MDCM CLINIC POLICY REGARDING
PROTECTION OF PERSONAL INFORMATION
This personal information protection policy (hereinafter the “Policy”) sets out how CLINIC MDCM collects, uses, communicates, stores and destroys your personal information. For ease of reading, we will use the expressions “we” or “the clinic” from time to time in the Policy.
We may provide you with additional information regarding the processing of your personal information, in certain cases, at the time of collecting your personal information. We may also obtain your specific consent in certain cases relating to the collection, use, disclosure and retention of your personal information.
The Policy applies to personal information we collect regardless of how, for example in person, by telephone or through our website.
By accepting this Policy or providing us with personal information after having had the opportunity to review the Policy or any additional notice, you agree that your personal information will be processed in accordance with the Policy and the additional notice.
1 ABOUT US
Here are our full credentials:
CLINIC MDCM
203-5515 RUE ST-JACQUES
MONTREAL, QUEBEC
H4A 2E3
Please do not hesitate to contact our Protector of Personal Information, our Administrative Assistant, with any questions or comments you may have regarding the Policy, how we treat your personal information or to exercise your rights regarding your personal information .
You can contact our Protector of Personal Information by mail at the address mentioned above.
Within CLINIC MDCM we have assigned the roles and responsibilities as follows:
Under the authority of the clinic operators, the administrative assistant ensures that the rules specific to the protection of personal information are established in the clinic and that they are understood by all staff.
We educate our staff members and professionals to fully understand the importance of protecting personal information, in particular through the information provided by the College of Physicians of Quebec, the Commission for Access to Information of Quebec and certain medical associations. .
2 IMPORTANT DEFINITIONS
In the Policy, we mean:
“Privacy incident”
1) access to personal information not authorized by law;
2) the unauthorized use of personal information by law;
3) the unauthorized communication of personal information by law; Or
4) the loss of personal information or any other breach of the protection of such
information.
“Personal information” any information which concerns a natural person and allows, directly or indirectly, to identify them.
3 HOW WILL WE PROCESS YOUR PERSONAL INFORMATION
How do we collect your personal information? | Mainly using RAMQ registration forms, our electronic medical records, the access window to a family doctor, the population access window, the Santé Québec file, Logibec for information from establishments, by telephone. |
What personal information do we collect? | Personal contact information, health insurance card, health information. For our staff, personal contact details, information required under labor laws, tax laws. |
From whom do we collect your personal information? | Directly from you, from the family doctor access desk, from the population access desk, from the Santé Québec file, from the RAMQ and from the health establishments in the network. |
Why do we collect your personal information? | In order to provide you with health services. For our staff, in order to be able to employ and remunerate them. |
What happens if you do not consent to the collection of your personal information? | We will not be able to provide you with health services or hire you. |
How will we share your personal information with third parties? | With our electronic medical records, the Santé Québec file, Logibec for interaction with health establishments in the network, with our billing agency for the Régie de l’assurance santé du Québec. For our employees, according to the means provided by the rules of government authorities. |
Who can have access to your personal information? | Doctors, health professionals loaned by the CISSS, consultant health professionals, nurses, secretaries, all strictly in the execution of their own functions. For our employees, medical clinic managers and people responsible for human resources and accounting, strictly in the execution of their duties. |
How long will we keep your personal information? | As long as the doctor-patient relationship lasts, according to the rules laid down by the Law and by the College of Physicians of Quebec. For our employees, as long as the employment relationship lasts and according to the laws and regulations in force for the management of human resources within a company. |
What are the risks associated with processing your personal information? | Confidentiality incidents occur (see definition above). |
Where will we store your personal information? | We store your personal information in our provider’s electronic medical record system, which is approved by the Department of Health and Human Services. Billing with the Régie de l’assurance santé du Québec using the billing agency system. Those of our employees in our electronic personnel management systems, those of payroll service providers and in locked filing cabinets. |
How are complaints handled? | Procedure for handling complaints related to the protection of personal information |
4 WHAT TECHNOLOGY PRODUCTS DO WE USE
Software name | Name of supplier | Utilities | Update Schedule |
MEDESYNC | TELUS | Patient files | By the supplier |
CAREFILE | CAREFILE | Billing | By the supplier |
CERIDIAN | CERIDIAN | Management System | By the supplier |
5 SAFETY MEASURES AND INHERENT RISKS
We follow security standards in our industry to protect the information we collect and receive. In particular, we have appropriate physical, technical, IT and administrative safeguards in place to protect your personal information against a confidentiality incident.
