Calgary Couples Counselling Centre (or CCCC) is a private practice in Calgary, Alberta, Canada. It is operated by Dr. Nathan Cobb, who is a Registered Psychologist and a Registered Marriage and Family Therapist with a Ph.D. in Marriage and Family Therapy.
Calgarycouplescounselling.com is the official website of CCCC. Throughout the remainder of this document, calgarycouplescounselling.com will be referred to as simply “our website”. Privacy is in important principle in all operations of CCCC and its official website. Every effort is taken to safeguard the privacy of individuals in the collection, use, storage, and disclosure of personal information. This document: a) describes the privacy policy of CCCC and its official website, and b) outlines the types of personal information we receive and collect, as well as the steps we take to safeguard information so that you can make an informed decision about sharing personal information with us. CCCC strives to maintain the highest standards of decency, fairness and integrity in all our operations, including the protection of privacy of our therapy clients, customers and visitors to our website.
Personal information refers to information about an identifiable individual. Personal information includes information that relates to an individual’s personal characteristics (e.g., name, date of birth, home address and telephone number), health (e.g., presenting problem, health history, health services received by the individual, social situation) or activities, views and opinions (e.g., opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
The primary purpose that CCCC obtains personal information is to provide psychological assessment, counselling and consulting services to individuals, couples, and families in a responsible and professional manner. For example, information may be collected about a client’s health history, family history, physical and psychological condition, and social situation to help assess what their needs are, advise them of their treatment options and help them to receive the treatment they choose.
It would be rare for CCCC to collect such information without the client’s express consent, but this might occur in an emergency (e.g., the client is unconscious) or where it is believed the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from a client and there is no reason to believe that the message is not genuine).
A secondary purpose of obtaining personal information by CCCC is to establish a baseline of health and social information. This allows identification of changes occurring over time as part of the provision of psychological services.
A third purpose is to advise the general public (or previous and ongoing clients) of special events, resources or services, such as seminars or new services in development, that are available through CCCC, and to make such services or resources accessible to the public. Only that personal information necessary for this purpose is collected. (For example, a first name and email address would be the only required information for a newsletter subscription. No other personal information would be necessary to receive free newsletters.)
A related purpose is to advise the general public (or previous and ongoing clients) of resources that are independent of CCCC. Previous or ongoing clients have previously given consent to receive such information.
A fourth purpose for collecting personal information is to invoice clients of CCCC for services that were not paid for at the time of the visit, to process credit card payments, or to collect on unpaid accounts.
A fifth purpose is to advise clients that their service should be reviewed (e.g., to ensure the service is still relevant to their needs). Individuals associated with CCCC will contact you only: a) in response to a question or suggestion initiated by you, b) in accordance with your prior consent to be contacted, (i.e. to complete feedback evaluations about the process of counselling, or to receive newsletters or promotions for upcoming events such as workshops, etc.), or c) as necessary to conduct the normal business affairs associated with the provision of services that you have initiated (i.e. scheduling matters, collecting on overdue accounts, reminders about upcoming appointments, follow-up to services being provided, etc.).
If you choose at any time to provide personal information such as your name, contact information (i.e. email address or telephone number) or any other personal information via email, online form, paper-and-pencil format, or otherwise, be assured that this information will never be given out, sold to advertisers, or used for any purpose other than what you intend. Our website may collect and use your personal information for the following purposes:
CCCC does not collect any private, personally identifiable information about you without your knowledge. Our official website collects only the personal information you provide and only uses that information for the purpose you provided it (e.g., to respond to email, to register for a course, to subscribe to a newsletter, to provide feedback about progress, etc.). No personal information whatsoever is required or requested in order for you to access the information and services on our official website. No one accessing this website will ever be required to subscribe to any newsletters or services.
We may collect non-personally identifiable information about you whenever you interact with our website. Non-personally identifiable information may include the browser name, the type of computer and technical information about your method of connecting to our site, such as the operating system and the Internet service provider you used, and other similar information.
This website is directed to adults. It is not directed to children under the age of 16. We operate our site in compliance with current regulations. Anyone under the age of 16 must provide parental consent to use this site. We do not knowingly collect or use personally identifiable information from anyone under 16 years of age.
