This policy describes Appletree Medical Group Inc.’s (“Appletree”, “we”, “us”, “our”) general privacy and information practices with respect to the personal information and personal health information that we may collect about you during your visits to and use of our website, virtual care services or when you otherwise interact with us, how we use personal information and personal health information, and the manner in which personal information or personal health information may be disclosed or shared by us (“Privacy Policy”).
- Personal information means information about an identifiable individual.
- Personal health information is identifiable information about an individual which relates to: physical or mental health of the individual, including family health history; providing of health care to the individual, including the identification of a person as a provider of health care to the individual; payments or eligibility for health care in respect of the individual; donation by the individual of any body part or bodily substance or which is derived from the testing or examination of any such body part or bodily substance; the individual’s health number; or identification of an individual’s substitute decision-maker. Personal health information includes other identifying information that is contained in a record that contains personal health information.
Consent
Unless an exception to consent applies, Appletree only collects, uses or discloses your personal information and personal health information with your consent, which may be express or implied as required by applicable law. You may withdraw your consent at any time, subject to legal and contractual restrictions.
Website
By visiting our website or otherwise interacting with us you signify your acceptance of this Privacy Policy and consent to the collection, use and disclosure of your personal information by Appletree in accordance with the terms of and for the purposes set out in this Privacy Policy.
Virtual Care Services
When you use our virtual care services and input sensitive personal information, including personal health information, we will ask for your express consent for us to collect, use and disclose such information. Your use of our virtual care services is subject to the Terms of Use and Privacy Policy of Verto Inc. You will be required to review and accept the Terms of Use upon registration and can refer to the Privacy Policy at: https://verto.health/privacy-policy/
Patient Portal
When you register for a Patient Account on our website, your consent for us to collect your contact information, payment information, and health card information will be implied through your conduct in providing this information to us in order to create an account. When you use our Patient Portal to input and provide sensitive personal information, including personal health information, we will ask for your express consent for us to collect, use and disclose such information. Your use of our Patient Portal is subject to our Patient Portal Privacy Policy located at https://www.appletreepatients.com/PatientPortal/Ottawa/Authentication/PrivacyPolicy as well as our Patient Portal Terms of Use Agreement.
Collection and Use of Personal Information and Personal Health Information
Information we automatically collect:
We obtain certain information about your use of our website. Specific types of usage information that may be collected automatically include: information about how, when and where you use our website; the hardware and software you use to interact with our website; your device identifier; your mobile network information; the settings you use on our website; your network location; your IP address; and information about the webpages you visited prior to coming to our website.
Our website uses Google Analytics. Google Analytics allows us to analyze and enhance user experience by better understanding how you interact with our website. For more information on how Google Analytics collects and processes information, as well as how you can control the information sent to Google, please review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/.
Google Analytics also uses cookies to collect standard internet log information and visitor behaviour information in an anonymous form. The anonymous information generated by Google Analytics cookies about your use of our website (including your IP address) is transmitted to Google and compiled into aggregated statistical reports that are used by Appletree to optimize website content. You may control your advertising preferences or opt-out of certain Google advertising products (i.e. the Google Analytics cookies) by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.
Information you explicitly provide:
We also collect personal information and personal health information about you either from you directly or from a person acting on your behalf. The information that we collect may include your name, date of birth, address, personal and family health history, health card information, payment information, health insurance information, records of your visits to our Appletree Medical Centres, and the care that you received.
We may use your personal information and personal health information in order to deliver virtual care, administrate virtual care services, receive payment for your treatment and virtual care, research, compile statistics, fundraise, meet legal requirements, and fulfill other purposes permitted or required by law. Your personal health information may be disclosed to physicians, health care professionals, and staff directly involved in your health care. We are also required to disclose patient information to several organizations, such as the Ministry of Health.
Appletree and/or agents acting on its behalf may use personal information and personal health information to generate de-identified and/or aggregated information so that it does not contain any information that either alone or with other information could identify an individual. Appletree may use such de-identified and/or aggregated information for research purposes, for activities to improve the quality of care, or to evaluate our services. Appletree also has entered an agreement to sell such de-identified and/or aggregated data sets to a third-party data science company for use by the company to generate insights into: treating and preventing illness; the analysis of costs, benefits, and financial management of healthcare (i.e. health economics); and the evaluation of the safety of drugs and devices in patients (i.e. post-marketing surveillance).
Sharing of Personal Information and Personal Health Information
Under certain circumstances, Appletree will disclose your personal information or personal health information:
- When you have expressly consented to the disclosure;
- Where your consent is implied, including where we disclose your personal health information to another health information custodian for the purposes of providing health care or assisting in providing health care to you;
- Where necessary to establish or collect payment;
- When we are required or authorized by law to do so without your consent.
Appletree engages certain third-party service providers and/or agents to provide administrative services to us, for example, computer (information technology services), as well as call centre services. To the extent that these service providers have access to your personal information, they are obligated by us to provide an equivalent level of protection for your personal information to the level of protection that we provide.
Security Safeguards
We have instituted appropriate safeguards in our efforts to ensure that the personal information and personal health information that we collect is protected. Our Internal Privacy Policy governs the manner in which all our employees access and manage patient information. Our employees are required to sign a confidentiality agreement and our physicians are bound by the rules and guidelines instituted by the College of Physicians and Surgeons of Ontario with respect to privacy and confidentiality.
Physical safeguards, such as facility access controls, workstation security, and mobile device security requirements, are in place in order to protect personal information and personal health information.
Our patient information system uses passwords and a firewall to protect the system from inappropriate accesses and from Internet users. The security capabilities of the patient information system are also upgraded on an ongoing basis. In addition, the Virtual Care account and Appletree Patient Portal accounts are password-protected, and confidential personal information available through these accounts is secured through encryption technologies.
If your personal health information is stolen, lost, or accessed by unauthorized persons, we will notify you at the first reasonable opportunity.
We caution that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
Retention of Personal Information and Personal Health Information
Appletree will retain your personal information and personal health information only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. We retain personal health information for at least the minimum retention period required by the College of Physicians and Surgeons of Ontario. Where personal information is no longer needed, it will be securely destroyed or permanently anonymized or de-identified.
All personal information and personal health information is stored and retained within Canada at a highly secure data centre maintained by Rogers Communications.
Links to Other Websites
We may provide links to, or automatically produce search results for, third-party websites or resources, or third-party information referencing or linking to third-party websites or resources. Appletree has no control over such third-party websites and resources, and you acknowledge and agree that Appletree is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Privacy Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. Appletree is not responsible for the privacy or security practices or the content of external websites, services or products.
Access and Correction
You have the right to access and correct your personal information under our control. Please email our Appletree Privacy Custodian at privacy@appletreemedicalgroup.com to request access to or change your personal information and/or preferences. We will correct or delete any personal information we have about you, unless we are required to keep it by law.
Questions and Concerns
If you have any questions or concerns regarding our information and privacy protection practices, or if you feel that your privacy rights have been violated, please contact our Appletree Privacy Custodian at privacy@appletreemedicalgroup.com or at the following address:
Appletree Privacy Custodian
Attn: Dr. Thom Tyson
2575-B Baseline Rd.
Ottawa, ON K2H 7B3
If you feel your privacy rights under PHIPA have been violated, you may also submit a written complaint to the Information and Privacy Commissioner of Ontario at the following address:
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
1-416-326-3333
1 (800) 387-0073 (within Ontario)
Modification to Privacy Policy
We reserve the right to change our Privacy Policy. A revised Privacy Policy will apply only to data collected subsequent to its effective date. Any revisions will be posted at least 10 days prior to its effective date.