Client and Caregiver Privacy Policy
Effective Date of Policy
This Statement has been adopted by AGI as of October 1, 2020.
Company Statement
At Alzheimer Groupe Inc (AGI), privacy of our clients’ personal information is an important part of our organization’s quality of care. We understand the importance of protecting client and caregiver personal information and are committed to the principles and practices needed to protect the security and privacy of the personal information collected, used and/or disclosed.
We value your trust and aim to build a lasting relationship with you and your loved one. This privacy policy aims to be as transparent as possible about the way we handle your personal information.
Overview
All AGI employees who handle client and caregiver personal information are aware of the sensitive nature of the information disclosed to us. They are all informed of the appropriate uses and protection of client information. All personal information will be handled in accordance with the key privacy principles, such as identifying personal information types and purposes, limiting collection, limiting use, disclosure and retention, proper consent, individual access, data accuracy, openness, safeguards and compliance.
Personal Information - Defined
For the purposes of this Statement, “personal information” means any information which relates to a natural person and allows that person to be identified.
Types of Personal Information Collected by AGI
AGI collects two types of information: a) personally identifiable information that clients and their caregivers knowingly choose to disclose, which is collected on an individual basis and b) general user information that does not contain personally identifiable information, collected on an aggregate basis as users browse the AGI website. The latter is addressed in the section called Safeguarding and Storing Personal Information.
Personally Identifiable Information
Personal information varies according to the circumstances and customarily includes such items as clients’ contact and billing information, medical history and contact information for pertinent medical professionals, and prescription information. Information can also include contact information for both medical and financial Powers of Attorney. Credit card numbers (for purposes of processing the payment for services rendered etc.), and third-party billing information (for purposes of processing purchase of services on behalf of a particular client) are also collected. For visitors to our website, AGI may ask for certain personal information for the purpose of providing requested content and/or services. AGI also requests your name and e-mail address each time a client or caregiver contacts us by clicking on the "Contact Us" link. We may retain a record of users who have contacted us to respond properly to questions or concerns and for purposes of future communications.
Sources
AGI collects personal information through a variety of sources. The information is often collected directly from or on behalf of a particular client, in which case the information is collected with that party’s consent. The information may also be collected from a medical professional or from an institution or health authority, such as a long-term care facility. In these cases, AGI has taken reasonable steps to ensure that the individual to whom the personal information relates, have provided their consent to the collection of the information by AGI.
Use of Personal Information by AGI
AGI uses personal information that it collects for the following purposes:
- To provide individuals with services that are requested or that are part of AGI’s ongoing service offerings;
- To promote, conduct, process and complete transactions with AGI clients and caregivers, including invoicing third party payers for goods and services;
- To offer activities and programs (i.e. counselling, support groups, activity centre programming, education and training, etc.), for clients and/or their caregivers.
Disclosure of Personal Information by AGI to Third Parties
AGI does not sell, rent or trade personal information that it collects. AGI will not knowingly disclose personal information to any third parties except in the following circumstances:
- When AGI, in good faith, believes the law permits or requires such disclosure.
- When AGI has received consent to do so, or under limited circumstances, specifically described at such time as personal information is collected.
- To family members or caregivers of clients in order to complete transactions on behalf of clients and in situations where AGI, on reasonable grounds, believes that such family members or caregivers are who they purport to be and have the particular clients’ authority.
- Where legally obligated to provide contact information to another agency as assigned.
- In the event of the sale, merger, acquisition or transfer of all or substantially all of the assets of AGI, personal information that has been collected may be one of the transferred business assets.
- Client information may be accessed by regulatory authorities/orders under the terms of the Act of Respecting the Protection of Personal Information in the Private Sector and for the defense of a legal issue.
AGI will not under any conditions supply a client’s insurer with their confidential medical history, without client and/or caregiver consent.
When unusual requests are received, AGI will contact you for permission to release such information.
Confidentiality (as expressed in our AGI Counselling Agreement)
Your personal information will always be kept secure and will not be released to anyone outside of our Support Services team without your explicit permission.
Exceptions to Confidentiality
Your confidential personal information may be released without your consent by law under the following conditions.
1. When there is apparent imminent risk of harm to yourself or others;
2. Under the law which mandates reporting for the protection against elder abuse;
3. Under subpoena from a court of law.
*In all cases, if information is to be released, your counsellor will consult with you before taking any action.
