Privacy Policy
1. Introduction
Little Steps Behavioural Services ("Little Steps," "we," "us," or "our") is committed to protecting the privacy of the children and families we serve, and of everyone who visits our website. This Privacy Policy explains what personal information we collect, how we use and protect it, and the choices and rights you have.
This policy covers two related things:
- Our website — information collected from visitors to thelittlesteps.ca and from people who contact us through it.
- Our services — personal information, including personal health information, that we collect when we provide assessment, therapy, coaching, and related services to children and families.
By using our website or our services, you agree to the practices described in this policy.
2. The laws that apply
We handle personal information in accordance with Canadian privacy law, including:
- The Personal Information Protection and Electronic Documents Act (PIPEDA) — the federal law governing how private-sector organizations collect, use, and disclose personal information in the course of commercial activity.
- The Personal Health Information Protection Act, 2004 (PHIPA) — the Ontario law that governs personal health information. When we provide health care services, we act in the capacity of a health information custodian under PHIPA and handle personal health information accordingly.
Where PHIPA applies to personal health information, its rules govern that information.
3. What we mean by "personal information" and "personal health information"
Personal information is information about an identifiable individual — for example, a name, email address, phone number, or IP address.
Personal health information is identifying information about an individual's health, health care, or related matters — for example, a child's developmental history, diagnosis, assessment results, therapy goals, progress notes, or information about funding for care.
Information about a child's age, development, or needs that you share with us is treated as sensitive and, where it relates to health or care, as personal health information.
4. Information we collect
4.1 Information you give us through the website
When you complete our contact or inquiry form, or otherwise reach out to us, we may collect:
- The parent's or caregiver's name
- The child's age
- Your preferred method of contact
- Your phone number and/or email address
- Any details you choose to include in your message, which may include information about your child's needs
Please share only what is necessary to start a conversation. You do not need to include detailed health information in a website message.
4.2 Information collected automatically when you visit the website
Like most websites, we automatically collect certain technical information when you browse, including your IP address, browser type, device type, operating system, the pages you view, the date and time of your visit, and the website you came from. We collect this through cookies and similar technologies (see Section 6).
4.3 Information we collect when we provide services
When a child becomes a client, we collect the personal information and personal health information needed to assess, plan, and deliver care. Depending on the services, this may include:
- Contact and identifying information for the child and for parents or guardians
- Developmental, behavioural, medical, and educational history
- Assessment results, diagnoses, and reports from other professionals (provided with your consent)
- Therapy and program records, session notes, behavioural data, and progress reports
- Information about schooling and other supports involved in your child's care
- Funding and billing information, such as Ontario Autism Program (OAP) details or private insurance information
- Communications between your family and our team
4.4 Information from other sources
With your consent, we may receive information from other people involved in your child's care — for example, physicians, schools, other therapists, or referral sources.
5. How we collect information
We collect personal information directly from you whenever possible — through the website, by phone, by email, and during consultations and sessions. We collect personal health information directly from you and your child and, with your consent, from others involved in your child's care. We collect technical website information automatically, as described above.
6. Cookies and tracking technologies
Our website uses cookies and similar technologies to function properly, to understand how visitors use the site, and to measure our advertising.
- Essential cookies make the website work — for example, our website host (Webflow) may set cookies needed for security and performance.
- Google Analytics helps us understand website traffic and how visitors use our pages so we can improve them. It uses cookies to collect information such as your approximate location, device, and activity on our site.
- Meta (Facebook) Pixel helps us measure the results of advertising — for example, our Summer Camp campaigns — and understand which ads lead people to contact us. The Meta Pixel may set cookies and share certain activity with Meta.
These tools may collect information through your browser and may process it outside Canada, including in the United States (see Section 11).
You can control cookies through your browser settings, and you can opt out of certain tracking:
- Google Analytics — install the Google Analytics Opt-out Browser Add-on.
- Meta advertising — adjust your ad preferences in your Meta account settings.
Blocking some cookies may affect how the website works.
7. How we use your information
We use personal information to:
- Respond to your inquiries and schedule consultations
- Provide, plan, and coordinate assessment, therapy, coaching, and related services
- Communicate with you about your child's care and our services
- Administer billing, funding, and insurance for services
- Operate, maintain, and improve our website
- Measure and improve our advertising and outreach
- Meet our legal, regulatory, and professional obligations
We use personal health information to provide and support health care for your child, and for related purposes permitted or required by PHIPA.
We do not sell your personal information.
8. Consent
We collect, use, and disclose personal information with your consent, except where the law permits or requires us to act without it.
