We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.

What is Personal Information?

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, home address or phone number, family status), or their health (e.g., health history, health conditions, health services received by them). 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.

Who We Are

Our organization, Limerence Centre for Sexual & Relationship Therapy, includes at the time of writing two Board Certified Clinical Sexologists and one support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, credit card companies, website managers, cleaners and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

We Collect Personal Information: Primary Purposes

About Clients:

Like all Sexologists, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide sexual and relationship therapy treatments. For example, we collect information about a client’s health history, including their family history, physical condition and function, and social situation in order to help us assess what their health needs are, to advise them of their options, and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health social information so that, in providing ongoing health services, we can identify changes that are occurring over time.

About Members of the General Public:

For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of Limerence Centre’s services in general or our clinic in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and e-mail addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.

On our website, we only collect, with the exception of cookies, the personal information you provide, and only use that information for the purpose you gave it to us (e.g., to respond to your e-mail message, to register for a course, to make an appointment, to receive copies of publications). Cookies are only used to help you navigate our website, and are not used to monitor you.

About Contract Staff, Volunteers and Students:

For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of health emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work-related performance and provide a report as authorized by them.

We Collect Personal Information: Related and Secondary Purposes

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

• To invoice clients for good or services that we were not paid for at the time, to process credit card payments, or to collect unpaid accounts.



• To advise client and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new product) that we have available.



• Our Centre reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff.



• Like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.



• The cost of some goods/services provided by Limerence Centre to clients is paid for by third parties (e.g., Blue Cross, private insurance). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.



• Clients or other individuals we deal with may have questions about our goods or services after they have been received. We also provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful. We retain our client information for a minimum of seven years after the last contact, to enable us to respond to those questions and provide these.



• If Limerence Centre or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Centre’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

Protecting Personal Information

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

• 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 are used on all computers. All of our cell phones are digital, which signals are more difficult to intercept.



• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.



• Electronic information is transmitted either through a direct line or is anonymized or encrypted.



• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties, and in accordance with our privacy policy.



• External consultants and agencies with access to personal information must enter into privacy agreements with us.

Retention and Destruction of Personal Information

We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided, and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.

We keep our client files for about seven years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence (e.g., with people who are not clients), newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or all of the client file to our clients.

You Can Look at Your Information

With only a few exceptions, you have the right to see what personal information we hold about you. Often, all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible, and tell you the reason, as best we can, as to why we cannot give you access.

Do You Have a Question?

Our Information Officer, Greg McCrea, can be reached at Limerence Centre, 190 Bronson Avenue, 2nd floor, Ottawa, Ontario K1R 6H4, and by telephone at 613-231-5708 and fax at 613-231-5814. He will attempt to answer any questions or concerns you might have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He will acknowledge receipt of your complaint, ensure that it is investigated promptly, and that you are provided with a formal decision and reason(s) in writing.

This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set our here. There are some rare exceptions to the commitments set out above.

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: