Caring for Couples Counselling Center Inc.

Last updated: October 14, 2026

 

Your privacy matters, especially when you’re trusting me with something as personal as your relationship. This policy explains, in plain language, what information I collect, why, where it’s stored, who can see it, and what your rights are.

 

Who I am

Caring for Couples Counselling Center Inc. is my psychotherapy practice. I’m Brian Tohana, a Registered Psychotherapist (Qualifying) with the College of Registered Psychotherapists of Ontario (CRPO). Under Ontario’s Personal Health Information Protection Act (PHIPA), I’m the “health information custodian” for my practice. That means I’m legally responsible for protecting your personal health information, and I’m the person to contact with any privacy questions.

 

The short version

• I only collect what I need to provide my services and stay in touch with you.

• Your clinical records are stored securely in Canada and are never used for marketing.

• AI-assisted session notes are only used if you (and, in couples therapy, both partners) opt in, and you can change your mind at any time.

• I never sell or rent your information.

• For anything sensitive, please use the secure messaging in my client portal rather than email.

• You can ask to see or correct your information at any time.

 

What I collect

If you visit this website

My website platform (Wix) collects usage information through cookies and similar technologies, such as the pages you visit, your device and browser type, your approximate location and your IP address. I see this mainly as overall statistics that help me understand how the site is used. You can limit or block cookies through your browser settings.

 

If you join the waitlist

Your name, email address, and what you share about your availability and reasons for seeking therapy. I use this to contact you about availability.

 

If you subscribe to my emails

Your name and email address, plus basic information about how you interact with my emails (such as whether they’re opened). You’ll only receive these emails if you’ve opted in.

 

If you contact me

Whatever you include in your message, along with your contact details.

 

If you become a client, or apply to become one

• Contact details and basic personal information.

• Your answers to the intake form, which may include health, relationship and personal history.

• Session notes and other clinical records I’m required to keep as a regulated professional.

• Appointment, billing and payment information.

 

How I use your information

• To provide therapy, including assessing fit, scheduling, sessions and record-keeping.

• To send receipts, including receipts you can submit to your insurance provider.

• To respond to your questions and manage the waitlist and consultations.

• To send you emails you’ve subscribed to.

• To understand how my website is used, so I can improve it.

I never sell or rent your personal information, and I don’t share it with anyone for their own marketing.

 

Who else may see your information

Your information is confidential. Apart from me, the only people who may see it are:

• My clinical supervisor. As a Registered Psychotherapist (Qualifying), I practise under the clinical supervision of a qualified supervisor, and I may discuss our work with them to support the quality of your care. My supervisor is bound by the same confidentiality obligations.

• My service providers (described below), who handle information on my behalf, only as needed to provide their services, under their own security and privacy commitments.

Beyond this, I won’t share your information without your consent, except in the limited situations described under “Confidentiality and its limits.”

 

AI-assisted session notes

With your consent, I use the AI-assisted note feature built into my practice management system, Colib. It helps me focus fully on our conversation while documenting themes, patterns and progress.

• What it involves. During online sessions, the session audio is converted into a written transcript, which is then used to draft a session note.

• It’s your choice. You can opt in or out on your intake form. In couples therapy, both partners must consent before a joint session is used for AI-assisted notes.

• You can withdraw at any time (through your intake form or the AI settings in the client portal) without affecting your care. Withdrawing stops AI processing from that point on; it doesn’t delete notes already in your clinical record, which I’m required to keep.

• I review and edit every note. The AI drafts, and I remain responsible for what’s in your record. The AI doesn’t make any diagnosis or treatment decisions.

• How it’s handled. The audio is deleted as soon as the transcription is complete, and the transcript is deleted once the note has been drafted. Speech-to-text processing happens in Canada. The note-drafting step may be processed in the United States, where, according to Colib, the content isn’t stored or logged and isn’t used to train AI models.

 

Where your information is stored

Client records: Colib

I use Colib, a Canadian practice management system, for scheduling, intake forms, clinical notes, billing, secure messaging and video sessions. According to Colib:

• All client records are stored on encrypted servers in Canada (Amazon Web Services, Montreal region), with backups also kept in Canada.

