Our Data Privacy Policy
TWIG Fertility Inc. (“TWIG”) is committed to protecting your personal information and your personal health information. TWIG complies with the Ontario Personal Health Information Protection Act, 2004 (PHIPA) and the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and this privacy policy (the “Policy”) has been developed in accordance with the aforementioned privacy laws.
This Policy tells you the ways in which we may collect, use and disclose your Information and how we safeguard such Information (defined below). It also describes your rights and certain obligations we have regarding the use and disclosure of your Information.
Make sure that both your personal health information and personal information are protected.
Provide you with this Policy outlining our legal duties and privacy practices with respect to your personal health information and personal information.
TWIG believes that securing your personal information and your personal health information is a very important part of our job.
We endeavor to safeguard personal information and personal health information using methods that are appropriate to the sensitivity of the information. We make sure that only those people who need to see your personal health information and your personal information have access to the information. We maintain physical, technical and procedural safeguards which are designed to prevent your Information from theft, loss and unauthorized access, copying, use, modification, disclosure or disposal. For example, physical measures include locked file cabinets, restricted access to certain facilities and restricted access to our offices. Technical safeguards include the use of passwords and limitation of access to electronic storage. Procedural safeguards include requiring all of our employees, physicians and agents to sign confidentiality agreements. In addition, all staff of TWIG are required to undergo online privacy and security training.
When we say “you” in this Policy, this refers to TWIG’s patients or prospective patients.
When we say “we”, “our”, or “us”, this refers to TWIG.
“HIC” means health information custodian.
“Information” means personal health information and personal information.
“personal information” means information about an identifiable individual and includes information such as your name, mailing address, email address, phone number at home and work, and name of your employer. For the purposes of this Policy, “personal information” does not include “personal health information”.
“personal health information” or “PHI” means information relating to and identifying an individual, including information that concerns:
The privacy practices described in this Policy will be followed by all healthcare professionals and employees at TWIG.
How we may use and disclose Information about you
The following sections describe different ways that we may collect, use and disclose your Information:
It is important that the information contained in our records is both accurate and current. If your Information happens to change during the course of our relationship, please keep us informed of such changes.
USE
TWIG may use your Information (as permitted by PHIPA and PIPEDA) for the following purposes:
Other permitted or required disclosures of personal health information under PHIPA include:
We may disclose your personal health information to comply with our legal and regulatory requirements under the Regulated Health Professions Act and other applicable statutes. We will not supply an insurer or your employer with your personal health information without your express consent. In the event a request for such information is made, we will forward it to you and obtain your specific consent to release the requested information.
We will disclose your personal information if we have told you we will do so (either in this Policy or at the time the information is collected from you) and have obtained your consent, which may be express or implied. Additionally, TWIG may disclose the personal information where permitted or required by applicable law or regulatory requirements, or to comply with valid legal process such as court orders, or during emergency situations or where necessary to protect the safety of a person or group.
In addition, both personal health information and personal information may be transferred to a successor, should there be a change in ownership in all or a part of TWIG, provided that the successor is bound by appropriate agreements and required to use or disclose your Information in a manner consistent with the use and disclosure provisions of this Policy.
TWIG uses Google Analytics to collect and analyze information about the use of our website. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
TWIG has enabled the use of Demographic and Interests data which is part of Google Analytics Advertising Features. We use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers for better targeting advertisements and for marketing purposes.
You can opt-out of having made your activity on TWIG available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. You can also opt-out of the Google Analytics Advertising Features through Ads Settings, or Ad Settings for mobile apps.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Your health records are saved as an Electronic Medical Record (EMR) which is stored with a PHIPA compliant EMR service provider in Canada. Certain of the third party software and service providers we use may store Information outside of Canada but we have taken steps to confirm that they are handling and storing this Information with a high standard of care and security.
It is important to us that we only collect, use or disclose your Information where we have your consent, whether express or implied, to do so.
We will only collect, use or disclose your personal health information outside your circle of care with your express consent or in accordance with PHIPA. TWIG will notify you as to what personal health information it requires at the time of collection so it can properly deliver care to you.
Depending on the sensitivity of the personal information, your consent may be express, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you accept our products or services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.
Typically, we will seek your consent at the time that we collect your personal information. In some circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You understand that use of technology may increase the risk of your personal health information being unintentionally disclosed or intercepted by third parties. Technical failures and technological issues may result in a loss of personal health information and/or delay or interruption. TWIG assumes no responsibility or liability for any technical failures or technological issues associated with delivering results.
Retention of Records. TWIG will retain patient records as required by law and professional regulations and to fulfill our own purposes for collecting personal health information. The Canadian Medical Protective Association (CMPA) and College of Physicians and Surgeons of Ontario (CPSO) advise their members to retain health records for at least 10 years from the date of last entry or, in the case of minors, 10 years from the time the patient would have reached the age of majority (age 18). There may be reasons to keep records for longer than this minimum period.
