© 2020 Annie Frisbie IBCLC, Inc, all rights reserved
Last Modified: November 23, 2021
Personal Health Information
What is Personal Health Information?
Personal health information is information about an identifiable individual. Personal health information includes, but may not be limited to, information that relates to:
the physical or mental health of the individual (including family health history);
the provision of health care to the individual (including identifying the individual’s health care provider);
a plan of service;
payments or eligibility for health care or coverage for health care;
the donation or testing of an individual’s body part or bodily substance;
the individual’s health number; or
the identification of the individual’s substitute decision-maker.
The types of personal health information we collect may include your name, date of birth, health history, health insurance number and records of the care provided to you.
Why We Collect Personal Health Information
We collect, use and disclose personal health information for the following purposes:
to provide services to support our clients
to conduct quality improvement and risk management activities
to obtain payment for services provided
to comply with our regulatory obligations
to advise clients about special events or opportunities (but we will always obtain express consent to do so)
We will collect, use and disclose only as much personal health information as is needed to achieve these purposes. You can withhold or withdraw your consent to the collection, use or disclosure of your personal health information by contacting us (details below).
We may use a number of consultants and agencies that may, in the course of their duties, have limited access to personal health information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, lawyers, temporary workers to cover holidays, credit card companies, website managers and cleaners. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
Access to Health Records
You have the right to seek access to your health records that we keep and to ask us to correct a record if you believe it is inaccurate or incomplete. Please contact us for more information.
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.
This policy applies to information we collect, use, or disclose about you:
On this website email@example.com (the “Website”).
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier and any other identifier we may use to contact you ("personal information").
We provide an opportunity for any user to unsubscribe from our emails or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails.
Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
Technical information, including your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) or methods used to browse away from the page.
HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Information You Provide to Us
The information we collect directly from you on or through our Website may include:
Information that you provide by filling in forms on our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your search queries on the Website.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statistical information and may include personal information and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
To notify you about changes to our Website or any products or services we offer or provide though it.
To improve our Website, products or services, marketing, or customer relationships and experiences.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
DISCLOSURE OF YOUR INFORMATION
To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Parenting From Within, our customers, or others
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to firstname.lastname@example.org. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
CHILDREN UNDER THE AGE OF 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or provide any information about yourself to us, including your name, address, telephone number, email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the contact details set out below.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at the contact details below. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
Parenting From Within
You also have the right to complain to the Privacy Commissioner of Ontario at the address below if you have concerns about our privacy practices or how your personal health information has been handled:
2 Bloor Street East, Suite 1400 Toronto, ON M4W 1A8
Toronto Area: 416-326-3333
Long distance: 1-800-387-0073
If you are covered by the General Data Protection Regulation (“GDPR”), you have a number of important rights free of charge. In summary, those include rights to:
• Fair processing of information and transparency over how we use your use personal data;
• Access to your personal data;
• Require us to correct any mistakes in your information which we hold;
• Require the erasure of personal data concerning you in certain situations;
• Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
• Object at any time to processing of personal data concerning you for direct marketing;
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• Object in certain other situations to our continued processing of your personal data; and
• Otherwise restrict our processing of your personal data in certain circumstances.
You may also have the right to claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, available at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .
If you would like to exercise any of those rights, please contacts us using the contact information set out below.
Additionally, if you are covered by the GDPR we note that we are processing your information in order to fulfill contracts we might have with you or otherwise to pursue our legitimate business interests. Additionally, please note that your information will be transferred outside of Europe, including to Canada.