• Information is encrypted both while it travels and while it’s stored, and every access or change is recorded in an audit log.

• A few supporting services operate outside Canada. Card payments are processed by Stripe in the United States: your card details go to Stripe, but your clinical information doesn’t. Colib also uses US-based services for technical error monitoring and backup text-message delivery. The AI note-drafting step is described above.

• The client portal uses Google Analytics by default to measure how the portal is used. You can decline it through the portal’s cookie banner.

 

Email: Proton Mail

My email is hosted by Proton Mail, which stores messages in encrypted form on servers in Switzerland. Emails between my account and a regular email account (like Gmail or Outlook) are usually protected in transit by standard encryption, but they aren’t end-to-end encrypted, and details like the subject line and email addresses aren’t protected in the same way. For that reason, please use the secure messaging in the Colib client portal for anything personal or sensitive, and keep email to general questions and scheduling.

 

Email subscriptions: Kit

My subscriber emails are sent through Kit (formerly ConvertKit), a US-based email platform. Your clinical information is never added to my email list.

 

Website: Wix

My website is hosted by Wix, which may store website information outside Canada, including in the United States.

 

When information is stored or processed outside Canada, it may be subject to the laws of that country.

 

Couples therapy and your records

In couples therapy, the relationship is my client, and our work together is documented in a joint record. If you have individual conversations with me as part of couples work, they form part of that couples work, as explained in the “no secrets” policy in your intake form. That policy describes how I work therapeutically; it doesn’t override your rights under privacy law.

If one partner asks for access to, or release of, the couples record, I’ll generally need the consent of both partners before sharing information that relates to the other partner. I’ll handle any such request carefully and talk it through with you.

 

Confidentiality and its limits

What you share in therapy is confidential. Apart from the people described above, I won’t share your information without your consent, except where disclosure is required or permitted by law. For example:

• When it’s reasonably necessary to reduce or eliminate a significant risk of serious bodily harm to you or to someone else.

• When a child may need protection under child protection legislation.

• When disclosure is required by a court order or other legal authority, including my regulatory college.

Whenever possible, I’ll discuss these situations with you before any information is shared, and I’ll share only what is necessary.

 

How long I keep information

• Clinical, appointment and financial records: as CRPO requires, at least 10 years from our last interaction (or, for a client under 18, 10 years from their 18th birthday, whichever is later). Records may be kept longer if required by law, for example during a legal proceeding. Once the retention period has ended, records are securely destroyed.

• Waitlist information: until you start therapy, ask to be removed, or it’s no longer needed.

• Email subscriptions: until you unsubscribe. Unsubscribing stops all future marketing emails; Kit may keep a minimal record of your unsubscribe so you aren’t added again by mistake.

• General inquiries: only as long as needed to respond and follow up.

 

If something goes wrong

If your personal health information is ever lost, stolen or accessed without authorization, I’ll let you know at the first reasonable opportunity, and I’ll notify Ontario’s Information and Privacy Commissioner when the law requires it.

 

Your rights

You have the right to:

• See your information. You can ask for access to the personal information I hold about you, including your clinical record.

• Correct it. You can ask me to correct information you believe is inaccurate or incomplete. Some things, like professional opinions made in good faith, may not be changed. If I don’t make a correction you’ve asked for, you can ask me to attach a statement of disagreement to your record.

• Withdraw consent where the law allows, including consent to AI-assisted notes.

• Unsubscribe from emails at any time, using the link in every email.

To make a request, email me or message me through the client portal. I’ll confirm your identity before releasing or changing any information, and I’ll respond within 30 days (or let you know if a lawful extension is needed).

Clinical records must be kept for the legally required period, so they can’t be deleted on request before then.

 

Concerns and complaints

If you have a concern about how your information has been handled, you’re welcome to contact me so I can try to address it. You can also contact the Information and Privacy Commissioner of Ontario directly at any time, at www.ipc.on.ca.

 

Changes to this policy

If I update this policy, I’ll change the date at the top of this page.

 

Contact

Brian Tohana, Registered Psychotherapist (Qualifying)
Caring for Couples Counselling Center Inc.
235 Carlaw Avenue, Toronto, ON M4M 2S1
(416) 660-1838
brian@caringforcouples.ca