You are about to tell us about your body, your pain and your medical history. We take that seriously. This page explains, in plain language, what we collect, why, who sees it, how long we keep it, and what you can ask us to do about it.
ACCESS Surgical Network is an Ontario corporation. We are a concierge coordination service for patients seeking privately funded surgery in Canada. We are not a hospital, we are not a clinic, and we do not provide medical care ourselves. Your surgeon provides your surgery and the accredited facility provides the operating room. Both are independent, licensed and separately regulated.
This policy explains how ACCESS handles personal information, including personal health information, that you give us or that we collect on your behalf. It applies to this website and to the coordination services we provide.
Your surgeon and the facility that treats you have their own privacy obligations and their own policies, which govern the records they hold. This policy covers what we do.
We collect only what we need in order to coordinate your care. In practice that falls into four groups.
We do not ask for what we do not need. You are never required to tell us anything about your health in order simply to ask us a question. Send us as much or as little as you are comfortable with, and we will tell you what we actually need in order to help.
We use your information for the purposes of coordinating your care, and for nothing else. Specifically:
We do not sell your information. We do not rent it. We do not trade it. We do not use your health information for advertising, and we do not disclose it to anyone for marketing purposes.
We collect, use and disclose your personal health information with your knowledge and consent. When you contact us and describe your condition, you are consenting to us using that information to help you. When we need to share your file with a surgeon or a facility so that they can assess or treat you, we do so on the understanding that this is why you came to us, and your coordinator will make that clear at the time.
Where we want to do something with your information that goes beyond coordinating your care, we will ask you first, separately and in plain terms.
You can withdraw your consent at any time, subject to legal and contractual limits and reasonable notice. Tell your coordinator, or write to us using the details in section 12. Withdrawing consent may mean we can no longer coordinate your care, and we will tell you honestly if that is the consequence.
Your information is shared only with people who need it in order for your care to happen. That means:
We may also disclose information where the law requires or permits it, for example in response to a court order, or where disclosure is necessary to prevent serious harm.
That is the complete list. Nobody else sees your file.
We maintain administrative, technical and physical safeguards appropriate to the sensitivity of the information we hold. In practice that includes restricting access to those who need it to do their job, using encrypted transmission and storage for health information, requiring confidentiality commitments from our staff and service providers, and reviewing our practices as our systems change.
We will be straightforward with you about one thing: no organisation can promise that a security incident is impossible, and any organisation that tells you otherwise is overselling. What we can tell you is that we take it seriously, that we hold only what we need, that we keep it no longer than we should, and that if a breach did occur which posed a real risk of significant harm to you, we would notify you and the relevant regulator as the law requires.
We keep your information only as long as we need it for the purposes described in this policy, and for as long as we are legally required to. Health information relating to coordinated care is retained in line with applicable legal and professional requirements, which can run to a number of years. Enquiries that do not proceed are kept for a limited period and then securely destroyed.
Please note that your surgeon and the facility that treated you hold their own clinical records, and their retention obligations are their own and are generally longer than ours.
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The information collected in this way is technical and aggregate. It is not health information, and it is not used to identify you as a patient.
Some of the service providers we rely on, such as the platform that handles enquiries submitted through this website, may store or process information on servers located outside Canada. Where that is the case, the information may be subject to the laws of the country in which it is held, including lawful access by that country's authorities.
We select our service providers with this in mind and require them to protect your information to a standard comparable to our own. If you have concerns about this, tell your coordinator, and we will discuss alternatives with you.
You have the right to:
We may update this policy as our services and our systems change. The date at the top of this page tells you when it was last revised. Where a change is significant, we will take reasonable steps to bring it to the attention of patients whose care we are coordinating.
Questions about this policy, requests for access or correction, and complaints should be directed to our Privacy Officer:
You may also raise anything at all with your care coordinator, who will make sure it reaches the right person.
This policy describes how we handle your information. It is not a substitute for the privacy policies of your surgeon or the facility that treats you, and it does not limit any rights you have under applicable privacy legislation, including Ontario's Personal Health Information Protection Act, the federal Personal Information Protection and Electronic Documents Act, and the equivalent legislation in your own province or territory.
Ask us. You will get a straight answer from a person, and asking costs you nothing.