Privacy | Personal Counselling and Accessible Learning Services | Seneca Students

Privacy of personal and personal health information is an important principle to the Counselling and Accessibility Services department. Our professional staff, including regulated health-care providers, are committed to collecting, using and disclosing information responsibly and only to the extent necessary for the services we provide. The Counselling and Accessibility Services department follows legislated privacy obligations in both the Freedom of Information and Protection of Privacy Act (FIPPA) and, when acting as a health information custodian as part of our care delivery model, the Personal Health Information Protection Act (PHIPA).

What is Personal Information?

Information about an identifiable individual, including:

• race, national or ethnic origin, religion, age, sex, sexual orientation, and marital or family status
• employment and educational history
• medical, psychiatric and psychological history, prognosis, condition, treatment and evaluation
• any identifying number (Social Insurance Number, student number), symbol or other assigned particular
• home address and telephone number
• personal opinions of or about the individual
• name, where it appears with or reveals one’s personal information
• correspondence sent to Seneca by an individual that is implicitly or explicitly of a private or confidential nature and any reply to that correspondence that would reveal its contents.

What is Personal Health Information

Any identifying information about an individual in oral or recorded form, including but not limited to information that:  

• relates to the physical or mental health of the individual, including information that consists of the health history of the individual’s family  
• relates to the providing of health care to the individual, including the identification of a person as a provider of health care to the individual  
• is a plan of service within the meaning of the Home Care and Community Services Act, 1994 for the individual  
• relates to the donation by the individual or any body part or bodily substance of the individual or is derived from testing or examination of any such part or bodily substance 
• is the individual’s health number  
• identifies an individual’s substitute decision maker 

Who We Are

Counselling and Accessibility Services includes professional staff from the following areas: counselling services, accessibility services, enhanced services (i.e. learning strategists, assistive technologists), reception (i.e. administrative assistants, service advisers, and support staff such as scheduling support services, data entry, etc.). Our management department is staffed by a Director, Associate Director/Senior Manager Counselling Services/Accessibility Services and an Office Manager.

Seneca Partners We Collaborate With

In order to provide supports and services to Seneca students accessing Counselling and Accessibility Services, the department works collaboratively with internal departments on a frequent basis, including but not limited to the Seneca Test Centre, Counsellor within First Peoples@Seneca and the Medical Centre. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles accessing information in the course of doing business with our department. In situations where more information may be required to support a specific student, an informed consent form will be signed between the student and one of these departments.

Provision of Academic Accommodations – OHRC March 2016

Consistent with the Ontario Human Rights Commission Recommendations (Letter dated March 2016) students are not required to deliver their Academic Accommodation Letters directly to their teaching faculty or academic and program area. Counselling and Accessibility Services works with the academic and program areas to identify the most efficient process or person who can assist with the implementation of Academic Accommodation Letter notification to assigned teaching faculty, coordinator, student adviser and chair for the student during their length of registration with Seneca. The Academic Accommodation Letter outlines a student’s academic needs within a learning environment (e.g. classroom, testing, assessment, evaluation and in practical settings such as field, co-op or clinical settings). Only relevant information related to their resulting need based on functional limitations are disclosed to provide the student increased opportunities for success at Seneca. The student can work with the counsellor to authorize additional disclosure of information as needed for the purpose of enacting accommodations.

Collection of Information: Primary Purposes

Personal Health Information – Registered Students with our Office

Students who register with Counselling and Accessibility Services have acknowledged their agreement to participate in a process to receive services that may include activities such as personal counselling, accessibility services, enhanced services and/or academic accommodations. We collect, use and disclose personal health information as required of a health information custodian and in compliance with PHIPA in order to serve students registered with our office. For our students, the primary purpose for collecting information is to provide counselling, accessibility and/or academic accommodations. For example, we collect information about a student’s health history, including their family history, physical condition, social situation and functional limitations in order to help us assess what their educational needs are, to advise them of their options which may include such things as short-term supportive counselling, academic accommodations, learning skills or assistive technology supports or a referral to a community agency or practitioner for longer-term clinical supports. A secondary purpose is to obtain a baseline of health and social information so that in providing short-term counselling services we aim to identify or detect changes that occur over time that suggest a student may require acute supports. It would be rare for us to collect such information without the student’s express consent, but this might occur in an emergency (e.g., the student is unconscious, medical issue such as a seizure) or where we believe the student would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from the student and we have no reason to believe that the message is not genuine).

Electronic Collection, Usage and Storage of Personal Health Information

Counselling and Accessibility Services currently uses an electronic records keeping system called ClockWork. Access to ClockWork is restricted to Counselling and Accessibility Services employees and information is protected through the use of technical and administrative safeguards such as restricted access permissions, multi-factor authentication and use of other industry standard security controls.

ClockWork is used by a number of college and universities providing counselling and accessibility services. ClockWork includes a number of self-service modules that enable the provision of virtual services to students, such as distribution of accommodation letters and secure uploading of medical and related documentations.

On the Counselling and Accessibility Services website, we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a service or support, to access assistive technology and other material resources). Cookies are only used to help students navigate our website and are not used to monitor their activities.

