Privacy Policy and Notice of Information Practices

Last updated: July 27, 2026

Creative Minds Therapy Music and Arts Centre (“Creative Minds,” “we,” “us” or “our”) is committed to protecting the privacy and confidentiality of the personal information and personal health information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, retain and protect information when you:

Visit creativemindstherapy.ca
Contact us by telephone, email or website form
Request information about our services
Register for a program or appointment
Receive services from Creative Minds

Our privacy practices are guided by applicable Canadian and Ontario privacy legislation, including the Personal Health Information Protection Act, 2004 (PHIPA) and, where applicable, the Personal Information Protection and Electronic Documents Act (PIPEDA).

Scope of This Policy

This policy applies to:

Visitors to the Creative Minds website
Prospective, current and former clients
Parents, caregivers and substitute decision-makers
Individuals who contact or communicate with us
Individuals who register for programs, workshops or communications
Other individuals whose personal information is provided to Creative Minds

Clients may receive additional consent forms and privacy information during the intake process. If there is a difference between this website policy and a client’s formal service agreement or consent documents, the formal client documents will govern the therapeutic service.

Information We May Collect

The information we collect depends on how you interact with Creative Minds.

Website and inquiry information

When you visit our website or contact us, we may collect:

Your name
Email address
Telephone number
Preferred method of contact
Information included in an inquiry
The service or program in which you are interested
Information about a child or youth provided by a parent or caregiver
Appointment or consultation requests
Communication preferences
Technical information such as IP address, browser type, device type and website activity

Please do not include detailed or highly sensitive personal health information in a general website form, ordinary email or social media message.

Client and personal health information

If you or your child proceeds with services, Creative Minds or the practitioner responsible for the client’s care may collect information necessary to provide safe and appropriate services, including:

Name and contact information
Date of birth and pronouns
Parent, caregiver or substitute decision-maker information
Emergency contact information
Relevant health, developmental, educational, social and family history
Reasons for seeking services
Assessment and treatment information
Individual goals, progress notes and service plans
Referral information
Communications relating to services
Appointment and attendance information
Billing, payment and insurance information
Records required by law or professional standards

We aim to collect only the information reasonably necessary for the identified purpose.

Children and Youth

Creative Minds provides services to children, youth and families. Information about a child or young person may be collected from the individual, a parent, caregiver, substitute decision-maker, referring professional or another authorized source.

Consent is based on an individual’s capacity to understand the relevant information and the consequences of a decision, rather than age alone. Consent, confidentiality, parental or caregiver involvement and access to records will be discussed during intake and managed according to applicable Ontario law and the practitioner’s professional obligations.

When a child or youth is capable of making their own privacy and treatment decisions, their choices regarding the collection, use and disclosure of their information will be respected, subject to applicable legal and professional exceptions.

How We Use Information

Creative Minds may use personal information and personal health information to:

Respond to questions and inquiries
Determine whether our services may be appropriate
Match prospective clients with an appropriate practitioner
Schedule and manage appointments
Provide assessments, therapy and related services
Develop and review individualized goals and service plans
Communicate with clients, parents, caregivers and authorized individuals
Coordinate services with other professionals when authorized or permitted by law
Process payments, provide receipts and administer accounts
Maintain clinical and business records
Support client safety and respond to emergencies
Improve our services and website
Meet legal, regulatory, insurance and professional obligations
Send newsletters or promotional communications when consent has been provided

We will not use personal health information for an unrelated purpose without obtaining consent unless the use is permitted or required by law.

Consent

We collect, use and disclose personal information with consent, except where permitted or required by law.

Consent may be express or implied depending on the circumstances, the sensitivity of the information and the purpose for which it is being handled. Express consent may be provided verbally, electronically or in writing.

You may withdraw or limit your consent by contacting Creative Minds or the practitioner responsible for your record. A withdrawal of consent will not apply retroactively and may affect our ability to provide certain services. We will explain any relevant consequences before acting on the request.

