Privacy Policy
Last Updated: August 3, 2026
This Privacy Policy describes the policies and procedures of Samantha Fogel Therapy ("we," "us," or "our") regarding the collection, use, protection, and disclosure of your information when you visit our website at www.samanthafogeltherapy.ca (the "Website") or contact our practice.
We are committed to protecting your personal privacy and maintaining the confidentiality of your health information in accordance with Ontario’s Personal Health Information Protection Act, 2004 (PHIPA), the Personal Information Protection and Electronic Documents Act (PIPEDA), and the professional standards of the College of Registered Psychotherapists of Ontario (CRPO).
1. Important Notice & Crisis Disclaimer
THIS WEBSITE AND OUR CONTACT FORMS ARE NOT MONITORED 24/7 AND ARE NOT INTENDED FOR CRISIS OR EMERGENCY SUPPORT.
If you are experiencing a mental health emergency, feeling unsafe, or considering harm to yourself or others, please do not rely on website communication. Immediately:
Call or text 988 to reach the Suicide Crisis Helpline (Available 24/7 across Canada).
Call 911 or go to the nearest hospital emergency room.
Contact a local crisis centre in your community.
2. Health Information Custodian (HIC)
Under PHIPA, Samantha Fogel, RP, acts as the Health Information Custodian (HIC) and Privacy Officer for this practice. The HIC is legally responsible for ensuring that your Personal Health Information (PHI) is collected, used, stored, and disclosed securely and appropriately.
Contact Details for Privacy Inquiries:
Practice Name: Samantha Fogel Therapy
Health Information Custodian: Samantha Fogel, Registered Psychotherapist
Address: 128-82 Laird Dr, Toronto, ON M4G 3V1
3. Two Categories of Data We Collect
To protect your privacy, we strictly distinguish between general website analytics data and Personal Health Information (PHI).
Category A: Website Usage & Analytics Data
When you navigate our Website, we automatically collect non-identifiable usage data. This may include your IP address, browser type, operating system, referring URLs, pages visited, and the dates/times of your visits.
We use this data to ensure website functionality, improve performance, and measure the effectiveness of our marketing.
Tracking Technologies & Cookies
We use cookies, web beacons, and pixels to analyze traffic and measure advertising campaigns:
Essential Cookies: Necessary for website operation, security, and rendering pages correctly.
Analytics Cookies (Google Analytics): Collect aggregated browser statistics to help us understand how visitors interact with our site. You can opt out by installing the Google Analytics Opt-out Browser Add-on.
Advertising & Conversion Pixels (Google Ads & Meta Ads): Used strictly to measure whether an ad click resulted in a contact or website action.
Google Ads Safety Disclosure: In strict compliance with Google Ads policies for sensitive health categories, we do not use remarketing, retargeting lists, or custom audience lists to target visitors based on mental health interests, health conditions, or visits to our Website.
You can adjust your browser settings to refuse non-essential cookies or manage your ad preferences directly through Google Ad Settings.
Category B: Personal Health Information
Personal Health Information is identifiable information collected when you voluntarily reach out to inquire about therapy, schedule a consultation, or receive care. PHI may include:
Full name, email address, phone number, and mailing address.
Reasons for seeking therapy, brief health concerns, or clinical intake responses.
Session notes, treatment plans, billing records, and clinical correspondence created once care commences.
How PHI is Collected and Processed
Website Contact Form Links: Information submitted via our website form links are collected solely to evaluate whether we can offer appropriate clinical care, assess geographical eligibility (Ontario residents), and schedule initial consultations. We use Jane App, a secure practice management software, for this purpose.
Secure Practice Management (Jane App): Online appointment scheduling, intake forms, clinical documentation, and client portals are managed through Jane App (Jane Software Inc.). Jane App is a Canadian PHIPA-compliant electronic health record system. All client data managed via Jane App is encrypted in transit and at rest and stored on secure servers located within Canada.
4. Purpose and Limits of Collection & Disclosure
We collect and use your personal and health information for the following purposes:
Evaluating prospective clients for clinical fit and geographic jurisdiction.
Providing, planning, and managing professional psychotherapy services.
Processing payments and issuing billing receipts for insurance or tax purposes.
Meeting legal, regulatory, and ethical requirements mandated by the CRPO and Ontario law.
Limits of Confidentiality
We will never sell, rent, or trade your personal information or health records to third parties or use your clinical inquiries for external marketing. Personal Health Information is kept strictly confidential and will only be disclosed without your express consent under specific legal exceptions mandated by law, including:
Risk of Serious Harm: If there is reasonable grounds that disclosure is necessary to eliminate or reduce a significant risk of serious harm (includes physical or psychological harm) to the client or anyone else.
