TABLE OF CONTENTS
- Collection and Use of Personal Information
- Sharing of Personal Information
- Storage and Location of Personal Information
- Information About Our Website
- Safeguards and Retention
- Your Choices
- Access to Information
- Contact Us
1. COLLECTION AND USE OF PERSONAL INFORMATION
We may collect and use your personal information, including your personal health information, when you:
- Visit or obtain fertility care or wellness services at one of our centres or through our virtual care offering
- Book an appointment or request a virtual consultation
- Pay for a service
- Participate in an HFC survey
- Participate in health and fertility research
- Apply for a job with HFC
- Contact us
Fertility Care and Wellness Services: We collect your personal health information to enable HFC healthcare providers to provide you with healthcare and services when you visit one of our clinics, receive virtual care services, or otherwise engage with us. We may also collect relevant personal health information about you from your other healthcare providers for this purpose. Your information collected in connection with our healthcare services is stored in your medical record, which is accessible to healthcare providers in our centres and through virtual care.
While the nature of the personal health information you provide us will be unique to you and your healthcare needs, in general, we collect information such as your first and last name, sex, gender, date of birth, general health concerns, family status, personal and family medical history (including information about any treatments, diagnoses, or prescriptions), physician and medical referral appointment information, health care documents and test results (including reports and imaging results), blood type and DNA information, health card number, and other relevant health information about you and intended parents, for the purposes of determining suitability for, planning and delivering healthcare services to you.
Virtual Care Services: HFC healthcare providers offer virtual care services to provide non-urgent, non-emergency healthcare services remotely, either through real-time video or audio technology. If you choose to use our virtual care services, HFC may request that you verify your identity such as by showing the healthcare provider your government-issued photo ID at the start of your virtual care session. Virtual care sessions are not recorded. If you share personal information with your healthcare provider through the chat functionality in a virtual care session, that information will be stored in your medical record.
We do our best to make sure that any information you give to us during virtual care visits is private and secure; however, there may be circumstances in which your communications with us, including the transmission of certain sensitive personal health information, will be through unencrypted e-communication. As with all online communications, there is a risk that your personal health information may be intercepted or unintentionally accessed or disclosed, and this risk is increased when unencrypted e-communication is used. To help mitigate this risk, you should be in a private setting and should not use an employer’s or someone else’s computer or device.
Booking an Appointment or Virtual Care: We collect personal information when you book an appointment or request virtual care with a healthcare provider through the Website, by phone or in person. This information may include your first and last name, email address, date of birth, phone number, partner’s name and date of birth, reason for booking/requesting care, medical history, emergency contact information, information regarding how you heard about HFC, and any other information you choose to provide us. We use this information to book your appointment or virtual care session and provide the healthcare provider with the information they need to deliver healthcare services to you.
Payment: When you book an appointment or pay for a service from HFC, we (or our authorized third-party payment processor) may collect your full name, payment information (including billing address, credit card number, expiry date and CVV code) and, if applicable, your private health insurance information, in order to process the transaction and enable HFC healthcare providers to provide you with the healthcare services you have purchased.
Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys. We may use the information we obtain through our surveys, which may include personal health information, to review and identify opportunities for improving our delivery of healthcare and wellness services to our clients and as otherwise described to you at the time of conducting the survey.
Fertility Research: We may use your full name, email address and information about the care you have received from HFC to identify upcoming research or studies that may be appropriate for you and contact you to determine if you are interested in participating. With your written consent, HFC may conduct fertility research or studies using your personal health information in a manner that could identify you. In order to participate in certain research opportunities, you may be asked to provide an extra blood sample that will be stored by HFC and analyzed alongside your medical record for the purpose of comparing and evaluating the predictive value of any subsequent tests developed and for the development of new products or methods of service delivery. Your participation in any such research is entirely optional.
If you consent to our collection of an extra blood sample and use of your medical record for these purposes, we will not sell or disclose your personal health information to any third parties.
De-Identifying and Aggregating Information: We may de-identify or aggregate your personal information, including personal health information, such that it cannot reasonably be associated with you, for the following purposes:
(i) to protect your privacy and the security of your personal information;
(ii) to conduct analytics and/or research with the goal of:
- improving our existing offerings;
- developing new healthcare products and procedures;
- improving fertility healthcare outcomes.
