Our Pledge Regarding your Personal Information
Careand FamilyHealth Inc. (“Careand”, “we”, “us”,“our”)values privacy and is committed to protecting the privacy of our clients’personal information, including personal health information. This PrivacyPolicy tells you about the ways in which we collect, use, disclose andotherwise manage our client’s personal information.
“Personalinformation” means information about an identifiable individualand includes personal health information. We collect personal information aboutyou directly from you, and from your healthcare providers through theApplication and Website.
We may collectpersonal information from our clients directly, from their employers, or fromother third parties. For example, we (or our service providers or agents) maycollect: (i) name; (ii) gender; (iii) date of birth; (iv) address; (v)confidential, general or business email address; (vi) phone number; (vii)payment card information; (viii) photo; (ix) employer and employment status;(x) interests and preferences; (xi) general health concerns and your questionsand inquiries; (xii) personal and family medical history; (xiii) health cardnumber; (xiv) physician; (xv) samples; (xvi) diagnoses; (xvii) prescriptions;(xviii) referrals; (xix) treatment plans; and (xx) other relevant information,as required.
Collection, Use and Disclosure of Personal Information
We may collect,use or disclose personal information as set out below and as otherwise requiredor permitted by law. Personal information may be collected, used and disclosedbefore, during and after your visit to Careand.
Enrolment in Services:Before using the services of Careand, includingthe Application, you will need to register and provide certain personalinformation to permit us to offer our services and the Application.
Health Care Services:In general, we may collect, use and discloseyour personal information for the purposes of determining suitability for,planning, and delivering health care services, booking appointments, consultingwith health care providers, and accessing health records. In the course ofproviding these health care services, your personal information may be sharedwith health information custodians involved in your care (e.g. anotherphysician or health care practitioner, an allied health professional or memberof your clinical care team, a public hospital, pharmacy, laboratory, orambulance service), unless instructed otherwise by you.
We may also shareyour personal information for the purposes of contacting your family or asubstitute decision maker.
Payment: We may collect, use anddisclose your personal information for the purposes of facilitating payment forour services.
Internal Operations: We may collect, use anddisclose personal information for the purposes of risk management, security orotherwise to improve the quality of our services, including the evaluation andmonitoring of those services. For example, we may store all communications fortraining and quality assurance purposes. We may also conduct video recordingfor security purposes via the use of cameras located in public areas of ourclinic such as reception and clinic entrance and exit locations.
Legal and Compliance: We may disclose yourpersonal information where required or permitted by law. For example, we mayprovide your personal information in response to a search warrant or otherlegally valid inquiry or order. We may also disclose personal information forcertain proceedings and to investigate or prevent actual or suspected loss orharm to persons or property.
Research: Careand may conduct orparticipate in research and analysis, in which case your personal information,including personal health information, may be analyzed in de-identified form.The results of this research and analysis will not be disclosed or otherwisepublished in a manner that could identify an individual. Any additional testingfor research or analysis purposes that involves the collection, use ordisclosure of information that could identify an individual will involve aseparate informed consent process.
We may transferany information we have about you in connection with a proposed or completedmerger or sale involving all or part of Careand or as part of a corporatereorganization, business reorganization or other change in corporate control.
We use thirdparties to provide various services on our behalf. For example, we may useservice providers to store our data, authorize and process payments, recordtelephone calls, process test results and send email communications. When wetransfer personal information to service providers, we take reasonable steps toensure that your personal information is protected from loss, theft orunauthorized access, use, copying, modification, disclosure and disposal.
Storage of Personal Information
Your personalinformation will be maintained and accessed by Careand in Canada or by ourservice providers in Canada or the United States (the “U.S.”)and therefore, this information may be available to government authoritiesunder lawful orders and laws applicable in the U.S. Please note that suchinformation may be subject to lawful access by U.S. courts, law enforcement,and governmental authorities. By using our services or by providing us withyour information, you consent to this collection, transfer, storage, andprocessing of information to, in, and out of the U.S.
