maintained on servers located in Canada. Any information Nicole obtains about you will be stored in accordance with Canadian privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using Nicole’s Services, you consent to this collection, transfer, storage, and processing of information to and in Canada.
Nicole will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Changes to this Privacy Policy
Nicole may update this Privacy Policy from time to time. She will notify you of any changes by posting the new Privacy Policy on this page.
She will let you know via email and/or a prominent notice on her Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
How can you contact Nicole?
If you have any questions or concerns relating to this Privacy Policy or my privacy practices, please contact:
Nicole Lacy, MSEd, RP
Email: nicolelacy@hushmail.com
Privacy Concerns and Complaints
For more information about Nicole’s privacy protection practices, or to raise a concern you have with her practices, contact Nicole Lacy, MSEd, RP at nicolelacy@hushmail.com.
If you have a concern about the professionalism or competence of Nicole’s Services, you should discuss these concerns directly with Nicole. If she cannot satisfy your concerns, you are entitled to complain to Nicole’s regulatory college, the College of Registered Psychotherapists of Ontario.
You also have the right to complain to the Information and Privacy Commissioner/Ontario if you think Nicole has violated your rights.
The Commissioner can be reached at: Information and Privacy Commissioner/Ontario - 1400 – 2 Bloor Street East - Toronto, Ontario M4W 1A8 - Tel: (416) 326-3333 or 1-800-387-0073 - TDD/TTY: (416) 325-7539 - Website: www.ipc.on.ca