Privacy Policy

The LGBTQ+ Relationship Room

Effective date: July 18, 2026

Last updated: July 18, 2026

1. Purpose

The LGBTQ+ Relationship Room is committed to protecting the privacy, confidentiality, and security of personal information, particularly regarding personal health information. This privacy policy outlines how our practice collects, uses, discloses, safeguards, retains, and provides access to information relating to:

- therapy clients and prospective clients;

- participants in couples or relationship therapy;

- individuals submitting consultation or service inquiries;

- website visitors;

- purchasers of educational resources or digital products;

- newsletter subscribers; and

- any other individuals communicating with the practice.

Personal health information under the custody or control of the practice is managed in accordance with Ontario’s Personal Health Information Protection Act, 2004, as well as applicable professional standards and other legal commitments. Other federal or provincial privacy laws may also apply to non-health information or specific commercial activities.

This website policy does not replace the practice’s Letter of Agreement, Consent for Treatment form, client intake documents, or any separate consent required for recording, transcription, AI-assisted documentation, disclosure of records, or other specific activities. Using the website or submitting a general inquiry does not automatically constitute consent to therapy or to the collection, use, or disclosure of personal health information for unrelated purposes.

2. Health Information Custodian and Privacy Contact

The LGBTQ+ Relationship Room is operated by Jace Armstrong, MSW, RSW, who serves as the practice owner, health information custodian, and privacy contact. For any privacy questions, complaints, access requests, or correction requests, please contact:

Jace Armstrong, MSW, RSW

Registered Social Worker and Psychotherapist

The LGBTQ+ Relationship Room

Ontario, Canada

Email: admin@therelationshiproom.ca

Website: www.therelationshiproom.ca

The privacy email identified above must be actively monitored. Administrative or clinical communications should be sent through the designated method indicated by the practice.

3. Information Collected

The practice collects only information that is reasonably necessary to provide services, manage the practice, meet professional and legal obligations, ensure safety, and operate the website.

Therapy and health information may include:

- name, preferred name, pronouns, date of birth, and contact details;

- emergency contact information where applicable;

- intake, assessment, consent, and accessibility data;

- relevant mental health, medical, relational, family, social, occupational, and cultural information;

- appointment, attendance, and communication records;

- clinical notes, treatment plans, assessments, and progress information;

- risk and safety details;

- medication and health provider information where clinically relevant;

- referrals, reports, and authorized communications with other providers;

- billing, invoice, receipt, insurance, and payment-related details;

- communication and technology preferences; and

- records of consent, refusal, limitations, or withdrawal of consent.

In couples or relationship therapy, a record may include information about multiple individuals. The privacy, confidentiality, consent, and access rights of all individuals involved will be carefully considered before releasing information.

Website and inquiry information collected may involve:

- information submitted via consultation, contact, newsletter, account, or order forms;

- name, email address, telephone number, and requested service;

- IP address, browser, device, security, and approximate location information;

- pages visited, referral sources, interaction data, dates, and times;

- cookie and analytics information;

- order and transaction information; and

- newsletter and marketing preferences.

It is important not to submit sensitive clinical information, therapy records, or urgent safety information through a public website form. Current clients should utilize Owl Practice secure messaging as directed for sensitive communications. Please remember that the website and practice communications are not continuously monitored. In an emergency, call 911, go to the nearest emergency department, or contact 988 in Canada if necessary.

4. Purposes for Collecting and Using Information

Information may be collected and utilized to:

- respond to inquiries and consultation requests;

- determine the appropriateness of the practice’s LGBTQ+ therapy services;

- provide, document, coordinate, and evaluate therapy;

- support the continuity, quality, and safety of care;

- obtain and document informed consent;

- schedule appointments and send reminders;

- communicate with clients and authorized third parties;

- process payments and issue invoices or insurance receipts;

- maintain accurate clinical, administrative, and business records;

- respond to access, correction, complaint, legal, insurance, or regulatory matters;

- comply with professional, legal, tax, insurance, and reporting obligations;

- shield the client, another person, the public, or the practice where legally permissible or mandated;

- operate, maintain, secure, and enhance the website;

- process orders for educational resources or digital products; and

- send newsletters or marketing communications where consent or another lawful basis exists.

Personal health information is not sold, rented, or disclosed to advertisers for independent marketing purposes, nor is clinical information used to create targeted advertising audiences or intentionally disclosed to social media platforms.

5. Consent and Client Choice

Consent will be obtained in a manner appropriate to the information, purpose, sensitivity, and circumstances. Consent may be express or implied where permitted by law. Express consent will usually be obtained for activities including:

- audio or video recording;

- transcription of therapy sessions;

- AI-assisted clinical documentation;

- disclosure of records to an external third party;

- participation by an observer;

- uses unrelated to treatment or practice administration;

- marketing communications; and

- any other activity for which express consent is legally or professionally required.

