Policies

The services of the CSDC are available to all Toronto Metropolitan University full and part-time undergraduate and graduate students who are eligible to proceed in their program and not on academic leave. It should be noted that Continuing Education and Special Students have limited access to counselling.

We respect the concerns that you may have about the privacy of the material that you share with your counsellor. This information will be held in strictest confidence and no one outside the Centre for Student Development and Counselling, will have access to information about you without your signed consent. In some situations, however, we may need to be in contact with your health care providers or, in some cases, with professional staff of the Academic Accommodation Support in order to establish a circle of care and provide you with coordinated services. In these circumstances, and in accordance with Ontario’s Personal Health Information Protection Act, we would share with your care giver(s) only such information as is necessary for your assessment or treatment - unless you expressly request that we not share specific information with a particular care giver.

There are six exceptions to this agreement for which we might need to breach confidentiality:

1. If you intend to harm yourself.
2. If you intend to harm another person.
3. If you or your counsellor has a strong reason to think that a Toronto Metropolitan University Community member may be at risk of harm based on information that you provided in your session.
4. If there is a reasonable suspicion that a child (any individual up to their 16th birthday) is at risk of emotional and/or physical neglect or emotional, physical and/or sexual abuse. We are required by law to report this to the Children’s Aid Society immediately.
5. If you are involved in a court case and the judge thinks that counselling is relevant to the case, your file might be subpoenaed.
6. If you have a complaint about a regulated health professional (e.g., doctor, nurse, psychologist, chiropractor,  massage therapist...) with respect to their inappropriate sexual behaviour towards you, and you provide us with that individual’s name, we are required to report this complaint to their regulatory body.

In cases requiring crisis intervention, counsellors may adopt a team approach to help ensure the provision of the highest quality care.

Statement of Confidentiality and Privacy Principles

This document explains how Student Health and Wellness at Toronto Metropolitan University collects, uses, and discloses your Personal Health Information. Please read it carefully. This statement was last modified in April 2019. 

Who is accountable?

Student Health and Wellness protects the privacy of your Personal Health Information in accordance with the Personal Health Information Protection Act (“PHIPA”) and all other applicable privacy legislation, including the Freedom of Information and Protection of Privacy Act (“FIPPA”). The Executive Director, Student Health and Wellness has overall responsibility and oversight of Student Health and Wellness’s privacy practices.

What information is collected?

Under PHIPA, “Personal Health Information” includes identifying information related to: physical or mental health of the individual; 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; payments or eligibility for health care in respect of the individual; the donation by the individual of any body part or bodily substance of the individual; health number or the identify of an individual’s substitute decision-maker.

Under FIPPA, “Personal Information” means any factual or subjective information about an identifiable individual. Such information includes the individual's name, address, sex, age, education, medical or employment history, student number, employee number, relationship status, personal opinions of, or about, the individual.

Why and how is this information collected and used?

Collecting your Personal Health Information and/or Personal Information is necessary for the following purposes:

• Providing you with assessments, counselling, treatment, referral and/or consultation services.
• Consulting with other professionals in your circle of care about your care.
• Establishing and maintaining communication with you.
• Establishing and maintaining communication, including receiving and disclosing information, with third parties for which we have received written consent from you.
• Making referral appointments for you.
• Complying with legal and/or professional requirements for information gathering.
• Compiling information and statistics for internal use, or as aggregate data in research projects approved by the relevant ethics boards, as appropriate or as required by law. 
• Compiling information for internal use (e.g., statistical summaries for annual reports or for third parties with whom you have agreed to the disclosure of information.)

Will my information ever be shared or disclosed? 

Within Your Circle of Care

To enable the best care, your Personal Health Information and/or Personal Information may be shared within your circle of care. Your “circle of care” includes the professionals involved in providing your care. For example, that may include the physician, psychologist, and counsellor you see through Student Health and Wellness. Your information may be shared between, and accessible by, the professionals within your circle of circle for the purposes outlined previously, including to provide you care and ensure continuity of care. Student Health and Wellness has an audit process in place, including technological protections, to ensure that information shared within your circle of care is only accessed for valid purposes. If you have concerns about your Personal Health Information and/or Personal Information being shared within your circle of care, please discuss your concerns with Student Health and Wellness or your healthcare professional.

Outside of Your Circle of Care

Except in the exceptional circumstances outlined below, Student Health and Wellness will not disclose your Personal Health Information and/or Personal Information outside of your circle of care without your consent and direction. If you request for Student Health and Wellness to share your information with a third-party, you will be required to sign a consent form to authorize the release of the information. A fee for copies may apply. 

