Language & Privacy Policies
The Canadian Register of Health Service Psychologists (CRHSP) strives to maintain comparable content on its English (www.crhsp.ca) and French (www.rcposs.ca) language websites. Unfortunately, it is not always possible to obtain materials in both languages, especially with materials and links from external sources. When a translation is not available, the content in its original language is posted on both the English and French websites.
If there is a notation that a translation is “in preparation”, the translated content will be posted as soon as it becomes available.
Canadian Register of Health Service Psychologists
Adopted by the Board of Directors September 19, 2020 – Updated September 22, 2021
The Canadian Register of Health Service Psychologists (CRHSP) is a national credentialing body. It credentials health service psychologists who meet its eligibility criteria. A primary objective is to facilitate public and third party identification and access to qualified health service psychologists. It does so in part through the publication of a Directory that is published as an electronic online searchable Directory.
Subject to the provisions described below (in the sections “What is Personal Information?” and “How Is Information Collected?”) regarding public access to information in the Directory, CRHSP is committed to maintaining high standards of confidentiality with respect to the Personal Information provided to us. This Policy Statement has been prepared to affirm our practice of maintaining the privacy of our Registrants and others as well as to inform you of our practices concerning the collection, use and disclosure of Personal Information and information about Registrants provided to CRHSP.
For purposes of this Policy, “Registrant” means an individual psychologist who has been admitted to the Register or who seeks admission to the Register.
Our obligations apply to all Officers, Board members, Executive Committee members, Admissions Committee members, Web Master, employees, contractors and agents who provide services to or on behalf of CRHSP related to our products and services.
If you have questions about (i) access to your Personal Information; (ii) our collection, use, management, or disclosure of Personal Information; or (iii) this Policy, please contact the Office Administrator at [email protected], P.O. Box 91570, RPO Mer Bleu, Ottawa, Ontario K1W 0A6. Tel: 613-824-1940. The Office Administrator serves as CRHSP’s Privacy Officer.
What is Personal Information?
We consider “Personal Information” to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than information provided by Registrants for publication in the Directory.
How is Information Collected?
CRHSP has established an administrative agreement with the National Register of Health Service Psychologists (NR) which is headquartered in Washington, DC, USA. In addition to their CRHSP credential, Canadian Registrants are enrolled in an additional category of membership with the National Register entitled the “National Register – Canadian Register” category of membership. This will begin in 2021. The NR has operational management of all related Registrant functions and service provision to Canadian Registrants. Such management includes but is not limited to maintenance of CRHSP Registrant enrollment, as well as development and implementation of administrative functions supporting this category. The CRHSP registrant database is held on the NR IT platform maintained principally at the NR head office in Washington, DC, USA.
CRHSP and the NR will continue as independent legal entities; each organization will be governed by separate Boards of Directors. The role of the NR is the operational management of the CRHSP credential and the administration of the NR-CR credential.
At the time of admission and annually thereafter, Registrants complete a “Registrant Information Questionnaire” (RIQ). The completed RIQ provides information on the Registrant’s highest academic degree in Psychology, Licensure with provincial / territorial regulatory bodies of Psychology, areas of practice and practice related supplementary information. This information is published in the Directory unless the Registrant has requested that only their name be listed in the Directory (see below for how this occurs).The RIQ also provides the Registrant’s preferred mailing address, home address and telephone number, and the civil address, telephone and fax numbers, email address and web site for each distinct practice setting the Registrant requests be listed in the Directory. Home address and telephone number are considered “Personal Information” and are not listed in the Directory unless the Registrant has so requested by virtue of this also being a practice setting to be included in the Directory.
Purely demographic information (e.g., age, gender) is not published and is considered “Personal Information”. It may be used as aggregate data.
As part of the eligibility review and admissions process, each regulatory body of psychology with which the Registrant has licensure is contacted to verify their status in the particular jurisdiction. Once admission has been attained, regulatory bodies are asked to periodically verify that Registrants from their jurisdiction continue to hold licensure that enable them to practice Psychology autonomously.
How May Registrants Limit the Information Collected by the RIQ?
Any Registrant may request that only their name be published in the Directory. Such requests apply to all media in which the Directory is published. The RIQ provides for this option.
Registrants may also request a voluntary interruption of their listing in the Directory for a period not to exceed three years. Such a request should be submitted to the Office Administrator.
Why CRHSP Collects Personal Information
CRHSP collects various information, including Personal Information about Registrants, provided in writing (including electronic means) or verbally, to fulfill its objectives and purposes. This includes:
Developing statistical and equivalent profiles to
- assist Health Human Resource planning with the federal, provincial and territorial governments or with other professional bodies of Psychology and other health professions.
- assist its own recruitment and retention activities and otherwise manage our relationship with Registrants.
- communicate with and determine the needs of its Registrants.
- meet any legal or regulatory requirement. In particular, CRHSP responds to inquiries from regulatory bodies wishing to verify that information about a Registrant’s practice as stated in the Directory was provided to CRHSP by the Registrant.
CRHSP permits suppliers whose products and services have been deemed by CRHSP to be pertinent to health service psychologists to communicate information about their products and services to Registrants. This may include receiving a fee for Registrants’ published addresses.
CRHSP facilitates or participates in research that will advance health care and Psychology. Personal Information is only provided in this context on an aggregate basis. Registrants may also be asked to participate in research activities. This may include providing Registrants’ published addresses to external researchers whose scientific work has been deemed pertinent to CRHSP’s objectives and purposes.
How May Registrants Prevent Their Name and Published Addresses From Being Communicated to Suppliers and External Researchers?
