Privacy Policy – Virtuous Circle Counselling

Virtuous Circle Counselling (“VCC,” “we,” “us,” or “our”) is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us.

VCC provides counselling, psychological, assessment, and related services to clients in multiple Canadian provinces and territories, including through virtual care. Depending on the location of the client, the services provided, and the regulated professional providing the service, different privacy legislation and professional requirements may apply.

VCC handles personal information in accordance with applicable Canadian privacy legislation, including Alberta’s Personal Information Protection Act (PIPA) where applicable, as well as applicable professional, regulatory, and legal requirements.

This Privacy Policy explains VCC’s general privacy practices in connection with our website, services, and business operations. Additional requirements concerning clinical confidentiality, informed consent, virtual care, and the provision of professional services are addressed in applicable client consent documents and professional standards.

1. INFORMATION COLLECTION AND USE

VCC collects personal information that is reasonably required to provide our services, respond to inquiries, administer our operations, and meet applicable legal and professional requirements.

Depending on how you interact with VCC, we may collect information such as:

• name, address, telephone number, email address, date of birth, and other identifying or contact information;

• appointment, scheduling, intake, and clinician-matching information;

• information you provide through our website, website forms, telephone, email, or other communications;

• billing, payment, insurance, and direct-billing information;

• information required to establish or administer a client relationship;

• information relevant to counselling, psychological, assessment, or other professional services;

• clinical information, where applicable;

• information concerning a parent, guardian, family member, emergency contact, or other person where reasonably required;

• information necessary to meet legal, professional, regulatory, insurance, or contractual requirements; and

• technical information generated through use of our website, which may include IP address, browser or device information, referring pages, pages viewed, cookies, and similar information.

VCC may collect, use, or disclose personal information for reasonable purposes including:

• responding to inquiries;

• determining whether and how VCC can provide requested services;

• matching clients with appropriate clinicians;

• scheduling and administering appointments;

• providing counselling, psychological, assessment, and related services;

• maintaining appropriate clinical and administrative records;

• communicating with clients;

• processing payments and administering insurance or direct-billing claims;

• coordinating services or care where appropriately authorized or otherwise permitted by law;

• providing appropriate clinical supervision or consultation where applicable;

• maintaining quality, safety, and continuity of services;

• administering and operating VCC;

• meeting professional, regulatory, insurance, contractual, accounting, and legal requirements;

• protecting clients, clinicians, VCC, or others where permitted or required by law;

• maintaining the security and functionality of our website and technology systems; and

• understanding website performance and improving our services.

Where consent is required, VCC obtains consent appropriate to the sensitivity of the information and circumstances. Consent may be express or implied where permitted by applicable law.

Individuals may withdraw consent to certain collections, uses, or disclosures, subject to reasonable notice and any applicable legal, professional, regulatory, or contractual restrictions. Withdrawal of consent may affect VCC’s ability to provide certain services.

VCC does not sell personal or clinical information.

VCC may use third-party service providers to perform services on our behalf. Personal information is provided to such providers only as reasonably necessary for the services they perform or as otherwise permitted or required by law.

2. SECURITY, SAFEGUARDS AND RETENTION

VCC recognizes that counselling and psychological information can be highly sensitive. We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of personal information under our control.

Safeguards may include access controls and authentication, confidentiality obligations, secure practice-management systems, encryption or secure transmission technologies where appropriate, cybersecurity protections, secure storage, privacy and security procedures, staff and contractor education, vendor management, and secure destruction practices.

Access to personal information is limited to clinicians, employees, contractors, service providers, and other authorized persons who reasonably require access for legitimate purposes.

VCC retains personal information for as long as reasonably necessary to fulfill the purposes for which it was collected and to meet applicable legal, professional, regulatory, insurance, accounting, contractual, or business requirements.

Clinical records may be subject to specific retention requirements established by legislation or the professional standards applicable to the regulated professional responsible for the record.

When personal information is no longer reasonably required and there is no applicable legal or professional requirement to retain it, VCC takes reasonable steps to securely destroy, delete, or anonymize it.

No electronic system or method of transmission can be guaranteed to be completely secure. While VCC takes reasonable measures appropriate to the sensitivity of the information and risks involved, absolute security cannot be guaranteed.

3. WEBSITE ANALYTICS, COOKIES AND ONLINE TECHNOLOGIES

VCC’s website may use cookies, analytics tools, tags, pixels, and similar technologies to operate and secure the website, understand how visitors use it, measure performance, and improve our website and services.

Depending on the technologies enabled, information collected may include IP address, browser and device information, referring website, pages viewed, interactions with the website, and date or time information.

VCC may use third-party providers, including Google services, for analytics, measurement, advertising-related measurement, or website functionality.

VCC does not intend for general website analytics technologies to receive the contents of confidential clinical records.

Where applicable, users may be provided with choices concerning non-essential cookies or similar technologies. Browser settings may also allow users to restrict or delete certain cookies, although doing so may affect website functionality.

Individuals should avoid entering unnecessary sensitive clinical, financial, or other confidential information into general website forms or ordinary email.

4. CHILDREN AND MINORS

VCC provides services to children and adolescents. Personal information relating to minors is handled in accordance with applicable privacy legislation, professional requirements, and VCC’s applicable informed-consent processes.