Consent may be withheld, limited, or withdrawn, subject to legal, professional, safety, record-retention, and contractual requirements. Withdrawal typically applies to future collection, use, or disclosure and does not invalidate actions that were completed lawfully prior to the withdrawal being communicated. Opting out of optional documentation technology will not impact a person's ability to receive therapy or the quality of the services provided. An alternative manual documentation method will be utilized instead.

6. AI-Assisted Documentation

The practice may utilize an approved healthcare-specific AI-assisted documentation tool to assist in preparing draft clinical notes. AI-assisted documentation will not be implemented unless:

- the specific product, account, feature, and configuration have been reviewed and approved by the practice;

- relevant vendor, privacy, security, storage, retention, deletion, model-training, subprocessor, and incident-response arrangements have been evaluated;

- clients have received a separate, current, tool-specific notice;

- prior express consent has been documented from every participant whose voice or information will be processed;

- the clinician assesses that its use is suitable for the encounter; and

- all necessary privacy and security measures are in place.

Signing a general therapy agreement, using the website, or consenting to treatment does not imply consent to AI-assisted documentation. An approved documentation tool may temporarily process session audio, a transcript, or other personal health information to create a preliminary summary or draft note.

The technology does not replace the therapist’s professional judgment, is not permitted to make independent diagnostic, treatment, eligibility, or risk decisions, may produce errors, omissions, biased wording, or incorrect speaker attribution, and is treated solely as a documentation aid rather than an authoritative clinical record. Jace Armstrong is responsible for reviewing, correcting, reducing, and approving any information that is entered into the permanent clinical record.

Recordings, temporary transcripts, rough notes, and AI-generated drafts are not automatically included in the permanent clinical record. Temporary materials will be handled according to the approved vendor arrangement, retention period, deletion protocol, and relevant backup limitations. The separate AI-Assisted Documentation Notice and Consent Form will identify the designated provider and the account-specific practices that clients need to be aware of. Until the private-practice AI documentation arrangement has completed its vendor approval, configuration, testing, and consent-form process, it will not be activated for client sessions.

7. Service Providers

The practice employs service providers to support clinical and business operations. Depending on the service and configuration, these may include:

- Owl Practice for clinical records, intake and consent forms, scheduling, secure messaging, billing, client-portal functions, and virtual care;

- payment-processing services integrated with Owl Practice;

- website hosting, domain, security, contact-form, analytics, order, and account providers;

- email and telecommunications services;

- virtual-meeting providers where specifically arranged;

- accounting, insurance, legal, or professional consultants as needed; and

- an approved AI-assisted documentation provider when separately disclosed and consented to.

Service providers are expected to process information only for authorized purposes and in line with the required contractual, privacy, and security stipulations. The practice evaluates providers proportionately, factoring in:

- purpose and necessity;

- information processed;

- processing and storage location;

- security measures and access controls;

- subcontractors and subprocessors;

- retention and deletion policies;

- use for product improvement or model training;

- incident-notification procedures;

- export and termination arrangements; and

- residual risk.

It should be noted that some website, email, telecommunications, payment, or administrative providers may process information outside of Ontario or Canada, and information processed in another jurisdiction may be subject to that jurisdiction’s laws. A provider will not be labeled as exclusively Canadian-hosted, fully anonymous, immediately deleted, or risk-free unless such claims have been verified for the exact product, plan, feature, and configuration.

8. Electronic Communication and Virtual Care

Services may involve secure video appointments, Owl Practice secure messaging, email, electronic forms, payment processing, and digital clinical-record systems. No electronic communication system can guarantee complete security. Possible risks include unauthorized access, interception or misdirection, another individual viewing a message or notification, loss or compromise of a device, malware or security incidents, internet or service-provider failure, and processing by authorized service providers.

Ordinary email and SMS should not be utilized for emergencies or overly detailed clinical information. Clients are encouraged to:

- use Owl Practice secure messaging for sensitive information where available;

- confirm recipient addresses prior to sending information;

- avoid including health information in email subject lines;

- utilize a private location and secure internet connection for virtual sessions;

- secure their devices with passwords; and

- notify the practice if there are changes in communication preferences or contact information.

Virtual sessions will not be recorded without informing every participant and obtaining separate express consent.

9. Safeguards

The practice implements reasonable administrative, technical, and physical safeguards based on the sensitivity of the information. Safeguards may encompass:

- unique accounts and access restrictions;

- multifactor authentication where applicable;

- encryption where supported;

- secure clinical and client-portal systems;

- device passwords, encryption, updates, and automatic locking;

- minimum necessary access;

- secure communication methods;

- vendor assessment and contractual safeguards;

- secure backup and disposal protocols;

- confidentiality requirements;

- incident-identification and response measures; and

- periodic reviews of policies, vendors, accounts, and access.

No safeguard can eliminate all privacy or security risks. If a privacy incident occurs, the practice will take reasonable steps to contain, investigate, document, remediate, and prevent recurrence. Affected individuals, the Information and Privacy Commissioner of Ontario, the professional regulator, or another pertinent authority will be notified when legally required.

10. Clinical Records and Retention

Clinical records are maintained for a minimum of 10 years from the date of the last entry. If the client was under 18 at the date of the last entry, the record is kept for at least 10 years from the date the client turned, or would have turned, 18. Records may be retained longer when needed or justifiably explained by:

- legislation or professional standards;

- an access or correction request;

- complaints, investigations, audits, or legal proceedings;

- a legal hold;

- insurance or contractual requirements;

- continuity-of-care needs; or

- another documented legal or professional basis.

Different retention periods may be applicable to:

- unsuccessful inquiries;

- website submissions;

- administrative correspondence;

- business and tax records;

- consent records;

- privacy incident records;

- temporary recordings;

- temporary transcripts and AI drafts;

- marketing records; and

- digital product transactions.

Temporary documentation materials will be destroyed according to the approved workflow once the finalized note has been verified and transferred unless there is a legitimate legal, professional, safety, or operational reason to preserve it. When information is eligible for destruction, reasonable measures will be enacted to make it unreadable and irretrievable. Vendor backup and deletion behaviors will be factored before information is labeled as permanently deleted.

11. Disclosure of Information

Information may be disclosed:

- with valid consent;

- to an authorized service provider acting on behalf of the practice;

- to another healthcare provider where consent or alternative lawful authority permits;

- for billing, payment processing, insurance, audit, legal, regulatory, or professional purposes;

- under a valid court order, warrant, summons, subpoena, or another lawful process;

- where permitted or required by child protection, safety, reporting, or other applicable legislation;

- when reasonably necessary to mitigate or reduce a significant risk of serious bodily harm;

- when necessary to address or defend a legal, insurance, privacy, or professional complaint or proceeding;

- to ensure practice continuity or transfer of record custody; or

- in any circumstance permitted or required by law.

Only the information reasonably necessary for the authorized purpose will be disclosed. Where legally and practically feasible, the individual will be informed before a disclosure is made. In couples or relationship therapy, one participant does not automatically hold the right to access all information concerning another participant. The nature of the joint record, applicable consents, legal rights, and the privacy of other individuals will be considered.

12. Access and Correction

Individuals may submit a written request to:

- access their personal health information held by the practice;

- receive a copy of an accessible record;

- request corrections to information they believe is inaccurate or incomplete;

- inquire how their information has been used or disclosed where relevant;

- ask questions regarding technology or AI-assisted documentation; or

- request deletion where permitted by law and professional standards.

Identity and authority will be verified before access is granted. Requests will be addressed within 30 calendar days, subject to any lawful extensions, permitted refusals, or applicable fees. Access may be limited where allowed or mandated by law, including where the record contains another person’s information or the disclosure could present a legally recognized risk. A clinical record cannot necessarily be deleted before the applicable retention period has elapsed.

Requests may be submitted to:

admin@therelationshiproom.ca

13. Website Cookies and Analytics

The website may employ essential cookies or similar technologies for purposes such as:

- security;

- navigation;

- account and order functionalities;

- form operation;

- spam prevention;

- performance; and

- basic analytics.

The website may utilize services including Google reCAPTCHA to mitigate spam and automated misuse. These services may receive technical information such as IP address, device, browser, cookie, and interaction information according to the provider’s terms. If cookie-preference controls are accessible, visitors may use them to manage non-essential technologies. Browser settings can also be employed to restrict cookies, although disabling essential cookies may impair website operation. The practice will update this policy and related consent controls before adding or materially changing advertising pixels, targeted advertising tools, or other non-essential tracking technologies.

14. Newsletters and Marketing

Newsletters and promotional messages are sent only where consent or another lawful basis exists. Recipients may unsubscribe using the link included in the communication or by contacting the practice directly. Unsubscribing from marketing does not preclude the practice from sending necessary communications to provide or administer requested services. Clinical information will not be intentionally utilized for targeted advertising.

15. Privacy Questions and Complaints

Questions, requests, and complaints should first be directed to:

Jace Armstrong, MSW, RSW

The LGBTQ+ Relationship Room

Email: admin@therelationshiproom.ca

The practice will review the concern, document it when appropriate, and respond as reasonably required. Individuals may also lodge a complaint with the Information and Privacy Commissioner of Ontario. Information regarding health-privacy complaints can be accessed through the Commissioner’s website. Telephone: 416-326-3333, Toll-free: 1-800-387-0073, Address: 2 Bloor Street East, Suite 1400, Toronto, Ontario, M4W 1A8. Individuals may also contact the Ontario College of Social Workers and Social Service Workers regarding professional conduct concerns.

16. Policy Review and Updates

This privacy policy will be reviewed at least annually and sooner following:

- a material change in practice operations;

- adoption or significant change of a technology provider;

- changes in information handling, retention, or processing location;

- a privacy or security incident;

- changes in applicable legislation or professional standards; or

- other significant governance changes.

The current version will be posted on the website along with its effective and last updated dates. Material changes will be communicated where appropriate. New consent will be obtained where a proposed new collection, use, or disclosure requires it.