EMERGE Virtual Care Privacy Notice
Last Updated March 30th, 2021
This notice explains how we collect, use and disclose your personal health data when you use our healthcare services and products in Canada, or visit or use the EMERGE Virtual Care App.
If you have any questions about how we process your information, please don't hesitate to get in touch by contacting our Privacy Officer at email@example.com
1. Information We Collect
We use the following categories of personal data:
When you register with us, you complete your health profile and provide us with basic information about yourself, such as your name, date of birth, physical address and email address. You may also provide us health card number/provincial health insurance number for the purposes of the healthcare provider bill the public health system. You are responsible for the accuracy of the information that you provide to us.
Health and medical information
The main type of information we hold about you is health and medical information: information about your health, symptoms, treatments, consultations and sessions, medications and procedures. This includes details of your consultations with our doctors.
We get some of this information directly from you, when you register with us and when you use our healthcare services.
We do not retain recordings of our consultations, but we do retain records of interactions with you. To monitor our service quality, we may retain records of when you contact our support teams via email or phone.
2. Provision of the EMERGE Virtual Care Platform
Users eligible for Virtual Care feature:
- We collect and use your Information to register you, create your Personal Profile, authenticate you when you log in into the EMERGE Virtual Care Platform.
- We collect your provincial health card number in order to the healthcare provider of your choice can bill provincial health plans for those services that are eligible for coverage by provincial health plans.
- You may choose to enter and store your Information in the EMERGE Virtual Care Platform such as your medical conditions, and allergies.
- We use Information that you enter, or which is created as part of an interaction with an Authorized Healthcare Provider to make it available to you when you access your Personal Profile.
- We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.
- To request Virtual Care, you need to describe the symptoms relevant to your request. You may also specify whether you’re seeking to renew a prescription or obtain a sick note. We facilitate your disclosure to the selected Authorized Healthcare Provider of that information, along with age and name to determine whether your request is eligible. Once the selected Healthcare Provider confirms that your request is eligible, we disclose the remaining of your information saved on your profile with the selected Healthcare Provider. Unless you have elected not fill your information in the EMERGE Virtual Care Platform about you, the selected Authorized Health Care Provider will be able to view it too.
- We may collect location data through the use of GPS technology and your IP address where applicable to services you have requested, e.g., show nearby providers. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings..
3. Use of Personal Information
The purposes for which we use your personal data and the grounds on which we do so are set out below. We generally use personal data with your consent, except where the use of personal data without consent is permitted by law.
Providing you a service
We obtain and use your personal details in order to verify your identity and eligibility for our services, establish and deliver our contract with you including to provide the services you request.
We collect, use and transfer your medical information in order to the selected healthcare provider perform effective diagnosis, treatment and care. This includes the information collected through our consultations with you (such as notes), our digital services. The selected healthcare provide may also share information with other healthcare professionals as necessary for the provision of care to you, such as your Family Doctor, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, and laboratories chosen by you for the purpose of health exams.
Keeping you up to date
As part of providing you, with high quality health care services, we may contact you by SMS, email and/or other means to provide appointment reminders, offer you helpful information.
We may also use your email address, postal address, phone number and/or name to contact you or present you with occasional updates and marketing messages where you have not opted out.
You can opt out receiving these communications at any time by following the instructions contained within the marketing communication.
Based on our legitimate interest in managing and planning our business, we may analyze data about your use of our products and services to, for example, troubleshoot bugs within the App or our website, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you that would have a significant legal effect on you – it is only about improving our App so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
Where necessary, we may need to share personal details for the purposes of fraud prevention and detection.
We also store your medical information, such as notes from consultations and your interactions with our digital services. For example, we may need to review your information and, where necessary, make disclosures in compliance with lawful requests by regulatory bodies or as otherwise required by law or regulation.
Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.
We may obtain and use data about your precise location where you give your consent (through providing us access to your location through your App or browser settings or your address), for example, to help direct you to the nearest healthcare provider.
Sharing your personal data with others
We have partnered with local healthcare providers to provide you healthcare services through our platform. Your personal data will be shared with the healthcare provider of your choice when necessary to allow local healthcare providers to provide these services to you and to us.
We will, where necessary for your treatment or care, share your information with your other health and social care providers.
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.
We may share your personal information with companies we have hired to provide services on our behalf, such as data hosting and processing, technical support, marketing and communications. These service providers are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.
Where you access our services through public health insurance, and where you have given your consent, we will provide the selected healthcare institution of your choice with the personal information required to allow them to process your claim. This may include your name, email address, policy number, location, demographic information, that you had an appointment through us, the date of the appointment, details of your diagnosis, prescription, pharmacy location, whether or not you had a referral made and other similar information about your appointment through EMERGE Virtual Care. Personal information provided will be limited to only what is required.
Unless we otherwise give you notice, we will retain your Information on the EMERGE Virtual Cate Platform on your behalf until such times as you or we terminate your Personal Profile. To ensure that Authorized Healthcare Providers may exercise any authority they have to withhold Information they compile in connection with Virtual Care consultations from patients under the law, you will be required to request any access you would like to notes made by an Authorized Healthcare Provider about your consultation from the Authorized Healthcare Provider. EMERGE Virtual Care is not the custodian of Information held on the EMERGE Virtual Care Platform; rather it holds Information on behalf of Users or Authorized Healthcare Providers. On termination of your Personal Profile, we will delete the Information associated with your Personal Profile, except Information that an Authorized Healthcare Provider advises us he or she requires in connection with a consultation. In such circumstances, EMERGE Virtual Care will destroy the Information when the Authorized Healthcare provider has obtained a copy or terminates his/her account with EMERGE Virtual Care.
Data storage, security and transfers
We do not store your medical information on your mobile device.
Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
While some of your personal information may be processed outside of Canada, we store all of your medical information on secure servers in Canada.
Some of your personal information may be processed or accessed outside of Canada by EMERGE Virtual Care or our service providers. Regardless of location, personal information will be protected in accordance with the applicable data protection law and subject to strict safeguards. For example, when we do transfer personal information outside of Canada, we strive to minimize the amount of personal information to what is absolutely necessary to achieve the specified purpose. Notwithstanding these safeguards, while outside of Canada, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access personal information in certain circumstances. We will only provide, and our service providers are only permitted to provide, personal information in these circumstances if we or they are compelled to do so under applicable laws.
4. Personal Information Protection
EMERGE Virtual Care takes the security of your information seriously. We store your information in electronic format within Canada. More generally, we have in place appropriate technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, EMERGE Virtual Care employees are obligated to protect Information by adhering to our policies, practices and applicable laws.
You also play an important role in protecting your privacy and the confidentiality of your Information.
- Create a strong and unique password for your Personal Profile and update it periodically.
- Do not share your Personal Profile or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request.
- Log out of your Personal Profile once you are finished using it, especially if you share your Device with anyone else.
- Have a strong and unique password on your Device.
- Choose a quiet, private location from which to receive services from Authorized Healthcare Providers.
5. Your rights
As indicated above, whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by emailing us with your request.
You may also have the right to:
Request access to the personal data we hold about you. For other information, you can make a request by email;
Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
Ask us to restrict our processing of your personal data or object to our processing.
6. Contact us
For any questions or concerns, or if you’d like information about how to create a complaint with us or an applicable privacy commissioner’s office, you can contact us by sending an email to firstname.lastname@example.org