HopeStart Mental Health Inc. – Privacy Policy

Effective Date: November 30, 2025
Last Reviewed: January 31, 2026

HopeStart Mental Health Inc. (“HopeStart,” “we,” “us,” or “our”) is committed to protecting the privacy, confidentiality, and security of the personal information and personal health information of the individuals and families we support.

This Privacy Policy explains how we collect, use, disclose, retain, and safeguard personal information and personal health information through our website, communication systems, and service platforms.

By accessing our website or engaging with our services, you consent to the practices described in this Privacy Policy.

1. Who We Are

HopeStart Mental Health Inc. is a community-based organization providing employment-focused services, including:

  • Psychotherapy services provided by qualified and regulated practitioners

  • Occupational therapy assessments and functional supports

  • Job coaching and workplace transition supports

  • Service coordination and employment-focused planning

HopeStart operates in Ontario and complies with applicable privacy legislation, including:

  • Personal Health Information Protection Act (PHIPA)

  • Personal Information Protection and Electronic Documents Act (PIPEDA)

  • Other applicable provincial and federal privacy laws

HopeStart Mental Health Inc. is the Health Information Custodian (HIC) for all personal health information collected through its services.

We collect only the information necessary to provide safe, coordinated, ethical, and effective services.

2. Information We Collect

a) Information Collected Through Our Website

When you visit our website or submit a form, we may collect:

  • Name, email address, and phone number

  • Information voluntarily submitted through contact, referral, or inquiry forms

  • Application information if you apply for subcontractor or employment opportunities

b) Personal Information for Service Delivery

If you inquire about or receive services, we may collect:

  • Name, preferred name, and pronouns

  • Contact information and emergency contacts

  • Demographic information (where relevant)

  • Scheduling preferences

  • Funding information (e.g., Passport funding, insurance details, Employment Ontario referrals)

c) Personal Health Information (PHI)

When services involve psychotherapy, occupational therapy, job coaching, or coordinated supports, we may collect:

  • Diagnostic or developmental information (where relevant)

  • Mental health and substance-related information

  • Functional assessments and employment-related barriers

  • Safety planning and activation information

  • Names and roles of involved caregivers or professionals (with consent)

  • Service plans, progress notes, assessments, and documentation

All PHI is stored electronically in Owl Practice, a PHIPA-compliant electronic practice management system hosted on Canadian servers. No physical client files are maintained.

d) Automatically Collected Website Information

Our website hosting provider, Squarespace, may automatically collect limited technical data such as:

  • IP address

  • Browser and device type

  • Pages visited and time spent on the site

  • General usage analytics

This information is used only to support website functionality and performance. We do not use website data for advertising or profiling.

3. How We Use Information

We use personal information and personal health information to:

  • Deliver psychotherapy, occupational therapy, job coaching, and service coordination

  • Schedule appointments and communicate service updates

  • Develop, document, and review service plans

  • Coordinate care with consented supports and professionals

  • Process billing, invoicing, insurance documentation, and Passport funding records

  • Respond to inquiries and referrals

  • Recruit and onboard subcontractors

  • Maintain regulatory, legal, and professional obligations

  • Improve service quality and website functionality

We do not sell, rent, or trade personal information.

4. How We Store and Protect Information

a) Owl Practice (Electronic Health Record System)

HopeStart uses Owl Practice for all client records and documentation. Safeguards include:

  • PHIPA-compliant Canadian data storage

  • Encryption in transit and at rest

  • Role-based access controls

  • Audit logs and activity tracking

  • Secure client portal messaging

  • Regular data backups and redundancy

b) Website Hosting – Squarespace

Squarespace hosts our website and may store limited form submissions and analytics data in accordance with its privacy practices.

c) Email – Google Workspace

HopeStart uses Google Workspace for business email and document management.

While Google Workspace is a secure, enterprise-grade platform, email communication is not fully secure. Clients are encouraged not to include sensitive personal health information via email and to use the secure Owl Practice portal where possible.

d) Additional Safeguards

HopeStart employs administrative, technical, and physical safeguards including:

  • Password-protected systems

  • Encrypted devices

  • Multi-factor authentication where available

  • Confidentiality agreements with staff and subcontractors

  • Limited access based on role and need-to-know

5. Disclosure of Information

a) With Consent

With appropriate consent, information may be shared with:

  • Family members or caregivers

  • Healthcare or community professionals

  • Employers (where relevant and consented)

  • Funding bodies (e.g., Passport funding administrators)

Consent may be withdrawn at any time, subject to legal limitations.

b) Without Consent (Legal Exceptions)

HopeStart may disclose information without consent when required or permitted by law, including:

  • Risk of serious harm to the individual or others

  • Child protection concerns

  • Serious risk to a vulnerable adult in a care setting

  • Court orders, subpoenas, or warrants

  • Legal or regulatory reporting obligations

Only the minimum necessary information will be disclosed.

6. Third-Party Service Providers

HopeStart uses trusted third-party service providers, including:

  • Owl Practice (client records, scheduling, billing, secure portal)

  • Squarespace (website hosting)

  • Google Workspace (email and document management)

These providers process information on HopeStart’s behalf and are contractually required to safeguard privacy. They are not permitted to use information for their own purposes.

7. Passport, Insurance, and Employment Ontario Funding

If you choose to use external funding sources:

  • Invoices and receipts may include your name, service dates, and hours

  • No unnecessary clinical information is included

  • Records may be shared with you or your authorized representative

  • HopeStart does not communicate directly with funders unless consent is provided

8. Retention of Information

HopeStart retains personal information and PHI in accordance with:

  • PHIPA requirements

  • Regulatory college standards

  • Legal and professional obligations

Information is securely retained and disposed of when no longer required.

9. Your Privacy Rights

You have the right to:

  • Access your personal information and PHI

  • Request corrections to inaccurate information

  • Withdraw or modify consent

  • Request limits on disclosure

  • Ask questions about privacy practices

  • File a privacy complaint or concern

Requests may be subject to legal exceptions.

10. Cookies and Analytics

Squarespace uses cookies to support:

  • Website functionality

  • Performance and analytics

HopeStart does not use cookies for advertising, tracking, or behavioural profiling.

11. External Links

Our website may contain links to third-party websites. HopeStart is not responsible for the privacy practices or content of external sites.

12. Children and Youth

HopeStart does not knowingly collect personal information directly from children under the age of 16 through its website without parental or guardian involvement.

13. Privacy Breach Management

In the event of a privacy breach involving personal health information, HopeStart will:

  • Contain and assess the breach

  • Notify affected individuals where required

  • Comply with PHIPA breach reporting obligations

  • Take steps to prevent recurrence

14. Changes to This Policy

This Privacy Policy may be updated periodically. The Effective Date will reflect the most recent revision.

15. Contact Information

For questions, access requests, or privacy concerns, please contact:

Privacy Officer
HopeStart Mental Health Inc.
Email: matthew@hopestartmentalhealth.ca
Phone: 365-357-2827
Location: Cambridge, Ontario