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Privacy Policy

Safer Spaces: An Intersectional Therapy Collective and the clinicians who provide Client Services (the “Therapist(s)”) are committed to protecting the privacy and confidentiality of the personal health information they hold on behalf of clients. In this Privacy Policy, “you”, “your” and “client” or “clients” refers to the users of Safer Spaces' services.

Each Therapist who provides care to clients registered through Safer Spaces is a health information custodian (“Health Information Custodian”) under Ontario’s health privacy legislation, the PHIPA. In this Policy, “we” and “our” refers to the Therapists, and Safer Spaces acting as their agent. To that end, in order to fulfill their privacy obligations as Health Information Custodians, the Therapists and Safer Spaces have entered into a legal agreement to make Safer Spaces an agent of the Therapists under PHIPA. As an agent of the Therapists, Safer Spaces has a variety of roles, including acting as privacy officer for each of the Therapists, and for running the overall privacy program on their behalf. Safer Spaces is also a custodian of personal information and subject to the Protection of Personal Information and Electronic Documents Act in respect of personal information that it collects from Clients that does not relate to Client Services.

Safer Spaces, on behalf of the Therapists, has also contracted with a third-party vendor, Jane Software Inc. (the “Jane App”), as an electronic medical record (“EMR”) and virtual care platform service provider to support the Therapists and house client information. To be clear, the Jane App is an agent and electronic services provider to each Therapist and each Therapist has appointed Psychotherapy Collective as its PHIPA agent. For more information on the Jane App’s privacy practices, please see the Jane App’s Privacy Policy. Psychotherapy Collective assumes a central role in privacy training for Therapists and their agents in relation to the work done through Safer Spaces 

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