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Privacy Policy

Your health information is private, and I am legally responsible for protecting it. As a Naturopathic Doctor registered with the College of Naturopaths of Ontario, I am the health information custodian of your records under Ontario's Personal Health Information Protection Act, 2004 (PHIPA). This statement explains what I collect, why, where it is kept, who can see it, and how you can access or correct it.

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Effective date: Nov 11 2026

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Privacy Officer: Dr. Courtney Holmberg, ND — 111-955 Queen St W, Toronto, ON, M6J3X5 — [647-351-7282] — [info@courtneyholmbergnd.ca]

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What I collect

I collect only the information I need to care for you. This may include:

  • Contact and identity details: name, date of birth, address, phone, email, emergency contact.

  • Health history: current concerns, medical and family history, medications, supplements, allergies, lifestyle and diet.

  • Clinical records: assessment findings, diagnoses, treatment plans, visit notes, and products prescribed or dispensed.

  • Test results: lab requisitions and results I order, and reports you or other providers share with me.

  • Billing details: appointments, fees, payments, receipts, and insurance information you ask me to use.

  • Communications: emails, messages and forms you send me.

If you are a parent or substitute decision-maker, I also collect your contact details and your relationship to the patient.

 

Why I collect it

I use your information to:

  1. Assess, diagnose, treat and follow up on your health concerns.

  2. Book appointments and send reminders.

  3. Bill you and, at your request, your insurer.

  4. Coordinate care with other providers you are seeing.

  5. Improve the quality of my practice.

  6. Meet legal and professional obligations, including College of Naturopaths of Ontario record-keeping standards.

 

Your consent. By booking and receiving care, you consent to my collecting and using your information for these purposes. I will get your express consent — written or verbal, and noted in your file — before sharing your information with anyone outside your care team, such as an insurer, lawyer or employer.

You may withdraw or limit your consent at any time, including asking me not to share certain information with other providers. I will tell you if this could affect your care. Withdrawal does not apply to information already shared or to disclosures the law requires.

 

Where it's stored

Your records are kept electronically in Jane App, the practice-management system I use for booking, charting and billing. Jane stores Canadian clinic data in Canada, in Amazon Web Services data centres in Montreal and Calgary. Data is encrypted in transit and at rest, and backed up daily.

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I protect your information by:

  • Using password-protected, access-controlled accounts with an audit log of who views or changes records.

  • Keeping any paper documents in a locked location and never leaving them unattended.

  • Requiring any service provider who handles your information on my behalf to protect it as PHIPA requires. I remain accountable for it.

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How long I keep it. I keep records for at least 10 years after your last visit. For patients under 18, I keep them at least 10 years after their 18th birthday. After that, records are securely destroyed.

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Who can see it

I do not sell, rent or trade your information. Access is limited to:

  • Me, as your naturopathic doctor.

  • Staff or agents acting for me (for example, an administrative assistant or a covering ND), only as needed for their role and bound by confidentiality.

  • Service providers that run the systems I use, such as Jane App, under privacy and security obligations.

  • Other providers in your care, such as your family doctor or a lab, when needed for your care and only with your written consent. You can ask me not to share with a specific provider.

  • People you authorize, such as an insurer, lawyer or family member, with your express consent.

 

When the law requires or permits it, I may disclose information without consent. Examples include a court order or subpoena, a College of Naturopaths of Ontario request, reporting a child in need of protection, reportable diseases to public health, or preventing a significant risk of serious harm.

 

Accessing or correcting your records

You have the right to see and get a copy of your health record, including lab results.

In Jane App. Log in to your Jane account to view your appointments, receipts, intake forms and any chart entries or documents I have shared with you. You can update your contact details in your profile at any time.

To request your full record:

  1. Ask me in person, by phone or by email, or send a written request to the Privacy Officer above.

  2. I may ask you to confirm your identity.

  3. I will respond within 30 days. If I need more time, I will tell you why, as PHIPA allows.

  4. I may share records through your Jane account, by secure electronic copy, or on paper.

 

I may charge a reasonable fee to cover the cost of preparing and sending copies. I will not withhold your records because a fee is unpaid. In rare cases the law allows access to be limited, for example if it could cause serious harm. If so, I will explain why in writing.

To correct your record: If you believe something is inaccurate or incomplete, contact me in writing. I will respond within 30 days. If I don't agree to the change, I will explain why and you may add a statement of disagreement to your file.

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Email, website and privacy breaches

Email and messages. Email is convenient but not fully secure. If you contact me by email, I will treat it as consent to reply that way, unless you ask otherwise. Please don't send urgent health concerns by email.

Website. My website may collect basic, non-identifying visit data (such as pages viewed) to improve the site. Online booking is handled securely through Jane App.

If a breach happens. If your information is lost, stolen or accessed without authorization, I will notify you as soon as possible. Where PHIPA requires, I will also report it to the Information and Privacy Commissioner of Ontario.

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Questions or complaints

Contact my Privacy Officer first (details at the top of this page). If you are not satisfied, you may complain to the Information and Privacy Commissioner of Ontario: 1-800-387-0073, www.ipc.on.ca.

This policy may be updated. The current version is always posted here.

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