Access & Correction Rights
You may be ableto access some of your health record and other records (collectively, the “Records”)through the Application. You may also ask to see or make a formal writtenrequest to see and/or obtain a copy of your Records. We will endeavour torespond to a formal access request within 30 days. If necessary, we willprovide written notice of the reason for any time extension and the length ofthe extension.
We may deny orrestrict your access to your Records in very limited circumstances (e.g., ifthe information is subject to legal privilege, it is reasonable to believe thatdisclosure would result in a risk of serious bodily harm to you or anotherperson, if a provincial or federal act prohibits disclosure).
If you believeyour Records to be inaccurate or incomplete, you may request that the Recordsbe corrected. We will make the correction if you demonstrate that theinformation is inaccurate or incomplete for the purposes for which theinformation is being used. We may not correct the Records if it was notoriginally created at Careand and we do not have sufficient knowledge,expertise or authority to correct it; or if the Records consist of aprofessional opinion or observation made in good faith about you.
At your request,we will provide written notice to third parties who received the incorrectinformation about the correction, to the extent reasonably possible, and if thecorrection could reasonably be expected to have an impact on your ongoinghealth care or benefits.
Careand believesthat securing your personal information is very important. We have implementedreasonable administrative, technical and physical safeguards in an effort toprotect against loss, theft or unauthorized access, use, copying, modification,disclosure and disposal of personal information in our custody and control.However, please note that no data transmission or storage can be guaranteed tobe 100% secure. As a result, while we strive to protect your information andprivacy, to the extent permitted by law, we cannot and do not guarantee orwarrant the security of any information you disclose or transmit to us.
Your onlineaccess to some of your information may be protected with a password that youselect. We strongly recommend that you do not disclose your password to anyone.We will never ask you for your password in any unsolicited communication (suchas letters, phone calls, or email messages).
Information about our Website and Application
We collect the IP(Internet protocol) addresses of all visitors to our Website and users of ourApplication, and other related information such as page requests, browser type,operating system and average time spent on our Website. We use this informationto help us understand our Website activity, and to monitor and improve ourWebsite. Our Website uses a technology called “cookies”. Cookies may let usknow who you are, and may help us personalize your experience on our Website.You may set your web browser to notify you when you receive a cookie or to notaccept certain cookies. However, if you decide not to accept cookies from ourWebsite, you may not be able to take advantage of all of the features of ourWebsite. Our Website may also use a technology called “tracer tags” or “WebBeacons”. This technology allows us to understand which pages you visit on ourWebsite. These tracer tags are used to help us optimize and tailor our Websitefor you and other future visitors to our Website.
We may collectlocation information through your use of the Application and Website. Thisinformation may include specific location information drawn from your device’sGPS, Bluetooth, or Wi-Fi signals, including information about nearby Wi-Finetworks, location beacons, and cell towers. We receive this information whenyou use location-enabled services that we offer, and also when you use certainlocation-based informational, marketing, or public service applications that weor other parties offer.
Some web browsersmay transmit “do not track” signals to the Website and other online serviceswith which the browser communicates. There is no standard that governs what, ifanything, websites and online services should do when they receive thesesignals. We currently do not take action in response to these signals. If andwhen a standard for responding is established, we may revisit our policy onresponding to these signals.
Questions or Comments
If you wish moreinformation, access to your Records or you believe that your privacy rightshave not been followed as required by law or as explained in this PrivacyPolicy, you may contact us at the address, email address or phone number below.
Careand Family Health Inc.
162 Cumberland Street, Suite 200
Toronto, ON M5R 1A8
Attention: Alon Birshtein
Phone Number: 647-951-4770
You may also makea complaint about our information and privacy practices to the Information andPrivacy Commissioner at:
Information andPrivacy Commissioner of Ontario 2 Bloor Street East, Suite 1400 Toronto,Ontario M4W 1A8 Tel: (416) 326-3333 Toll-free: 1-800-387-0073