Privacy Policy

1. Who We Are

Snow Psychology Counselling Services ("the Practice," "we," "us," "our," "me," or "my") provides individual counselling services, including outdoor walk-and-talk sessions in Calgary, Alberta and secure video counselling to clients across Canada (excluding Ontario, Quebec, British Columbia, or the Maritime provinces, where we are not currently registered to provide services). This Privacy Policy explains how we collect, use, disclose, and protect personal information, including personal health information, in the course of operating our website and our clinical practice.

This Practice is based in Alberta and handles personal information, including health information, in accordance with applicable Alberta privacy law. Where personal information moves across provincial or national borders, for example when clients located outside Alberta access our services, the federal Personal Information Protection and Electronic Documents Act (PIPEDA) also applies. We are not a "covered entity" under the United States' Health Insurance Portability and Accountability Act (HIPAA), and this policy does not claim HIPAA compliance. Where noted below, we have voluntarily adopted safeguards consistent with HIPAA's standards for handling health information.

2. The Privacy Officer

We have designated a Privacy Officer who is accountable for our compliance with this policy and applicable privacy law. You can reach our Privacy Officer at:

• •Name: Michael Snow
• •Email: snowpsychologycounselling@gmail.com

3. What Personal Information We Collect

3.1 Information you provide directly

• •Contact details: name, email address, phone number, mailing address
• •Intake and clinical information: presenting concerns, mental health and relevant medical history, risk factors, session notes, treatment plans, and other information you share during counselling
• •Billing information: payment details, insurance or benefits information used for direct billing or receipts
• •Communications: emails, messages, or voicemails you send us

3.2 Information collected automatically through our website

• •Technical data such as IP address, browser type, device information, and pages visited, collected through Google Analytics 4 and similar tools
• •Advertising and conversion data collected through Google Ads when you interact with our ads or book a consultation through our site
• •Cookies and similar technologies, described further in Section 9

4. Why We Collect It (Identifying Purposes)

Consistent with applicable Alberta and federal privacy law, we collect personal information only for purposes we identify at or before the time of collection, including to:

• •Provide, coordinate, and bill for counselling services
• •Communicate with you about appointments, invoices, and practice updates
• •Maintain clinical records as required by our professional and legal obligations
• •Operate, secure, and improve our website
• •Measure and improve the effectiveness of our advertising
• •Meet legal, regulatory, and professional College/Association obligations

5. Consent

We collect, use, and disclose personal information only with your knowledge and consent, except where the law permits or requires otherwise (for example, to prevent imminent harm). Because health information is sensitive, we obtain your express (explicit) consent, typically in writing during intake, before collecting or using it for clinical purposes.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer. Withdrawing consent may limit our ability to continue providing counselling services to you, and we will explain the implications if this applies to your situation.

6. Limits of Confidentiality

Information shared in counselling is confidential, with the following legally and ethically required exceptions, which we review with you at intake:

• •Disclosure of intent to seriously harm yourself or another identifiable person
• •Suspected abuse or neglect of a child or vulnerable adult, where reporting is legally mandated
• •A court order or other legal requirement to disclose records
• •Situations required for Canadian Counselling and Psychotherapy Association standards of practice

7. How We Disclose Personal Information

We do not sell personal information. We disclose personal information only as needed to provide services, as permitted or required by law, or with your consent, including to:

• •Jane App, our practice management and clinical records platform, which stores your clinical and health information on servers located in Canada
• •Jane App for secure video counselling sessions
• •Stripe for billing and payment processing
• •Insurance providers or benefits administrators, only with your authorization, for direct billing or claims
• •Regulatory bodies, professional associations, or legal authorities where required by law

Your clinical and health information, secure video call and transcription are all stored through Jane App, remaining on servers located in Canada and are not transferred to the United States or other foreign jurisdictions in the ordinary course of providing your counselling services.

Some non-clinical data does cross the border. Our website analytics (Google Analytics 4) and advertising tools (Google Ads) are operated by companies based in the United States, so technical and advertising data described in Sections 3.2 and 9 may be stored or processed there and could become subject to lawful access by US authorities. We select all service providers with safeguards appropriate to the sensitivity of the information involved, and enter into agreements requiring them to protect your information appropriately.

8. Data Retention

We retain clinical records for the period required by Canadian Counselling and Psychotherapy Association standards of practice and applicable Alberta law, currently 10 years from the date of last contact, or longer if required by law or an active legal matter. Website analytics and advertising data are retained according to the retention settings of Google Analytics/Ads as configured in our account. When information is no longer required, we securely destroy or anonymize it.

9. Cookies and Website Analytics

Our website uses cookies and similar technologies to operate correctly, understand how visitors use the site, and measure advertising performance. This may include Google Analytics 4 and Google Ads conversion tracking. You can control or disable cookies through your browser settings or using the button below; doing so may affect some site functionality. We do not use cookies to track your activity across unrelated third-party websites for advertising purposes beyond what is described here.

You can change your cookie choice for this site at any time:Cookie choices

10. Security Safeguards

We protect personal information, including health information, using safeguards appropriate to its sensitivity, consistent with applicable Alberta privacy law's security requirements and, where applicable, aligned with HIPAA Security Rule practices. These include:

• •Encrypted transmission and storage of clinical records
• •Access to client records limited to authorized personnel
• •Secure, PIPEDA aligned video conferencing for telehealth sessions
• •Regular review of our security practices and third-party vendor agreements

No method of transmission or storage is completely secure. If a breach occurs that creates a real risk of significant harm, we will notify affected individuals and the Office of the Information and Privacy Commissioner of Alberta (and the federal Office of the Privacy Commissioner of Canada, where PIPEDA applies) as required by law, without unreasonable delay.

11. Your Rights

Subject to limited exceptions permitted by law, you have the right to:

• •Access the personal information we hold about you
• •Request correction of inaccurate or incomplete information
• •Withdraw consent to certain uses or disclosures, as described in Section 5
• •Ask questions about our privacy practices or file a complaint

To exercise any of these rights, contact our Privacy Officer using the details in Section 2. We will respond within the timelines required by applicable privacy law, generally 30 days.

12. Children's Information

Our services are intended for adult clients and mature minor clients aged 16 and older. We do not knowingly collect personal information from children through our website without appropriate parental or guardian consent.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page reflects the most recent revision. Material changes will be communicated to active clients directly.

14. How to Reach Us or File a Complaint

If you have questions, concerns, or a complaint about how we handle your personal information, please contact our Privacy Officer first (Section 2). If you remain unsatisfied, you may contact:

• •Office of the Information and Privacy Commissioner of Alberta (OIPC) — oipc.ab.ca
• •Office of the Privacy Commissioner of Canada (for matters involving cross-provincial data) — priv.gc.ca