Despite these measures, given the risks inherent in the use of computer systems, we cannot ensure or guarantee the security and confidentiality of the information that you transmit or provide to us, and you do so at your own risk. If you have reason to believe that personal information has been compromised, please contact us using the contact information provided in section 1 of the Policy.
6 HOW AND UNDER WHAT CONDITIONS WILL WE DISCLOSE YOUR PERSONAL INFORMATION FOR PURPOSES OF PUBLIC SAFETY OR PROSECUTION OF OFFENCES
6.1 In case of serious risk of death or serious injury
We may communicate personal information that we hold in order to protect a person or group of people when there is reasonable cause to believe that a serious risk of death or serious injury, linked in particular to a disappearance or an act of violence, including a suicide attempt, threatens this person or group and the nature of the threat inspires a sense of urgency.
The information can then be communicated to the person(s) exposed to this risk, to their representative or to any person likely to help them. Only information necessary for the purposes pursued by the communication will be communicated.
6.2 Law enforcement
We may also communicate information to the Director of Criminal and Penal Prosecutions or to a person or group responsible for preventing, detecting or repressing crime or legal offenses when the information is necessary for the purposes of prosecution for a violation of a law applicable in Quebec.
Finally, we will be able to communicate information to a police force when it is necessary for the planning or execution of an intervention adapted to the characteristics of a person or the situation, in one or other of the following cases:
1° the police force intervenes, at our request, to provide us with help or support in the context of the services we provide to a person;
2° we act in consultation or in partnership with the police force within the framework of mixed practices of psychosocial and police interventions.
7 IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE QUEBEC?
We may transfer your personal information to service providers we use in the course of our operations. It is therefore possible that your personal information may be transferred outside of Quebec, for example to cloud computing to ensure data redundancy, that is to say, to ensure its integrity.
8 WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?
The law gives you different rights with regard to your personal information. In particular, you have the following rights:
Access: the right to ask whether we hold personal information about you and, if so, to request access to that personal information.
Rectification: the right to request rectification of any incomplete or inaccurate personal information we hold.
Withdrawal of consent: the right to withdraw your consent to the communication or use of personal information held. In this case, we will no longer be able to provide you with health services or keep you employed if you are one of our employees.
Restriction or refusal of access: the right to request that a particular stakeholder or one who belongs to an indicated category of stakeholders cannot have access to one or more pieces of information that you have identified.
Complaint: the right to make a complaint addressed to our personal information protection manager as identified in article 1 in connection with this Policy or to file a complaint with the Commission de l’access à l’information du Quebec if you believe that an infraction of the laws on the protection of personal information has been committed. To file a complaint with the Commission d’access à l’information (Québec), please use the appropriate form available at the following address: For citizens | Quebec Information Access Commission (gouv.qc.ca)
Portability: You have the right to request that your personal information be communicated to you or transferred to another organization in a structured and commonly used technological format.
To exercise any of these rights, please contact our Privacy Officer as indicated in section 1 of this Policy.
9 HOW DO WE USE BROWSING COOKIES?
We do not use any browsing cookies.
10 THIRD PARTY SITES
This Policy does not apply to any third party websites, pages or applications that may be accessed through our services and we are not responsible for such third party services.
If you follow such links, these third party sites or services will likely have their own privacy policies which you should review before submitting your personal information.
11 FULLY AUTOMATED DECISIONS
We do not use any technology that makes automated decisions based on personal information.
12 IDENTIFICATION, PROFILING, OR LOCALIZATION TECHNOLOGIES
We do not use any technology that uses personal information for identification, profiling or location purposes.
13 DESTRUCTION OF PERSONAL INFORMATION
Personal information is destroyed according to the rules provided for by the regulations issued by the College of Physicians of Quebec, by the laws applicable in Quebec regarding the management of human resources and by the laws applicable in Quebec for the protection of personal information.
14 HOW DO WE UPDATE THIS PRIVACY POLICY?
We may, from time to time, modify the Policy to reflect changes in our business processes or in the law.
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