5. SERVICE PROVIDERS AND PROCESSING OF INFORMATION OUTSIDE CANADA

VCC uses third-party technology and service providers to support our website and business operations. These may include providers supporting website hosting, practice management and electronic records, payment processing, insurance and direct billing, communications, information technology, analytics, cybersecurity, accounting, legal services, and other operational functions.

Some VCC service providers, infrastructure, personnel, or subprocessors may be located outside Canada.

VCC’s website is hosted using infrastructure located in the United States. Information submitted through or generated through use of the website may therefore be processed, transmitted, accessed, or stored in the United States.

Information submitted through website forms, including contact, inquiry, intake, or clinician-matching forms, may be processed, transmitted, accessed, or stored through website infrastructure located in the United States.

VCC uses its U.S.-based website hosting provider for purposes that may include hosting and delivering the VCC website, maintaining website infrastructure, security, backups, technical support, and related website operations.

Other service providers used by VCC may also process or store information outside Canada. The countries and purposes involved may vary depending on the particular service.

Personal information processed outside Canada may be subject to the laws of the jurisdiction in which it is processed or stored and may be accessible to courts, governments, law-enforcement agencies, or regulatory authorities in accordance with applicable law.

VCC takes reasonable steps appropriate to the sensitivity of the information to protect personal information handled by service providers, including contractual, administrative, technical, and organizational safeguards where appropriate.

Individuals may contact VCC’s Privacy Officer for further information about VCC’s policies and practices concerning service providers outside Canada.

The location of VCC’s website hosting infrastructure does not necessarily reflect the storage location of VCC’s clinical records. Different systems and service providers may be used for clinical records and other VCC operations.

6. DISCLOSURE OF PERSONAL INFORMATION AND COMPLIANCE WITH LAW

VCC does not disclose personal information to third parties except with appropriate consent or where disclosure is otherwise authorized or required by applicable law.

Depending on the circumstances and jurisdiction, VCC may be permitted or required to disclose personal information without consent, including:

• where disclosure is required by law;

• pursuant to a valid court order, warrant, subpoena, or other lawful process;

• circumstances involving child protection or another statutory reporting requirement;

• an emergency or serious threat to health or safety where disclosure is authorized by law;

• an investigation or proceeding where disclosure is legally authorized;

• prevention, detection, or investigation of fraud or unlawful activity;

• collection of a debt where permitted by law; or

• another circumstance expressly permitted or required by applicable legislation.

VCC assesses requests for disclosure according to the circumstances, applicable law, professional obligations, and the sensitivity of the information.

VCC does not provide government agencies, law enforcement, private parties, family members, employers, insurers, or other third parties with unrestricted access to client information merely upon request.

Where appropriate and legally permitted, VCC seeks to limit disclosure to information reasonably necessary for the authorized purpose.

7. CHANGES TO OUR PRIVACY PRACTICES

VCC may revise this Privacy Policy from time to time to reflect changes in our services, technology, service providers, privacy practices, professional obligations, or applicable law.

The current version will be posted on the VCC website and will identify the date on which it was last updated.

Where appropriate, material changes may also be communicated through additional means.

8. ACCESSING AND CORRECTING PERSONAL INFORMATION

Subject to applicable legislation and permitted exceptions, individuals may request access to personal information about themselves that is in VCC’s custody or control. 

Individuals may also request correction of personal information where they believe there is an error or omission.

Access is not absolute. VCC may be required or permitted to withhold certain information where applicable law provides an exception, including circumstances involving another person’s personal information or other legally protected information.

Formal requests for access or correction should be made in writing to VCC’s Privacy Officer.

VCC will respond to access and correction requests in accordance with the requirements and timelines established by applicable legislation.

9. CLINICAL PRIVACY, CONFIDENTIALITY AND PRIVACY INCIDENTS

VCC recognizes that counselling, psychological, assessment, and other clinical information is highly sensitive personal information and applies safeguards appropriate to its sensitivity.

Clinical information is collected, used, accessed, retained, and disclosed in accordance with applicable privacy legislation, professional requirements, consent arrangements, and other legal obligations.

Additional information regarding clinical confidentiality, informed consent, limits of confidentiality, virtual care, and other matters specific to professional services is addressed through VCC’s applicable client consent documents.

VCC maintains processes for responding to actual or suspected privacy and security incidents. Where an incident involving personal information occurs, VCC will take reasonable steps to investigate, contain, assess, and respond to the incident, including providing notification where required by applicable privacy legislation.

10. PRIVACY OFFICER, QUESTIONS AND COMPLAINTS

Virtuous Circle Counselling has designated a Privacy Officer responsible for overseeing VCC’s privacy practices and responding to privacy-related inquiries and concerns.

Individuals may contact our Privacy Officer with questions about this Privacy Policy, requests to access or correct personal information, questions about the use of service providers outside Canada, or concerns about how their personal information has been handled.

Privacy Officer
Virtuous Circle Counselling
4838 Richard Rd SW, Suite 300
Calgary, Alberta T3E 6L1
Telephone: 403-797-0660
Email: [email protected]

VCC will review privacy concerns and complaints and respond in accordance with applicable privacy legislation.

Individuals may also have the right to contact the federal or provincial privacy commissioner or other regulatory authority having jurisdiction over their personal information.

This Privacy Policy provides general information about VCC’s privacy practices. It does not replace specific informed-consent requirements, professional standards, contractual obligations, or legislation applicable to a particular clinician, service, client, or jurisdiction.