Health Information Custodian

Depending on the practitioner’s professional role and working arrangement, Creative Minds and/or the practitioner providing the service may be the health information custodian responsible for the client’s clinical record under PHIPA.

The health information custodian responsible for a client’s record will be identified during the intake and informed-consent process.

Team members, administrative personnel and service providers who handle personal health information on behalf of a health information custodian are required to access and use it only as authorized and for legitimate purposes.

When Information May Be Shared

Creative Minds does not sell or rent personal information or personal health information.

Information may be shared:

With the individual’s consent
With parents, caregivers, substitute decision-makers or other individuals authorized by the client
With professionals involved in the client’s care when authorized or otherwise permitted by law
With service providers that support scheduling, communications, records, virtual appointments, payment processing, website hosting or business operations
When required by a court order, warrant, subpoena or other valid legal process
When required by a regulatory college or professional body acting within its authority
When reasonably necessary to reduce or eliminate a significant risk of serious bodily harm
When child-protection, mandatory-reporting or other legal obligations apply
In other circumstances permitted or required by law

Only the information reasonably necessary for the applicable purpose will be disclosed.

Service Providers

Creative Minds may use third-party providers to support its clinical, administrative and website operations. These services may include:

Website hosting and maintenance
Online inquiry forms
Appointment scheduling
Electronic health records
Virtual-session platforms
Email and telephone services
Payment processing
Data backup and storage
Website analytics
Accounting and administrative support

These providers are given access only to information required to perform their services. We take reasonable steps to select providers that maintain appropriate privacy and security safeguards.

Some providers may store or process information outside Ontario or Canada. When information is stored or processed in another jurisdiction, it may be subject to the laws of that jurisdiction.

Jane App

Creative Minds uses Jane App, a third-party practice-management platform, for appointment scheduling, intake forms, clinical documentation, secure messaging and virtual appointments.

Jane App is designed to support compliance with Canadian privacy requirements, including PIPEDA and Ontario’s PHIPA. Information transmitted between a user’s browser and Jane’s servers is protected with 128-bit encryption, while stored information is protected with 256-bit encryption.

Creative Minds’ Jane account is configured to store Jane data in Canadian regional data centres. Creative Minds remains responsible for using the platform and handling personal health information in accordance with applicable privacy legislation and professional obligations.

More information is available in Jane App’s Privacy Notice.

Website Analytics and Cookies

Our website may use cookies and similar technologies to support website functionality, remember visitor preferences, understand how visitors use the website and improve its performance.

Information collected through cookies or analytics may include:

IP address
Browser and device information
Approximate geographic location
Pages visited
Time spent on the website
Referring website
Links or buttons selected

This information is generally used in an aggregated form and is not intended to create a clinical record or identify an individual therapy client.

You can control or disable cookies through your browser settings. Disabling certain cookies may affect how the website functions. Where required, visitors will be given an opportunity to manage non-essential cookie preferences.

Google Analytics

We use Google Analytics to understand how visitors use our website and to help us improve its content, performance and accessibility. Google Analytics may collect information such as the pages you visit, the time spent on the website, your general geographic location, device and browser type, referring website and interactions with website features.

Google Analytics uses cookies and similar technologies to collect this information. We review the information in aggregated reports and do not use Google Analytics to collect names, contact information, health information or information submitted through our forms.

Website Forms and Email

Information submitted through an online form or ordinary email travels electronically and may carry privacy and security risks.

Please limit an initial inquiry to the information reasonably necessary for us to contact you. Do not send detailed clinical, medical or highly sensitive information through a general contact form, ordinary email or social media message.

Submitting a website form or email does not establish a therapist-client relationship. If confidential information is required, Creative Minds will provide instructions for sharing it through an appropriate method.

Email and website forms are not monitored continuously and must not be used to request emergency or crisis support.