CCCC uses a number of consultants and agencies that may, in the course of their duties, have limited access to the personal information held by CCCC. These consultants and agencies include bookkeepers and accountants, lawyers, computer consultants, credit card companies, financial institutions, collection agencies, marketing personnel and website managers. As much as reasonably possible, CCCC restricts their access to any personal information held in confidence by CCCC, and has their assurance that they will follow appropriate privacy principles.
Personal information is collected from clients of CCCC or from members of the general public by various means including verbal exchange (i.e. over the telephone or in face-to-face meetings), paper-and-pencil forms, voicemail, email, and online forms submitted to us from our official website (i.e. order forms, contact forms, online questionnaires, etc.).
Some online feedback forms on our official website provide clients of CCCC with the opportunity to give personal information about their perceptions of the counselling experience. These forms are encrypted and use anonymous ID numbers rather than the client’s name for identification purposes. Use of these forms is voluntary and any information submitted is stored directly on our webhost’s secure server in Canada (see “Data Storage” below). These forms are also available in paper-and-pencil format if a client prefers.
Our website may collect personally identifiable information from you in a variety of ways, including, but not limited to, when you visit our site, register on the site, or fill out a form, and in connection with other activities, services, features or resources we make available on our site.
If you subscribe to our newsletter, we will ask you for your first name and your email address.
If you complete a form on our website, we will require your name and your email address, and will ask for information relevant to the purpose of the form.
If you submit content to us, we will ask for your name and email address. Details you include in your submission may personally identify you.
If you request to be notified about comments on any content you submit to us, or request to be notified when others submit content, we will require your first name and your email address.
If you purchase a product or service from us, we will collect your name, email address, billing address, and credit card number.
Our website lets you share content with your friends and followers on various social media platforms. Below are links to the privacy policies of these platforms.
You can always refuse to supply personally identifiable information and visit our site anonymously. However, it may prevent you from engaging in certain site-related activities.
If we make material changes in the collection of personally identifiable information, we will inform you by placing a notice on our site. We will use personal information received from you for internal purposes only and will not sell it or provide it to third parties.
We also collect each visitor’s IP address, which helps us combat spam and fraud. We do not use IP addresses for any other purpose.
Our website contains links to other websites that may be of interest to you. However, once you have used them to leave our site, we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide while visiting such sites. These sites are not governed by this privacy statement. Always exercise caution by reviewing the privacy statement of the website in question before continuing to use it.
A cookie is a string of information that our website stores on your computer, which your browser provides to our website each time you return to the site. We use cookies to help us identify and track visitors, their use of our website, and their website access preferences.
Our website uses Google Analytics to analyze the use of this website. Google Analytics collects demographic and interest data, and generates statistical and other information about website use, by means of cookies. These cookies are kept on your computer. We share this information with Google, which will store and use this information on its servers. Google’s privacy policy is available at https://policies.google.com/privacy.
Our website uses information from Google Analytics to track the number of visits to the website, browsers and operating systems. No personally identifiable information is obtained from these cookies. We use the information that Google Analytics generates relating to our website to create reports about the use of the site. These reports allow us to update the site and improve your usage of it.
If you do not wish your data to be collected via Google Analytics, you can install its opt-out browser extension or add-on at https://tools.google.com/dlpage/gaoptout.
We receive an affiliate commission for some of the products and services sold on our website.
The affiliate service platform we use is Amazon.
By clicking on a product or service link, you consent to that platform’s use of cookies, as outlined in the links below.
Our website uses retargeting ads, which require the setting of cookies in your browser.
Our website uses Facebook pixels to determine the effectiveness of some Facebook ad campaigns. You can change your Facebook ad settings here.
You can set your browser to accept or refuse all cookies automatically, or notify you when a cookie is being requested. Taking this action should not cause a problem with the continued use of our site. Consult the Help section of your browser for guidance on how to refuse all cookies or to notify you when a cookie is requested.
If you choose to refuse our website’s cookies, you may not be able to fully experience the interactive features of the site.