At any time, a Registrant may request the Office Administrator to delete their name and published addresses from any set of Registrants’ names and addresses provided to suppliers and external researchers. At the time of payment of the annual renewal fee and submission of the annual RIQ, Registrants are reminded that they make such a request.
How CRHSP Uses Personal Information
CRHSP only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances. We use only fair and lawful methods to collect Personal Information. Our use of Personal Information is limited to the purposes described in this Policy.
When CRHSP May Disclose Your Personal Information
As a general rule, all Personal Information concerning a Registrant is held in confidence. Except in limited circumstances, it is not revealed to anyone unless expressly or implicitly authorized by the Registrant. As noted above, CRHSP leases the published name and address to approved suppliers and this may also be provided to approved researchers.
Where CRHSP discloses Personal Information to organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes of providing services to the person concerned or CRHSP and to have appropriate safeguards for the protection of Personal Information.
It should be noted that there are circumstances where the use and / or disclosure of Personal Information may be justified or permitted or where CRHSP is obliged to disclose information without consent. These circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency, or other governmental tribunal;
- Where CRHSP believes, on reasonable grounds, that it is necessary to protect the rights, privacy, safety, or property of an identifiable person or group;
- Where it is necessary to establish or collect fees;
- Where it is necessary to permit CRHSP to pursue available remedies or limit any damages that CRHSP may sustain;
- Where the information is public.
When obliged or permitted to disclose information without consent, CRHSP will not disclose more information than is required.
Unless permitted by law, no Personal Information is collected or disclosed without first obtaining the consent of the Registrant or other individual concerned. However, we may seek consent to use and disclose Personal Information after it has been collected in those instances where CRHSP wishes to use the information for a purpose not identified in this Policy, or not previously identified, or for which the Registrant or other individual has not previously consented.
The procedure by which a Registrant may withdraw their consent to have their published name and addresses provided to suppliers and external researchers is described above. Other individuals may withdraw their consent to disclosure of Personal Information by communicating such a request to the Office Administrator. However, CRHSP shall be deemed to have acted in good faith and incur no liability when Personal Information has been disclosed with consent prior to the subsequent withdrawal of such consent.
Accuracy and Retention of Personal Information
CRHSP seeks to ensure that Personal Information provided by Registrants and maintained in its data base is accurate and current as well as complete for the purposes for which it uses the information. Within a reasonable time, it corrects errors or changes in information that are brought to its attention.
The complete records of former Registrants are retained for three years. However, no attempt is made to update these records. They are retained only for archival purposes and to facilitate requests for re-admission. They may be used for historical research. In this instance, Personal Information is only analysed or reported on an aggregate basis.
CRHSP currently holds all records including Personal Information and all other information about Registrants in its office in the City of Ottawa. These records are held in a combination of hard copy files and an electronic data base.
Protection of Personal Information
Access to Your Published Information and to Your Personal Information
Published information may be reviewed at any time. It may be found by consulting the online searchable Directory via the CRHSP web site at www.findapsychologist.ca
CRHSP permits the reasonable right of access and review of non-published Personal Information held by CRHSP about a Registrant. It will seek to provide the information in question within a reasonable time. Where information will not or cannot be disclosed, the Registrant will be provided with the reasons for the non-disclosure. Requests for access or questions about this aspect of the policy and procedures should be addressed to the Office Administrator.
CRHSP’s Web Site and Electronic Communications
A visitor to the CRHSP web site is not required to provide individually identifiable information. In order to access and use Registrant-only components of the site, Registrants may need to provide certain Personal Information. This is only used to provide information and services to Registrants.
Information is collected when an individual completes an on-line application for admission, an electronic renewal, or an on-line survey. The information is collected, used and disclosed in a manner consistent with this Policy Statement.
CRHSP periodically communicates via email to those Registrants who have provided a currently valid email address. This may occur during the annual renewal process, by dissemination of the electronic version of its newsletter, through the provision of educational information to enhance the professional competence of Registrants, through announcements of certain services and products (e.g., dates and location of workshops, availability of practice enhancement products), and through invitations to participate in surveys (e.g., to assist CRHSP in its strategic planning).
Products and Services
Registrants and third parties may need to provide Personal Information when purchasing products and services provided by CRHSP or by CRHSP and its partners. This may include:
- Corporate identification information
- Personal identification information
- Financial Information (e.g., purchase order numbers or any other payment information for billing purposes)
- Delivery information
This information is held by CRHSP only for internal purposes.
Consumers of CRHSP products and services may request the information held about them in connection with their purchases of such products and services. It would only be disclosed if required to do so by pertinent provisions found in this Policy above (section on “When CRHSP May Disclose Your Personal Information”). Requests to access by consumers of CRHSP products and services will be treated similarly to requests identified above (section on “Access to Your Published Information and to Your Personal Information”) and should be submitted to the Office Administrator.
CRHSP does not provide products and services to the public-at-large other than the information provided in its Directory and on its Web Site.
Review and Revision of This Policy
This statement is in effect as of October 1, 2020 following approval by the Board of Directors. It is intended to comply with the ‘Personal Information and Protection of Electronic Documents Act’ (PIPEDA) of the Government of Canada. It will be reviewed from time to time and revised as may be indicated to reflect evolving privacy practices, and / or changes in legislation, and / or judicial decisions on matters related to PIPEDA or privacy practices, and / or CRHSP’s desire to enhance its services to the public, third parties and Registrants. Should revisions occur, a notice will be posted on the CRHSP web site and published in appropriate CRHSP publications.