Consent
Personal information is obtained and used only with client or caregiver consent and may be expressed or implied depending on the circumstance. When the information is not sensitive, AGI may rely on implied consent, such as contacting a client for a service they have signed up for. AGI obtains positive consent, via the client consent form attached, for clients and caregivers to provide their consent to use their personal information for the purposes described. Any new use of personal information, would require an additional request for express consent.
Opting-Out of Receiving Information from AGI
Individuals always have the choice whether they wish to supply AGI with personal information. Individuals wishing to “opt-out” of receiving certain informational and promotional materials from AGI or who otherwise object to the collection, use and disclosure policies as provided under this Privacy Policy are asked to please contact the Privacy Officer.
Retention of Personal Information by AGI
AGI record retention of client and caregiver personal information relates to the purpose for which it was collected. For example, AGI is required to retain business history for a period of seven years to comply with Canada Revenue Agency (CRA) regulations. AGI has established and abides by retention schedules for personal information that comply with provincial legislation requirements.
Safeguarding and Storing Client Personal Information
AGI uses a telehealth software called Cliniko as its practice management system, which allows AGI to schedule appointments and conduct video consultations or counselling sessions with clients and /or caregivers. Confidentiality, privacy protection and security for client records are core strengths of the software. In addition, AGI retains hard copy paper files for most clients and these are stored in a locked cabinet and staff are trained to not leave important documents in open areas.
Securing Client and Caregiver Information
While Cliniko is the database used to store and safeguard client and caregiver information, AGI remains the custodian of that information. Every step has been taken to help AGI manage client and caregiver information securely and confidentially. Cliniko meets or exceeds all regulations of the Canadian Privacy Principles, GDPR, PIPEDA, and HIPAA.
Ultra-Secure Facilities
Data is stored off-site in state-of-the-art Canadian accredited and certified datacenter facilities. More information about Cliniko data security can be found here: https://www.cliniko.com/security/
Other Websites
The software now or in the future operated by or on behalf of AGI may contain links to other websites that may collect personal information. This policy does not extend to the data collection, disclosure, use and retention practices of these third parties and AGI does not assume any responsibility for the privacy practices, policies or actions of such third parties. Individuals should read the privacy policies of such third parties and make an informed decision whether to visit such web sites and/or provide personal information to such third parties based upon their privacy practices and individual discretion.
Aggregate Data Collection
Our data collection and storage software uses standard technology called "cookies" and web server logs to collect information about how our software is used. Cookies are small pieces of data that are stored by a user's web browser on the user's hard drive and allows web servers to recognize the computer used to access a website. This information is collected on an aggregate basis, therefore none of this information is associated with you as an individual, but rather collects anonymous traffic data so that AGI, through the use of Google Analytics, can better understand visitor behaviour. You can read about Google’s privacy policy here: http://www.google.com/intl/en/privacy/
Access to Personal Information
Individuals have the right to access, verify and correct or amend all their personal information collected by AGI. To access verify and correct or amend personal information, please contact AGI’s Privacy Officer at 514-485-7233 or email info@agiteam.org.
Compliance – Handling Complaints
Our privacy protocols comply with provincial and federal privacy legislation. For AGI employees that are members of their professional orders or associations, they are also be required to comply with the privacy policies of groups such as Quebec Order of Psychotherapists, Association des Art Therapeutes de Quebec, Canadian Counselling and Psychotherapy Association and Canadian Association of Social Workers. Our concern for protection of client and caregiver privacy is genuine and as such, all complaints concerning the collection, use and/or disclosure of personal information will be investigated by the AGI Privacy Officer as soon as feasible. Individuals will be notified of the outcome of the investigation of complaints promptly and will be notified of any relevant steps taken or to be taken.
Privacy Officer
Jo-Anne Pride, Bookkeeper, is responsible as the Privacy Officer for AGI. Any complaints regarding the collection, use and/or disclosure of personal information as well as any comments, questions or suggestions regarding this Privacy Policy can be directed to the Privacy Officer, at 514-485-7233 or by email to info@agiteam.org.
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[1] http://www.legisquebec.gouv.qc.ca/en/showdoc/cs/P-39.1