Privacy Policy
Privacy, Confidentiality & Duty to Report
Duty to Report
At Smart Sprouts, all staff members are legally obligated to act when there are reasonable grounds to believe that a child may be experiencing abuse, neglect, or may otherwise require protection.
In accordance with Section 125 of Ontario’s Child, Youth and Family Services Act (CYFSA), any individual who has reasonable grounds to suspect that a child is in need of protection must promptly report their concerns, along with the information that supports those concerns, to a Children’s Aid Society.
Children’s Aid Societies are responsible for receiving, assessing, and investigating concerns related to child welfare and protection.
If you have concerns regarding possible child abuse or neglect, please contact your local Children’s Aid Society directly. For Durham Region, contact (905) 433-1551. Services are available 24 hours per day, 7 days per week.
Privacy & Confidentiality
Smart Sprouts values and protects the privacy of all clients and their families. We maintain safeguards and procedures designed to ensure that personal and health information is collected, used, stored, and disclosed responsibly and securely.
Our privacy practices comply with applicable legislation and professional requirements, including but not limited to:
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Ontario’s Personal Health Information Protection Act (PHIPA)
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Health Care Consent Act (HCCA)
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Standards established by the College of Psychologists and Behaviour Analysts of Ontario (CPBAO)
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Child, Youth and Family Services Act (CYFSA)
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Services and Supports to Promote the Social Inclusion of Persons with Developmental Disabilities Act
Smart Sprouts only collects and uses information that is reasonably necessary to provide services and support high-quality care.
Our policies and procedures are reviewed regularly and may be updated over time. Where changes significantly affect how personal information is collected, stored, used, or disclosed, individuals will be notified and consent will be obtained where required.
Except where permitted or required by law, written consent must be obtained before sharing personal information—whether verbally or in writing—with external individuals or service providers. With consent, or where authorized by legislation, information may also be collected from other relevant sources.
Information Security & Safeguards
All employees, volunteers, directors, contractors, and third-party service providers associated with Smart Sprouts are required to sign a confidentiality agreement at the start of their involvement and renew this commitment annually.
Confidentiality obligations continue after an individual’s relationship with Smart Sprouts ends, unless disclosure is required by law or professional duty.
Personal information may be stored electronically or in physical records.
Security measures are maintained to reflect the sensitivity of the information and include administrative, technical, and physical safeguards. Access is restricted to authorized personnel only.
How Information May Be Used
The type and extent of information used may differ depending on the service being provided and the relationship between Smart Sprouts and the individual.
Information may be used for purposes including:
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Delivering assessment, treatment, consultation, coaching, and related services
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Monitoring service quality and evaluating client satisfaction to improve programs and supports
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Meeting legal, regulatory, and professional obligations
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Sharing updates about services, programming, or events where appropriate
De-identified or anonymous information that cannot reasonably identify individuals may be used for staff training, education, quality improvement, and research activities.
Where a research project requires direct participation from clients or families, Smart Sprouts will follow applicable research standards and obtain informed consent when required.
Smart Sprouts does not disclose personal information to unrelated third parties unless consent is provided or disclosure is otherwise authorized or required by law.
With appropriate consent, information may be shared with professionals or organizations involved in a client’s care, education, or support, such as schools, hospitals, or community agencies.
Clients and families may request access to their records, request corrections to inaccurate information, or withdraw consent for certain uses or disclosures by submitting a written request to Smart Sprouts via email at SmartSproutsABA@gmail.com.
Record Retention
Health records are maintained in accordance with CPBAO record-keeping requirements.
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Adult records: retained for a minimum of ten (10) years after the last professional contact.
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Records for clients under age 18: retained for at least ten (10) years after the client reaches age 18, or ten (10) years following the final professional contact, whichever period is longer.
Following the retention period, records may be securely destroyed. Individuals who wish to obtain copies of records prior to disposal may contact Smart Sprouts in writing or by email.
Online Data Collection & Third-Party Platforms
Smart Sprouts uses secure third-party platforms and software providers to support service delivery and operations, including activities such as appointment scheduling, registration, communication, and access to training materials.
To provide these services, it may be necessary for authorized service providers to process information submitted through online forms, including Personal Information (PI) and Personal Health Information (PHI).
Smart Sprouts works only with providers that are expected to maintain appropriate privacy and security standards. These providers may access information solely for the purpose of delivering services on behalf of Smart Sprouts and are not authorized to use personal information for independent purposes such as marketing, profiling, or unrelated analytics.
Contact Our Privacy Officer
If you have any questions or concerns about the privacy of your personal information, please contact our office at 289-251-9593.
You also have the right to raise a concern to the Information and Privacy Commissioner of Ontario if you are concerned about how we have handled your personal health information.
Information and Privacy Commissioner of Ontario
Address: 2 Bloor Street East, Suite 1400 Toronto, ON M4W 1A8
Phone: 1-800-387-0073
Website: www.ipc.on.ca