Exceptional Circumstances

However, there are certain exceptional circumstances, required by law, where Student Health and Wellness may need to disclose your information without your consent. These special circumstances include:

1. If you intend to harm yourself.
2. If you intend to harm another person.
3. If you or your counsellor has a strong reason to think that a Toronto Metropolitan University Community member may be at risk of harm based on information that you provided in your session.
4. If there is a reasonable suspicion that a child (under the age of 18) is at risk of emotional and/or physical neglect or emotional, physical and/or sexual abuse. For children under the age of 16, we are required by law to report this to the Children’s Aid Society immediately.
5. If you are involved in a court case and the judge thinks that counselling is relevant to the case, your file might be subpoenaed.
6. If you have a complaint about a regulated health professional (e.g., doctor, nurse, psychologist, chiropractor,  massage therapist, etc.) with respect to their inappropriate sexual behaviour towards you, and you provide us with that individual’s name, we are required to report this complaint to their regulatory body.

How is my information stored and protected?

Information is stored securely within an Electronic Medical Record (“EMR”). Additional safeguards include two-factor authentication, etc. The EMR also includes technological protections and audit trails and activity logging to mitigate inappropriate access. While users may have the ability to access the EMRs of various clients, they are only permitted to do so with a valid purpose, as outlined above. 

To ensure that PHI is only accessed for valid purposes, the Executive Director, Student Wellbeing, is responsible for conducting regular and random audits of EHR activities and access. Regular audits will be conducted, at minimum, on a quarterly basis. At their discretion, the Executive Director, Student Wellbeing, may also conduct random and/or more frequent audits, such as in response to a privacy complaint or any other identified incident. 

How long is my information retained?

The Electronic Medical Record (“EMR”) is retained for ten (10) years after the client’s last interaction with Student Wellbeing.  If a client is under the age of 18 years old at the time of collection, the 10 year retention period begins when the client turns 18. When the EMR reaches its retention period, it will be purged from the system. Student Wellbeing may retain the EMR for a longer period, if necessary.  Clients may request their records be transferred prior to the expiry of the retention period. 

Can I access or correct my information?

Yes, it is your right to access, or seek to correct, your Personal Health Information and/or Personal Information, in accordance with the applicable legislation, such as PHIPA or FIPPA.  You may be asked to verify your identity and a fee may apply for copies. 

You also have a right to withdraw your consent for Student Wellbeing to use and disclose your Personal Health Information and/or Personal Information. You will be asked to complete a form outlining your withdrawal of consent. This cannot be applied retroactively. 

To do so, please contact:

Administrative Coordinator
Student Wellbeing
Toronto Metropolitan University
350 Victoria Street
Toronto, ON  M5B 2K3
(416) 979-5000 ext. 6652

How do I challenge compliance?

You have the right to challenge Student Wellbeing’s compliance with its Statement of Confidentiality and Privacy. 

To do so, please contact:

Executive Director 
Student Wellbeing
Toronto Metropolitan University
350 Victoria Street
Toronto, ON  M5B 2K3
(416) 979-5000 ext. 2286

When you challenge compliance, Student Wellbeing will investigate your concern. If the complaint is determined to be well-founded, Student Health and Wellness will inform you and remediate the issue. If the complaint is determined to be not well-founded, Student Health and Wellness will explain why. 

If you are not satisfied with the response of Student Wellbeing, you may escalate your concern to the University Privacy Officer:

University Privacy Officer
Office of the General Counsel and Board Secretariat
Toronto Metropolitan University
350 Victoria Street
Toronto, ON  M5B 2K3
fippa@torontomu.ca

If you are still not satisfied with the response of the University Privacy Officer, you may contact the Information and Privacy Commissioner:

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, ON  M4W 1A8
416-326-3333 or 1-800-387-0073
info@ipc.on.ca

When you miss an appointment without providing adequate notice it results in the loss of service to another student who may otherwise have been seen during that time. The Centre for Student Development and Counselling therefore asks that you notify us at least 24 hours prior to your scheduled appointment if you are unable to make it.  If the lines are busy or you are calling after regular working hours, please leave a confidential telephone message (416-979-5195) which includes your name and the date and time of the appointment being cancelled.  A fee of $20.00 will be charged for each appointment not cancelled in advance. The Registrar's Office will be advised of outstanding charges, and as with unpaid library fines, your marks will be withheld pending payment. Urgent and compelling extenuating circumstances affecting your ability to provide the required notice will be considered.

Effective February 1, 2019, the Centre for Student Development and Counselling will only accept payment in person or online.

• Payment in Person: (debit or credit)
  Payment can be made at reception in Jorgenson Hall, JOR-07, during regular business hours.
• Payment Online: (credit only)
  You will receive an email with instructions. Please note a $4 processing fee will automatically be applied.