- For services and personal health information. We rely on your express consent for assessment and treatment. Within your child's circle of care — the team of providers who deliver care to your child — we may rely on your implied consent to share personal health information as needed to provide that care, unless you tell us otherwise.
- Withholding or withdrawing consent. You may withhold or withdraw your consent to certain collections, uses, or disclosures at any time (sometimes called a "lockbox" under PHIPA). Withdrawing consent may affect our ability to provide some services, and we will explain any consequences. Withdrawal applies going forward and does not affect uses or disclosures the law requires.
- For website inquiries and marketing. By contacting us through the website, you consent to us using your information to respond. If we send commercial electronic messages, we will do so in accordance with Canada's Anti-Spam Legislation (CASL), and you can unsubscribe at any time.
9. Children's privacy
Our services are for children, but our website is intended for use by parents, guardians, and other adults. The website is not directed at children, and we do not knowingly collect information directly from children through the website. Information about a child is provided to us by a parent or guardian, who consents on the child's behalf. As children mature, they may have their own rights regarding their personal health information under PHIPA.
10. When we disclose information
We may share personal information in the following circumstances:
- Within your child's circle of care, with other providers involved in delivering care, as described in Section 8.
- With service providers who help us operate — for example, our website host, communication and scheduling tools, and analytics and advertising providers. They may use the information only to provide services to us.
- For funding and billing, such as with the Ontario Autism Program or your private insurer, with your consent.
- When required or permitted by law — for example, to comply with a legal obligation, a court order, or a regulatory College, or to address a risk of serious harm.
- In connection with a business reorganization, such as a sale or merger, subject to appropriate privacy protections.
We do not sell or rent personal information, and we do not use personal health information for marketing.
11. Storage and information handled outside Canada
We store records securely and limit access to those who need it. Some of our service providers — including our website host (Webflow), Google, and Meta — may store or process information on servers located outside Canada, including in the United States. When information is handled in another country, it may be subject to the laws of that country, including lawful access by government authorities. We take reasonable steps to ensure our service providers protect personal information appropriately, and we limit the personal health information shared with website and advertising tools.
12. How long we keep information
We keep personal information only as long as necessary for the purposes described in this policy, or as required by law and our professional obligations. Records of personal health information are retained for the minimum periods required by applicable legislation and professional standards, and are securely destroyed when no longer needed. Website analytics data is retained according to the settings of the tools we use.
13. How we protect your information
We use reasonable physical, administrative, and technical safeguards to protect personal information against loss, theft, and unauthorized access, use, or disclosure. These include limiting access to those who need it, secure storage, and confidentiality expectations for our team. No method of transmission over the internet is completely secure, so we encourage you not to send sensitive health details through the website's contact form.
If a privacy breach affecting personal health information occurs, we will notify affected individuals at the first reasonable opportunity and meet our reporting obligations under PHIPA.
14. Your rights and choices
You have the right to:
- Access the personal information and personal health information we hold about you and your child, subject to limited legal exceptions
- Ask us to correct information that is inaccurate or incomplete
- Withdraw consent, subject to legal and contractual limits and reasonable notice
- Ask questions or raise concerns about how we handle your information
To make a request, contact our Privacy Contact (Section 15). We may need to verify your identity and your authority to make the request (for example, as the parent or guardian). We will respond within the timeframes required by law; access to personal health information is generally provided within 30 days, subject to PHIPA.
15. Privacy Contact
If you have questions, requests, or concerns about your privacy, or you would like to access or correct your information, please contact our Privacy Contact:
Recha SoodLittle Steps Behavioural Services104-3319 Sheppard Avenue East, Toronto, ON M1T 3K2info@thelittlesteps.ca+1 647 606 9687
16. Complaints
If you have raised a concern with us and are not satisfied with our response, you may contact:
- For personal health information — the Information and Privacy Commissioner of Ontario (IPC): www.ipc.on.ca
- For other personal information — the Office of the Privacy Commissioner of Canada (OPC): www.priv.gc.ca
17. Other websites
Our website and our ads may link to other websites we do not control. This policy does not apply to those sites. We encourage you to review the privacy policy of any website you visit.
18. Changes to this policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top shows when it was last revised. Material changes will be posted on this page, and your continued use of our website or services after an update means you accept the revised policy.
19. Contact us
Little Steps Behavioural Services104-3319 Sheppard Avenue East, Toronto, ON M1T 3K2 (Scarborough — near Warden & Sheppard)+1 647 606 9687info@thelittlesteps.ca