Privacy Statement

This Privacy Statement is made by or on behalf of ACT Greenwood Ltd., its affiliates and respective agents, its client physicians (“ACT Physicians”) and staff working at ACT Clinics (collectively, “we”, “our” or “us”) to inform patients seen by ACT Physicians about our privacy practices, including how we collect, use, and disclose your personal information.

What This Privacy Statement Covers

This Privacy Statement covers the following topics:

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Your Consent to the Collection, Use and Disclosure of Your Personal Information
• Retention, Storage, and Transfer of Personal Information
• Information Security
• Accessing and Updating Your Personal Information
• Changes to This Privacy Statement
• How to Contact Us

“Personal information” means information about an identifiable individual for purposes of Canadian federal and Ontario privacy laws. We may collect, use, and disclose different types of personal information, depending on the circumstances. Aggregated and anonymized data is not considered personal information because it cannot be used to identify you.

Personal Information We Collect

Generally, the categories of personal information we collect (not all of which may apply to you) are as follows:

• identity information, such as your name, date of birth, and gender
• contact information, such as your address, e-mail address, and telephone numbers
• health information, such as your medical history, symptoms, diagnoses, medications, test results, treatments, provincial health card number, and the names of your healthcare providers
• if you use our website or online platforms, technical and usage information such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform
• communication preferences

How We Use Your Personal Information

We generally use your personal information for the following purposes:

• to provide you with healthcare and related programs and services, as well as to determine your eligibility for programs and services;
• to communicate with you about our programs and services
• to process payment for your healthcare services, including through OHIP or your private insurer
• to ensure your safety and security, if you visit any ACT Clinic,
• to manage our operations and services, including to improve the effectiveness and efficiency of our programs and services
• to respond to your inquiries, complaints, or requests
• to investigate legal claims
• for such other purposes as you may consent to from time to time
• as otherwise required or permitted by law

How We Share Your Personal Information

We generally identify to whom, and for what purposes, we disclose your personal information and obtain your consent to such disclosure, prior to our collection of such information.

We may disclose your personal information to other healthcare providers, such as pharmacists or physicians, to facilitate the provision of your healthcare. This helps to coordinate care and ensure that everyone involved in your healthcare has the right information to meet your healthcare needs.

We may disclose your personal information when we believe such disclosure is required or permitted by law. In addition, we may disclose your personal information to a third party in the event of any significant business transaction, such as a merger or reorganization.

We rely on service providers to provide data processing and storage, and IT assistance. We also ensure that such service providers agree to maintain the confidentiality of your personal information and keep it secure, and to comply with applicable privacy laws and only use your personal information for the limited purposes for which it is provided.

Your Consent to the Collection, Use and Disclosure of Your Personal Information

We collect, use, and disclose your personal information with your consent or as permitted or required by law. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the personal information in question.

Generally, we rely on your implied consent to collect and use your personal information when you seek healthcare from us, and to disclose your personal information to other healthcare providers who are involved in your care.

If you wish to withdraw your consent to our collection, use, or disclosure of your personal information, please contact us using the contact information in the “How to Contact Us” section below. We will accommodate requests to withdraw consent, subject to legal or contractual restrictions, and  requests to place conditions on your consent to the collection, use, or disclosure of your personal information. Withdrawal of your consent may mean that we will no longer be able to provide you with certain services.

Retention, Storage, and International Transfer of Personal Information

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, and as permitted or required by law or regulatory requirements.

We may transfer your personal information outside of Canada to fulfil the purpose for which we collected it, including for processing and storage by service providers. While your personal information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada. Those laws may require disclosure of your personal information to authorities in that country.

Information Security

We and our service providers have implemented physical, organizational, contractual, and technological security measures in an effort to protect your personal information from loss or theft, unauthorized access, use, or disclosure. For example:

• we train our staff on the importance of safeguarding personal information
• we and they restrict access to your personal information to those staff or agents who need access for authorized purposes
• we or they protect personal information in electronic form using technological means such as firewalls, access controls, and encryption

Despite these measures, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in such risks as phishing and identity theft. In such cases, we will act promptly to mitigate the risks and to inform you if your personal information has been collected, used, or disclosed without authorization.

If you have reason to believe that your personal information is no longer secure, please contact us immediately using the contact information in the “How to Contact Us” section below.

Accessing and Updating Your Personal Information

You may make a request to access any personal information about you that we have collected, used, or disclosed, and we will provide you with any such personal information to the extent required by applicable laws.

You may also challenge the accuracy or completeness of your personal information in our records. If you demonstrate that your personal information in our records is inaccurate, we will amend your personal information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees.

If you object to how we handle your request, you may have the right to make a complaint to the Information and Privacy Commissioner of Ontario in relation to health privacy matters or, if the complaint relates to other privacy matters, to the Privacy Commissioner of Canada.

Changes to This Privacy Statement

The Privacy Statement was last revised as of the date that appears at the top of this page. From time to time, we may make changes to this Privacy Statement. When changes are made, they will become immediately effective when published in a revised Privacy Statement posted on any of our websites, unless otherwise noted. We may also communicate the changes to this Privacy Statement by other means.

How to Contact Us

We encourage you to contact your physician with any comments, questions, concerns, or requests regarding your personal information or our privacy practices. You may also contact our Privacy Office at:

Privacy Office
AddictionCentreTorontoPrivacy@gmail.com
1288 Danforth Avenue, Toronto, Ontario, M4J 1M6

If you feel that your privacy concerns have not been addressed, you have the right to make a complaint to the Information and Privacy Commissioner of Ontario. You may contact the Commissioner at:

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
416-326-3333 or 1-800-387-0073
www.ipc.on.ca