Collection of Information: Secondary and Related Purposes

Like most organizations, we also collect, use and disclose information for secondary purposes, which are related to our primary purpose of doing business. In these examples, a client may be one or more of the following: external business client, a student, supplier, company or agency. The most common examples of our related and secondary purposes are as follows:

• To advise students and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new resource/technology) that we have available.
• To advise students that a resource/technology or service should be reviewed (e.g., to ensure a resource/technology is still functioning properly and appropriate for their current needs and to consider modifications or replacement).
• Our department reviews student and other files for the purpose of ensuring that we provide high-quality services, including assessing the performance of our management staff and professional staff. In addition, external consultants (e.g., ministry auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our services, including reviewing student files and interviewing our professional and administrative staff.
• Counselling and Accessibility Services are regulated by a number of professional Colleges including: College of Psychologists of Ontario, College of Social Workers and Social Service Workers, College of Occupational Therapists Association, and other licensing bodies who may inspect our records and interview our professional staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our students, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Ministry of Colleges and Universities, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
• To invoice students for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
• The cost of some goods/services provided by the organization to clients is paid for by third parties (e.g., Bursary for Students with Disabilities (BSWD), Ontario Health Insurance Plan (OHIP), Workplace Safety and Insurance Board (WSIB), and private insurance, Assistive Devices Program (ASD)). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate student’s entitlement to this funding.
• Students or other individuals we deal with may have questions about our goods or services after they have been received. We also provide ongoing services for many of our students over a period of months or years for which our previous records are helpful. We retain our student record information for a minimum of 10 years after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our client records)

You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

Protecting Student Information

We understand the importance of protecting personal and personal health information. For that reason, we have taken the following steps:

• paper information is either under supervision or secured in a locked or restricted area
• electronic hardware is either under supervision or secured in a locked or restricted area at all times; in addition, passwords are used on computers
• paper information is transmitted through sealed, addressed envelopes or boxes by reputable Seneca staff or companies
• electronic information is transmitted either through a secure provider, a direct line, has identifiers removed or is encrypted
• staff are trained to collect, use and disclose personal information only as necessary to fulfil their duties and in accordance with the department’s privacy policy
• external consultants and agencies with access to personal information must enter into privacy agreements with Seneca

Retention and Destruction of Student Information

We retain personal and personal health information to ensure we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. We keep our student files for 10 years. Student paper files/records stored under this provision are held off site, at our third-party storage company used by Seneca. We keep any personal information relating to our general correspondence (i.e., with people who are not students) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, in some cases in consultation with key stakeholders we may send some or all of the client file to the student or their substitute decision-maker.

Student Access to Records

With only a few exceptions, students have the right to see what personal or personal health information the department has on file about them. Students will be asked to make this request in writing to:

Attention: Director

Counselling and Accessibility Services
1750 Finch Ave. E.
Toronto, Ont. M2J 2X5

We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We reserve the right to charge a nominal fee for such requests.

If we cannot give you access, we let you know the reason access has been denied. Requests are responded to within 30 days; however, there are limited circumstances where we are permitted to extend the time limit beyond 30 days.

If you believe there is an error in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that the information in the file is incorrect. Where we agree that an error has been made, we will make the correction and notify anyone to whom we sent this information. If we do not agree that an error has been made, we will still agree to include a brief statement from you in your file on the point and we will forward that statement to anyone else who received the earlier information.

Do You Have a Privacy Question Related to Your File Within Counselling and Accessibility Services?

Director

Counselling and Accessibility
Services 1750 Finch Ave. E.
Room E2427
416.491.5050 ext. 22900

Additional Questions/Complaints

If you have more questions after speaking with the Director within the Counselling and Accessibility Services office or if you wish to make a formal complaint about the department’s

privacy practices, you can do so in writing to our Privacy Officer. The Privacy Officer will attempt to answer any questions or concerns you might have.

The Privacy Officer will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision with reasons.

Privacy Officer

Seneca
8 The Seneca Way
Markham, Ont. L3R 5Y1
416.491.5050 ext. 77846

Concerns About Professionalism/Competence of Professional Staff

If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with one of the following persons:

• Director
• Associate Director/Senior Manager

You can reach the Counselling and Accessibility Services department at 416.491.5050 ext. 22900. If we cannot satisfy or address your concerns, you are entitled to bring concerns forward to our regulatory body:

The College of Psychologists of Ontario

110 Eglinton Ave. W.
Suite 500
Toronto, Ont. M4R 1A3
416.961.8817

The College of Social Workers and Social Service Workers

250 Bloor St. E.
Suite 1000
Toronto, Ont. M4W 1E6
416.972.9882

The College of Occupational Therapists of Ontario

20 Bay St.
Suite #900
Toronto, Ont. M5J 2N8
416.214.1177

Individuals have the right to contact the Information and Privacy Commissioner of Ontario about Seneca’s privacy practices or how their personal health information has been handled.

Information and Privacy Commissioner of Ontario

2 Bloor St. E.
Suite 1400
Toronto, Ont. M4W 1A8
416.326.3333
info@ipc.on.ca