Students requiring documentation to support a request for academic consideration or accommodation on compassionate grounds should discuss the particulars of their situation with their counsellor.  Other than in exceptional cases, such documentation will be available only to existing clients of the Centre (or to those who were clients during the time in which they experienced the personal difficulties).  Therefore, students presenting their circumstances after the fact should not normally expect letters of support.  The requested documentation will be provided at the discretion of the counsellor and usually be available within five working days.

Students are always welcome to seek the support of a counsellor in addressing personal concerns.

The Centre for Student Development and Counselling respects the needs of journalistic and academic researchers and appreciates their interest in the mental health of their peers. Student interviewers and reporters are welcome but with certain restrictions to protect the confidentiality and trust of our clients.

Interviewers must arrange a time for an interview in advance. Drop-in interviews will not be accommodated.  Please e-mail (csdc@torontomu.ca) or leave a note with our receptionist which includes your name, a number where you can be reached, and what type of information you are seeking. Your request will be circulated among the counsellors and if one of them believes that they can be of assistance to you, they will contact you to arrange an interview.

 PLEASE NOTE:

• Making a request for an interview is not a guarantee that you will receive one. During times of heavy client demand, the Centre may decline to grant interviews.
• Interviewers must clearly identify themselves as such (including at open groups and workshops run by the Centre).  Posing as a client in order to get an interview with a counsellor will be cause for immediate rejection of the student's request.
• Counsellors cannot provide "sample cases" and will not contact or solicit information from clients on behalf of an interviewer. Counsellors will not reveal information about individual clients or a Toronto Metropolitan University client population as this is a breach of confidentiality.
• Interviewers may not sit in on individual or group sessions. Endeavoring to speak with incoming, waiting, or exiting clients, including from a group session, is also not appropriate.
• In some cases, particularly where the subject matter is of a sensitive nature, counsellors may ask to review and approve the copy before it goes to press.
• Some counsellors routinely decline interviews based on past experiences of a negative nature.
• Interviews may be cancelled or halted (if in progress) if an urgent situation requiring the counsellor's attention arises. The counsellor will have no liability for cancelled or interrupted interviews. The provision of counselling services to clients supersedes any and all responsibility to the interviewer, including academic consequences.

IMPORTANT: Nothing in this policy will ever restrict a student, whether a reporter or a student doing a class assignment, from seeking counselling services now or in the future.

During the summer of 2020, Student Wellbeing will be merging our electronic health record to contribute to a more seamless and cohesive health and well-being experience for students. 

What does this mean for me as a client?
Now with your consent, Toronto Metropolitan counsellors and physicians involved in your care will see your entire health record. Previous to this merger, counsellors working in the Centre for Student Development and Counselling (CSDC) could not access your health record in the Medical Centre, nor could physicians in the Medical Centre access your health record in the CSDC. With a merged health record your healthcare providers will be able to enhance coordination of your healthcare needs and experience.

Who can access my health record? 

Only Toronto Metropolitan health professionals involved in your care or administrative staff who are required to access your record for specific reasons (ie: schedule an appointment, transfer a record with your consent, etc.) are permitted to access your record. The Student Wellbeing department has policies in place to optimize health information privacy including a regular audit to monitor who is accessing what health record.  For further information, attached is a full Student Wellbeing Statement of Confidentiality and Privacy Principles if you would like further information on how we collect, use and disclose your health information.

What if I want to access my own record?

The process to access your own health information remains the same. Please contact either the Medical Centre or the CSDC and they will walk you through the process. 

Can I opt out of this merged record?

With your consent, it will now be the regular practice to have your health record available to all of Toronto Metropolitan health professionals involved in your care. All of our Toronto Metropolitan health professional team members are members of regulatory colleges and bound to confidentiality standards and will not share your personal health information without your consent. There are multiple reasons why this could be of benefit to your care: decreased need to re-tell your story, faster access to updated health information for all Toronto Metropolitan University health professionals involved in your care, increased ability for those involved in your care to collaborate, etc. However, there is a “lockbox” option available in those rare instances where a client does not want their health information shared with other health professionals involved in their care. Please see your health care provider to discuss and address any concerns.

In order for your healthcare providers (i.e. counsellor and physician) to access your new integrated health record, we require your expressed consent and you will be asked to sign the following at your appointment.

Acknowledgment of the Statement of Confidentiality and Privacy 

By signing below, I acknowledge and confirm:

• I have reviewed the Statement of Confidentiality and Privacy of Student Health and Wellness (last modified in April 2019); 
• I understand how Student Wellbeing collects, uses, and discloses my Personal Health Information; 
• I have been offered a copy of the Statement of Confidentiality and Privacy; and,
• I am satisfied that Statement of Confidentiality and Privacy has been explained to me and that I have had the opportunity to have any questions answered.