Privacy Policy
I. Introduction
Patient Care Solutions Inc. (“PCS”) is the administrator of the New Leaf Vitality Program (the “Program”). PCS is committed to protecting the privacy, confidentiality, integrity, and security of the Personal Information (as this term is defined here in) entrusted to it by individuals, including those who participate in the Program.
In this Policy, the term “Personal Information” means any information, whether oral or in recorded form, that by itself or is able to be used substantially in combination with other information to identify an individual; and includes physical or mental health information of such individual. Program participants are referred to in this Policy collectively as “Patients” or individually as a “Patient.” The following
The Program is a Canadian weight-management and healthcare support program that helps eligible individuals access clinician-reviewed treatment options, including prescription medications where clinically appropriate, treatment suitability determinations, prescription management, pharmacy coordination, and ongoing support. Treatment options may include prescription medications used for weight management, metabolic health or related conditions when deemed clinically appropriate.
Patients may access the Program through participating pharmacies, the Program website, digital marketing channels, referrals, or other authorized sources. Program related healthcare services are delivered primarily through digital and virtual care technologies. Participation in the Program does not guarantee access to treatment, prescriptions, any specific medication or health results. Clinical decisions remain the responsibility of licensed healthcare professionals.
II. Program – Purpose
This Policy explains how the Program collects, uses, discloses Personal Information in relations to the Program. By enrolling into and/or participating in the Program, Patients hereby consent to the collection, use and disclosure of their Personal Information for purposes of administering the Program (the “Purpose”), including for eligibility assessments, clinical reviews, treatment planning, prescription management, pharmacy coordination, continuity of care, payment processing, communications and legal compliance.
III. Consent & Accuracy
Except as permitted by applicable law (as this term is defined below), the knowledge and meaningful consent of the Patient is required for the collection, use and disclosure of the Personal Information; and the Program will ensure that Patients are given an opportunity to provide informed consent at the time their Personal Information is collected. Patients who have provided such consent may revoke or modify their consent at any time by contacting:
Privacy Officer
New Leaf Vitality Program
Email: privacy@newleafvitality.ca or by telephone to [add phone number].
Please note, Patients may be required to disclosure further Personal Information in order for the Program’s Privacy Officer to confirm the identity of the individual making the revocation or modification request.
Personal Information shall be as accurate, complete, and up to date as is necessary for the Purpose. PCS will update Personal Information only as and when necessary to fulfill the Purpose or upon notification from the Patient or Program Partner(s).
Patients wishing to update their Personal Information may make a request to the Privacy Officer as noted above. PCS will make its policies and practices surrounding the management of Personal Information, as well as alternative contact information of Program’s Privacy Officer readily available.
IV. Personal Information
The Program may collect, use and disclose Personal Information for the Purpose, such as contact information, demographic information, health questionnaire responses, weight-management information, medication history, prescription information, healthcare provider information, pharmacy information, payment information, program participation records, and communications relating to healthcare services or Program administration. The following are examples of the Personal Information that may be collected, used and disclosed for the Purpose:
• Identification information
• Contact information e.g.: email, home address, telephone number(s)
• Medial and health information, including medical diagnosis, medical treatments, clinical assessments, Patient and
Patient’s family medical history
• Health insurance information
• Clinical reviews and decisions
• Patient interactions with Program Partners (as this term is defined below)
• Medical prescription information
• Lifestyle information e.g.: dietary and physical activity information
PCS recognizes the sensitivity of the Personal Information it collects for the Program purposes. PCS and its Program Partners (as this term is defined below) are committed to maintaining appropriate safeguards and complying with all legislation applicable to Personal Information, such as Personal Information Protection and Electronic Documents Act (2000, c. 5) (“PIPEDA”) and provincial privacy laws deemed substantially similar to PIPEDA, including provincial health information privacy laws. Personal Information may be shared with healthcare professionals, (such as physicians, nurse practitioners and pharmacists), participating pharmacies, laboratories, diagnostic providers, patient support personnel and authorized service providers (each a “Program Partner” or collectively, “Program Partners”) where reasonably necessary in furtherance of the Purpose, including Patient care, treatment monitoring, medication management, continuity of care and Patient safety. Such healthcare professionals and participating pharmacies may be health information custodians under applicable law; and are therefore independently obligated to comply with the requirements of such laws. Pharmacies maintain their own records and privacy practices; and Patients are encouraged to review the privacy policies of pharmacies involved in their support under the Program.
V. Personal Information Sharing
PCS will limit the collection of Personal Information to that which is necessary for the Purposes. Personal Information will be collected by fair and lawful means. In some cases, Personal Information may be collected from sources other than the Patient, for example Program Partners may need to share Personal Information with PCS in connection with the Purpose. Personal Information may also be collected as required or permitted by applicable law.
Access to Personal Information is limited to only those employees, contractors, agents and Program Partners on a “need to know” basis. Individuals who need to have access to Personal Information may do so only if such access is necessary and within the scope of that individual’s job responsibility, if contractually or otherwise required or permitted under applicable law.
VI. Communication
Patients may receive appointment reminders, prescription updates, pharmacy coordination notices, medication adherence reminders, refill support communications, injection training scheduling notices, educational content, treatment monitoring communications and certain marketing information that may be of interest to Patients. Such communications may be conducted by way of the following:
• Email
• Mail
• Telephone
• MS or text messaging
• Patient Portal messaging
• Video conferencing platforms
VII. Safe Guards
Appropriate physical, technical and administrative safeguards and precautions to secure Personal Information have been implemented. Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information, in accordance with applicable laws and PCS’s record retention policy.
Suppliers, contractors, agents and Program Partners working with PCS in connection with the Program are contractually required to use appropriate physical, technical and administrative safeguards and precautions to secure Personal Information and must have in place privacy policies and practices, including data security policies and practices that are at least as restrictive as this Policy.
VIII. Updates to this Policy
PCS will review this Policy periodically and will update this to address changes in applicable laws, regulations and the Program as necessary. When updates are made, an update will be posted on the Program website. Please check the Program website frequently to review the most recent Policy.