Court Orders & Subpoenas: Where necessary for particular legal proceedings.
Regulatory Audit: Disclosing information to a college for the purpose of administration or enforcement of the Regulated Health Professions Act, 1991..
Mandatory Reporting Obligations: Where a mandatory report is required; to report information for the purpose of preventing or responding to harm. These laws include but are not limited to the Child, Youth and Family Services Act; Long-Term Care Homes Act; Retirement Homes Act; Health Professions Procedural Code; and Personal Health Information Protection Act.
Legal Investigations & Warrants: To facilitate an investigation or inspection authorized by warrant or by any provincial or federal law.
Emergency Contact Disclosures: For the purpose of contacting a relative, friend or potential substitute decision-maker of the individual, if the individual is injured, incapacitated, or ill and unable to give consent personally.
5. Retention & Disposal of Your Data
We retain your data in accordance with statutory obligations and clinical record-keeping guidelines:
Clinical Practice Records (PHI): In compliance with CRPO regulations and Ontario health laws, complete clinical health records (including intake forms, session notes, and related client files) are retained for a minimum of 10 years from the date of the last clinical entry. For minor clients, records are retained for 10 years after the client turns 18 years of age.
General Inquiries (Non-Clients): Voluntary consultation inquiries from individuals who do not ultimately initiate therapy services are securely deleted or anonymized within 24 months.
Financial & Billing Records: Transaction details, invoices, and payment history are retained for up to 7 years to satisfy Canada Revenue Agency (CRA) tax compliance requirements.
Website Analytics Data: Aggregated web usage data and analytics cookies are retained for up to 24 months.
Upon expiration of the mandatory retention periods, physical and digital files are permanently and securely destroyed or anonymized in accordance with PHIPA standards.
6. Security & Third-Party Service Providers
We utilize commercial, technical, and administrative safeguards to protect your personal information against loss, theft, and unauthorized access:
Third-Party Vendors: We partner only with third-party service providers who comply with Canadian privacy legislation (PHIPA/PIPEDA) and maintain industry-standard administrative, physical, and technical controls.
Payment Processing: Payment processing is integrated securely through Jane App and PCI-DSS compliant payment gateways. Credit card numbers are never stored directly on our website servers.
Email & Unencrypted Transmission Warning: While our booking systems use end-to-end encryption, standard unencrypted email and basic website contact forms carry inherent security risks. We encourage you to limit sensitive clinical details submitted through initial website contact form links and email.
Virtual Care & Telehealth Safeguards
If you participate in video or audio psychotherapy sessions (telehealth), sessions are conducted using secure, end-to-end encrypted technology that complies with Ontario’s PHIPA regulations and Canadian health data standards.
Platform Security: Virtual video appointments are delivered via Jane App (Jane Software Inc.), a PHIPA-compliant telehealth platform. Video streams are encrypted in transit, hosted on Canadian servers, and are never recorded or stored by our practice.
Client Privacy Responsibilities: To protect your own confidentiality during telehealth sessions, you are responsible for joining appointments from a secure, private location and using a secure, private internet connection (avoiding public or shared Wi-Fi networks).
7. Your Privacy Rights Under PHIPA
As an individual receiving health care services in Ontario, you have rights regarding your Personal Health Information:
Right of Access: You have the right to request access to your personal health record held by our practice, subject to limited legal exceptions under PHIPA.
Right to Correction: You may request corrections to your personal health information if you demonstrate that the record is inaccurate or incomplete for the purposes for which it was collected.
Right to Withdraw Consent: You may withdraw or alter your consent for the collection, use, or disclosure of your PHI at any time, subject to legal or contractual restrictions and reasonable notice.
8. Questions and Regulatory Complaints
If you have questions, concerns, or wish to exercise your privacy rights, please contact our Health Information Custodian directly at connect@samanthafogeltherapy.ca.
If you believe your privacy rights under PHIPA have been breached and we have not resolved your concern to your satisfaction, you have the right to file a formal complaint with the Information and Privacy Commissioner of Ontario (IPC):
Information and Privacy Commissioner of Ontario
Address: 2 Bloor Street East, Suite 1400, Toronto, Ontario M4W 1A8
Telephone: (416) 326-3333 | Toll-Free: 1-800-387-0073
Website: www.ipc.on.ca
9. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy periodically to reflect changes in our legal obligations, regulatory requirements, or technology. Any changes will be posted on this page with an updated "Last Updated" date.