CCCC will not reveal your personal information to any other person or agency without your written permission, with some exceptions to this policy which are outlined below. Before exchanging any information with a third party, you will be consulted first about what information is to be exchanged.
Many of our clients consist of multiple family members who are working with a therapist at CCCC as a group or unit (i.e. spouses and partners in couple’s therapy, family members in family therapy). In such cases, the “client” is considered to be the group or unit. No information obtained from multiple family members in that unit may be released to an outside party without the prior written consent of each person from whom the information was obtained, unless: 1) a different agreement has been established ahead of time and documentation of such an agreement is attached to the client(s)’ file, or 2) information about the non-consenting party can be entirely removed from the information that is shared.
As part of the assessment phase of therapy or as otherwise indicated, if you and one or more persons are seeking therapy or consultation at CCCC as a unit, your therapist may request to meet with each of you on an individual basis for one or more sessions. You may also decide to share with your therapist in person, over the telephone, or through any other media, information to which other family members who are in therapy with you are not privy. In either of these cases, unless all clients have collectively made a different agreement ahead of time with their therapist and documentation of such an agreement is attached to the file, the therapist is free to use his or her clinical judgment to decide whether, when and how to incorporate information that has been shared with him or her by one member of the group into therapy sessions with the group as a whole. In other words, disclosure of such information by the therapist to others who are in therapy with you as a group is not considered a breach of confidentiality.
There are certain situations which may require CCCC to disclose your personal information in accordance with ethical and legal requirements and standard business practices.
First, when the cost of goods or services provided by CCCC to clients is paid for by third parties (e.g., WSIB, private insurers, EAP companies, etc.), these third party payers often have your consent or legislative authority to direct CCCC to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
Second, in cases where a person is subject to a foreseeable and imminent risk of bodily harm or death, a duty exists to protect the safety of such person(s). This means CCCC may need to disclose confidential information to appropriate authorities or individuals who can intervene on behalf of the person(s) at risk. The person(s) at risk may be a client of CCCC or may be someone associated with the client who is at imminent risk of bodily harm or death because of a client’s actions.
Third, as it is required by law to notify the appropriate authorities about child abuse/neglect or elder abuse/neglect. This includes cooperating with government agencies, such as Child Protective Services, who are conducting an investigation regarding abuse or neglect of a specific child or children.
Fourth, confidential client records can be subpoenaed by a court of law.
Fifth, there are exceptions that apply to personal information disclosed by minors. Parents or legal guardians of a minor have right of access to information about their dependent during provision of services. There are exceptions to this rule (i.e. such as in the case of mature minors or when all parties agree ahead of time to the confidentiality of information disclosed) that are to be discussed on a case-by-case basis, as applicable.
Sixth, in the unlikely event of a client’s account becoming 120 days past due or in the event of a dispute over a financial transaction, limited information may be shared with financial or legal agencies connected with the business of CCCC (i.e. credit card companies, collection agencies, etc.) as necessary to resolve such disputes or to collect on unpaid accounts. In such cases, any personal information disclosed is limited to only that which is necessary to resolve the dispute or to settle the account (i.e. dates, transaction amounts, etc.) and does not include any clinical information.
Finally, professional activities of CCCC’s therapists are regulated by the College of Alberta Psychologists who may inspect records and interview staff as part of their regulatory activities in the public interest. External regulators have their own strict privacy obligations. Sometimes these reports may include personal information about clients, or other individuals to support the concern (e.g., improper services). In addition, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review files and interview staff as a part of their mandates. In these circumstances, therapists of CCCC may also consult with other professionals (e.g., lawyers, accountants) who will investigate the matter and report back to CCCC.
If we sell CCCC and its official website, then the information we have obtained from you through your voluntary participation in our services or on our website may transfer to the new owner as a part of the sale so that the service provided to you may continue. In that event, you will receive notice through our website of that change in control and practices, and we will make reasonable efforts to ensure that the purchaser honors any opt-out requests you might make.
If you choose to refuse our website’s cookies, you may not be able to fully experience the interactive features of the site.
Paper information is either under supervision or secured in a locked or restricted area.
Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords and encryption keys are used on electronic devices. In addition, passwords are used on computers. Encryption keys are used on wireless access terminals.
Paper information is transmitted in sealed, addressed envelopes or boxes by reputable companies (e.g., Canada Post).
Where possible, electronic information is transmitted either through a direct line or is anonymized or encrypted. Email is not utilized to transmit personal information unless it can be encrypted, or unless it is requested by a client who has given consent to its use, or unless it is sent in response to a direct question or concern emailed to CCCC. In the latter case, great care is still taken to transmit only personal information that is necessary to the request and to consider more secure means of communicating highly sensitive information.
Electronic information is stored on secure computer hardware and is password protected.
Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this privacy policy.
Personally identifiable information and non-personally identifiable information collected by our official website is stored on our host’s servers. That host is SiteSell Inc., located at 1000 Saint-Jean Boulevard, Suite 702, Pointe-Claire, QC H9R 5P1 Canada.
Some information is collected by third-party services. These services include:
CCCC retains personal information for some time to ensure that any questions you might have about the services provided can be addressed and to ensure that CCCC remains accountable to external regulatory bodies.
CCCC is required to keep client files for ten years following the client’s last contact or if the client was less than eighteen years of age at the time of the last contact, for ten years following the day the client would have become eighteen.
Any personal information relating to general correspondence (i.e., with people who are not clients), such as newsletters, seminars and marketing activities are kept for about six months after the newsletter ceases publication, or after an individual terminates their subscription to a newsletter (i.e. seminar participants are given the opportunity to voluntarily join a mailing list for newsletters) or after a seminar or marketing activity is over. However, an individual’s contact information will be destroyed immediately if asked.
Paper files containing personal information are destroyed by shredding. Electronic files containing personal information are destroyed by deleting them. When the hardware is discarded, the hard drive is physically destroyed.
We provide this privacy policy as a statement to you of our commitment to protect your personally identifiable information. It is the policy of CCCC that clients have a legal and moral right to know what information is contained about them in their record. Clients shall have access to information which can be identified as pertaining to them (and only them) and which is stored in the client record, with the exception of information that is believed to be harmful or that is confidential about or from third parties. CCCC will need to confirm the client’s identity and legal right to have access to the information. In some cases, this may include requiring identification and/or proof that a legal designate has legal authority to make decisions on behalf of a client. CCCC reserves the right to charge a nominal fee for such requests.
Clients may be asked to put their request for access to information in writing. If it is not possible to give clients access to their record, they will be notified within 30 days if at all possible, and provided with the reason, as much as possible, as to why they cannot be given access.
If you believe there is a mistake in the information about you that CCCC has on file, you have the right to ask for this information to be corrected. This applies to factual information and not to any professional opinions that your therapist may have formed. You may be asked to provide documentation that our files are wrong. If changed, a statement of changed information is included in the record and anyone to whom we sent this information will be notified of the change. If the request for a change is declined, you may file a notice of disagreement in the record.
If you have submitted personally identifiable information through our website and would like to download and review that information, click on this link.
You can also request to edit or delete any of your information from the servers by clicking on this link.
Date of Last Policy Update: August 17, 2021
If you do not agree to our privacy policy as posted here on this website, please do not consent to the setting of cookies and the collection and storage of your personally identifiable information.
Your explicit consent indicates acceptance of this privacy policy in its entirety.
For more information about our privacy policies and procedures, please contact Dr. Nathan Cobb at:
200C Haddon Road SW
Calgary, AB T2V 2Y6
Telephone: 403-879-8323
Fax: 403-255-8570
If you wish to make a formal complaint about our privacy practices, you may make it in writing to Dr. Nathan Cobb. He will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
If you have a concern about the professionalism or competence of our services we would ask that you discuss your concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to the regulatory body, the College of Alberta Psychologists.
This policy is made under the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out in this privacy policy.
This policy will go into effect on September 1, 2021. CCCC reserves the right to change the terms of this privacy policy and to make new policy provisions effective for all personal information maintained by CCCC.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street
Ottawa, Ontario
K1A 1H3
Telephone: 1-800-282-1376
Fax: 613-947-6850
www.privcom.gc.ca
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