Virtual Services

When virtual services are provided, Creative Minds and its practitioners take reasonable steps to select appropriate technology and protect client privacy. However, no internet-based communication system can be guaranteed to be completely secure.

Clients may be asked to:

Participate from a private location
Use a secure internet connection
Confirm their physical location at the beginning of an appointment
Provide current emergency contact information
Avoid recording sessions unless permission has been obtained

The privacy considerations, limitations and responsibilities associated with virtual services will be discussed during the informed-consent process.

Marketing Communications

Creative Minds may send newsletters, program announcements or other promotional electronic messages when consent has been provided or where otherwise permitted by Canada’s Anti-Spam Legislation.

You may unsubscribe at any time by selecting the unsubscribe link in an email or contacting us at info@creativemindstherapy.ca.

Administrative communications relating to an inquiry, appointment, payment or current service are not promotional communications and may still be sent when reasonably necessary.

Retention and Secure Disposal

Personal information and personal health information are retained only for as long as reasonably necessary to provide services and meet applicable legal, regulatory, insurance and professional record-keeping requirements.

Retention periods may vary according to:

The type of information or record
The practitioner’s professional designation
The nature of the service
The client’s age
Applicable legal and regulatory requirements

When information is no longer required, it is securely destroyed, deleted or anonymized according to applicable requirements.

Protecting Information

Creative Minds uses reasonable administrative, technical and physical safeguards appropriate to the sensitivity of the information. These safeguards may include:

Password-protected systems
Access controls
Secure record-management platforms
Encryption where appropriate
Privacy and confidentiality requirements
Secure storage and disposal practices
Software updates and security protections
Procedures for responding to privacy incidents

Access to personal information is limited to individuals who require it for an authorized purpose.

Although we take reasonable precautions to protect information, no electronic system, internet transmission or communication method can be guaranteed to be completely secure.

Privacy Breaches

If personal health information is lost, stolen or used or disclosed without authorization, Creative Minds or the responsible health information custodian will take reasonable steps to contain and investigate the incident.

Affected individuals will be notified at the first reasonable opportunity when required by law. The Information and Privacy Commissioner of Ontario and applicable regulatory bodies will also be notified where legally required.

Accessing or Correcting Your Information

Subject to limited legal exceptions, you may request access to personal information or personal health information held about you and ask for inaccurate or incomplete information to be corrected.

Requests may need to be submitted in writing. We may ask for information to verify your identity before providing access to a record.

In some circumstances, access may be limited or refused as permitted by law. If this occurs, the reason and available complaint options will be explained.

Requests involving a clinical record should be directed to the health information custodian identified during intake or to the Creative Minds Privacy Officer.

Privacy Questions and Complaints

Questions about this Privacy Policy, requests to access or correct personal information, or concerns about how information has been handled may be directed to:

Antonietta (Toni) Mongillo, MMT, RP, MTA
Owner and Privacy Officer
Creative Minds Therapy Music and Arts Centre
202 S Blair Street, Unit 10
Whitby, ON L1N 8X9

Phone: 905-288-7984
Email: info@creativemindstherapy.ca

We will review privacy questions and complaints and respond within a reasonable period in accordance with applicable privacy legislation and professional obligations.

If you are not satisfied with our response concerning personal health information, you may contact:

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8

Telephone: 416-326-3333
Toll-free: 1-800-387-0073
Website: www.ipc.on.ca

You may also have the right to contact the practitioner’s regulatory college or another applicable privacy authority.

External Websites

Our website may contain links to external websites or services. Creative Minds is not responsible for the privacy, security, availability or content practices of third-party websites.

We encourage visitors to review the privacy policy of every external website or service they use.

Changes to This Policy

Creative Minds may revise this Privacy Policy to reflect changes to our services, technology, information practices or legal obligations.

The updated policy will be published on this page with a revised “Last updated” date. Material changes affecting current clients will be communicated when required.