Personal health information that is no longer required to fulfill the identified purposes is destroyed, erased, or made anonymous safely and securely.
Your right of access. You may ask to see the Information held by TWIG about you or make a formal written request to see and/or obtain a copy of your health record and the other personal information we have collected about you. We may deny or restrict your access in very limited circumstances (e.g., if the information is subject to legal privilege, it is reasonable to believe that disclosure would result in a risk of serious bodily harm to you or another person or if a provincial or federal act prohibits disclosure). Your request must be in writing, signed and dated.
We will endeavour to respond to a formal access request within 30 days, unless assembling or locating numerous pieces of information necessitates a lengthy search. We will provide written notice of the reason for the time extension and the length of the extension and will advise if there is a cost to be incurred to satisfy your access request.
Your right to correct the Information. If you believe your health record or personal information to be inaccurate or incomplete, you may request that the Information be corrected. We will make the correction if you demonstrate that the Information is inaccurate or incomplete for the purposes for which the Information is being used. We may not correct the record if it was not originally created at TWIG and we do not have sufficient knowledge, expertise or authority to correct it; or if the record consists of a professional opinion or observation made in good faith about you.
At your request, we will provide written notice to third parties about the correction, to the extent reasonably possible and if the correction could reasonably be expected to have an impact on your ongoing health care or benefits, to the persons who received the incorrect information.
We are committed to maintaining the accuracy, confidentiality and security of your Information.
disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You understand that use of technology may increase the risk of your personal health information being unintentionally disclosed or intercepted by third parties. Technical failures and technological issues may result in a loss of personal health information and/or delay or interruption. TWIG assumes no responsibility or liability for any technical failures or technological issues associated with delivering results.
Retention of Records. TWIG will retain patient records as required by law and professional regulations and to fulfill our own purposes for collecting personal health information. The Canadian Medical Protective Association (CMPA) and College of Physicians and Surgeons of Ontario (CPSO) advise their members to retain health records for at least 10 years from the date of last entry or, in the case of minors, 10 years from the time the patient would have reached the age of majority (age 18). There may be reasons to keep records for longer than this minimum period.
Personal health information that is no longer required to fulfill the identified purposes is destroyed, erased, or made anonymous safely and securely.
Your right of access. You may ask to see the Information held by TWIG about you or make a formal written request to see and/or obtain a copy of your health record and the other personal information we have collected about you. We may deny or restrict your access in very limited circumstances (e.g., if the information is subject to legal privilege, it is reasonable to believe that disclosure would result in a risk of serious bodily harm to you or another person or if a provincial or federal act prohibits disclosure). Your request must be in writing, signed and dated.
We will endeavour to respond to a formal access request within 30 days, unless assembling or locating numerous pieces of information necessitates a lengthy search. We will provide written notice of the reason for the time extension and the length of the extension and will advise if there is a cost to be incurred to satisfy your access request.
Your right to correct the Information. If you believe your health record or personal information to be inaccurate or incomplete, you may request that the Information be corrected. We will make the correction if you demonstrate that the Information is inaccurate or incomplete for the purposes for which the Information is being used. We may not correct the record if it was not originally created at TWIG and we do not have sufficient knowledge, expertise or authority to correct it; or if the record consists of a professional opinion or observation made in good faith about you.
At your request, we will provide written notice to third parties about the correction, to the extent reasonably possible and if the correction could reasonably be expected to have an impact on your ongoing health care or benefits, to the persons who received the incorrect information.
We are committed to maintaining the accuracy, confidentiality and security of your Information.
Changes to TWIG’s privacy practices and this Policy
We may revise TWIG’s privacy practices and this Policy from time to time. In addition, at any time you may request a copy of the Policy currently in effect. You may find a copy of our Privacy Policy on our website at www.twigfertility.com/privacy-policy/
Information, questions, access or complaints
If you wish more information, access to your records or you believe that your privacy rights have not been followed as required by law or as explained in this Policy, you may file a written complaint with us. Please send it to the TWIG Privacy Officer at the address provided below. If you have any questions or would like further information about this Policy, please contact:
PRIVACY OFFICER
Michelle Moniz
Fax: 416 987-2256
Email: privacy@twigfertility.com
DELEGATE
Fax: 416 987-2256
Email: privacy@twigfertility.com
You may also make a complaint about our personal health information and privacy practices to the Information and Privacy Commissioner at:
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Tel: (416) 326-3333 Toll-free: 1-800-387-0073
If you have concerns about our personal information and privacy practices, you may contact the federal Privacy Commissioner at:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (613) 947-1698
Fax: (613) 947-6850
Should there be, in a specific case, any inconsistency between this Policy and PHIPA or PIPEDA, whichever is applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy law. Any interpretation of this Policy will be made by the TWIG Privacy Officer. This Policy does not create or confer upon any individual any right or obligation, or impose upon TWIG any rights or obligations outside of, or in addition to, any rights or obligations imposed by PHIPA and PIPEDA, as applicable.