top of page

Privacy Policy

Effective date: May 1st 2026

Third Space OT · Gurleen Dhaliwal, OT Reg. (Ont.) · COTO #G2112572

1. Who we are and why this policy exists
Third Space OT is a private occupational therapy practice operated by Gurleen Dhaliwal, OT Reg. (Ont.). As a regulated health professional and Health Information Custodian under Ontario’s Personal Health Information Protection Act (PHIPA), Gurleen Dhaliwal is responsible for the privacy and security of all personal health information collected in the course of providing occupational therapy services.
This Privacy Policy explains what information we collect, how we use and protect it, and your rights as a client.


2. What information we collect
We collect personal and health information that is necessary to provide occupational therapy services, including:

  • Contact information (name, address, phone number, email address)

  • Date of birth and demographic information

  • Health history, diagnosis, medications, and relevant medical records

  • Occupational therapy assessment findings, treatment notes, and progress records

  • Insurance information and billing records

  • Emergency contact information

  • Information provided through intake forms, discovery calls, and sessions

We collect only the minimum information necessary for the purpose for which it is collected.


3. How we collect your information

Information is collected directly from you through:

  • Online intake forms completed through JaneApp

  • Virtual or in-person sessions

  • Email, phone, or written communication

  • Referrals from other healthcare providers (with your consent)

​

4. How we use your information
Your personal health information is used to:

  • Provide and coordinate your occupational therapy care

  • Communicate with you about appointments, billing, and your treatment

  • Process payment and issue insurance receipts

  • Fulfill legal and professional obligations under COTO standards and PHIPA

  • Communicate with other healthcare providers involved in your care, with your consent

  • Write reports for insurers, employers, or legal purposes, with your written consent

 

5. How we store and protect your information
All personal health information is stored and managed through JaneApp, a Canadian Electronic Medical Records platform that is compliant with PHIPA and uses industry-standard encryption. Your records are stored on Canadian servers.


Paper records, if any, are stored in a locked, secure location and are not accessible to unauthorized individuals.
We retain client records for a minimum of 10 years from the date of last service, or as required by COTO standards and applicable law. For clients who were minors at the time of service, records are retained for 10 years following the date the client reached the age of majority.


6. Who we share your information with
We do not sell, rent, or share your personal health information with third parties for commercial purposes. Your information may be shared only in the following circumstances:

  • With other healthcare providers directly involved in your care, with your explicit consent

  • With insurers, employers, or legal representatives, with your written consent

  • As required by law (e.g., mandatory reporting obligations, court order)

  • In a medical emergency where disclosure is necessary to prevent serious harm

You have the right to withdraw consent for information sharing at any time, except where disclosure is required by law.
 

7. Your rights
As a client of Third Space OT, you have the right to:

  • Access your personal health information held by Third Space OT

  • Request corrections to your records if you believe information is inaccurate or incomplete

  • Withdraw consent for the collection, use, or disclosure of your information (subject to legal limitations)

  • Ask questions about how your information is being used

  • File a complaint with the Information and Privacy Commissioner of Ontario (IPC) if you believe your privacy rights have been violated

To exercise any of these rights, please contact us at thirdspaceot@gmail.com. We will respond within 30 days.


8. Telehealth and virtual sessions
Virtual sessions are conducted via JaneApp’s built-in video platform, which is encrypted and PHIPA-compliant. We do not use non-compliant platforms such as regular FaceTime, standard Zoom, or WhatsApp for clinical sessions.
Clients accessing virtual sessions are responsible for ensuring they are in a private location during sessions. Third Space OT cannot guarantee the privacy of your home environment.


9. Website and communications
The Third Space OT website may collect non-identifiable information such as browser type and pages visited through standard analytics tools. This information is used to improve the website and is not linked to any personal health information.


Email is not a fully secure method of communication. Please do not send sensitive health information by email. Use the secure JaneApp client portal for intake forms and clinical documentation.


10. Contact and complaints
If you have questions about this Privacy Policy or concerns about how your information has been handled, please contact:
Gurleen Dhaliwal, OT Reg. (Ont.)
Third Space OT · thirdspaceot@gmail.com


If your concern is not resolved to your satisfaction, you may contact:
Information and Privacy Commissioner of Ontario (IPC) · www.ipc.on.ca · 1-800-387-0073
College of Occupational Therapists of Ontario (COTO) · www.coto.org · 1-800-890-6570


11. Changes to this policy
Third Space OT may update this Privacy Policy from time to time. Updated versions will be posted on the website with a revised effective date. We will notify active clients of material changes by email.

bottom of page