We may share such de-identified/aggregated information or insights with certain limited third parties to assist in researchanalytics, planning, or product and service development.
Careers: If you use our Website to apply for a job with HFC, you may provide us with certain personal information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We use this information for the purpose of processing and responding to your application.
Visit a Centre: The buildings in which our centres are located may conduct video recording for security purposes via the use of cameras located in public areas of the buildings over which we have no control.
Contacting Us: You may get in touch with HFC, including by SMS, telephone or email. When you contact us with a comment, question or concern, you may provide information that identifies you, such as your name, email and phone number, along with additional information we may need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future.
2. SHARING OF PERSONAL INFORMATION
Other Healthcare Providers: We may share your personal information with your other healthcare providers and facilities (e.g., another physician or healthcare practitioner, an allied health professional or member of your clinical care team, a public hospital, pharmacy, laboratory, or ambulance service) for the purpose of supporting your continuity of care. We may also share your personal information if required for the purpose of contacting your emergency contact or a potential substitute decision maker.
Employer/Benefits Providers: If you have indicated to us that you are eligible for private insurance coverage, we may disclose certain personal information to your employer or benefits provider for the purposes of coordinating payment from them, including your name, date of service, and the service provided. We may also share certain personal information with provincial health plans for billing of publicly-funded services.
Service Providers: Your personal information may be transferred (or otherwise made available) to third parties that provide services to us or on our behalf, such as laboratory and genetic testing, virtual care and administrative workflow technologies, financial assistance arrangements, cloud storage services, electronic medical records management and payment card processing. Our service providers are only provided with the information they need to perform their designated functions. They are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in Canada, the U.S. or other foreign jurisdictions (see ‘Storage and Location of Personal Information’ below).
Legal and Compliance: We and our service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or as otherwise may be required or permitted by applicable Canadian, U.S. or foreign law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: We may transfer information we have about our clients as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of HFC or as part of a corporate reorganization or other change in corporate control.
3. STORAGE AND LOCATION OF PERSONAL INFORMATION
We use service providers who may store or handle personal information, including personal health information, in Canada, the U.S. and other foreign jurisdictions in the course of providing services to us. Your medical record is stored by our electronic medical record provider in data centers in Canada. However, certain personal information, including personal health information, that you share with us in response to an intake questionnaire or survey may be stored or handled by our service providers outside of Canada.
4. INFORMATION ABOUT OUR WEBSITE
Visiting our Website: In general, you can visit our Websites without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Websites and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.
Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Websites, you may not be able to take advantage of all of the Website’s features.
Analytics: Our Website uses web analytics services such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information about Google Analytics or to prevent the storage and processing of this (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:
- https://policies.google.com/technologies/partner-sites and
5. SAFEGUARDS AND RETENTION
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. The only HFC employees and service providers who have access to our clients’ personal information are those who “need-to-know” the information in order to carry out their job duties.
HFC and any applicable third parties may retain de-identified information for the purposes outlined above under ‘De-Identifying and Aggregating Information”.
6. YOUR CHOICES
If you have provided consent to our collection, use or disclosure of personal information, you can withdraw your consent at any time (subject to our legal or contractual restrictions) by contacting us at the contact information set out below. If you withdraw your consent, we may not be able to provide certain products or services to you. As set out under the ‘Safeguards and Retention’ section above, even if you withdraw your consent, personal information that forms part of your medical record must be retained for a period of time to meet legal and regulatory obligations.
7. ACCESS TO AND UPDATING OF INFORMATION
Subject to limited exceptions under applicable law, you have the right to access, examine, update and ask to correct inaccuracies in your personal information and personal health information in our custody and control. You may make such requests by emailing or writing to us using the contact information set out below. You also have the ability to update your personal information by calling HFC or making a request in person. We may request certain personal information from you when you make such a request in order to verify your identity.
9. CONTACT US
160 Bloor St. East
Toronto, ON M4W 3R2
You may also bring your questions or concerns to the Information and Privacy Commissioner of Ontario by visiting www.ipc.on.ca.