Workhorse Health is a company that facilitates: (i) the matching of patients with healthcare provider(s); and (ii) increased client satisfaction (determined by the client) with the goal of successful outcomes through engagement with a psychotherapist assistant.
Please read this Policy carefully. By continuing to use the Workhorse Health products and services you are providing your consent to the collection, use, and disclosure of your PHI in accordance with this Policy.
1. Scope and Application
This Policy applies to any of your PHI that is collected through your interactions with Workhorse Health and certain of its partners in Canada. Throughout this policy, we collectively refer to these companies as “Workhorse Health”, “we”, “us” or “our”.
“Personal health information” includes any information that identifies or can identify you and that relates to the state of your health or the treatment you are receiving. PHI can include diagnostic, treatment, or care information. Privacy is all about consent, so it’s important that clients a) read the policy, and b) understand that by using Workhorse Health services they are consenting to the collection, use and disclosure of their PI in accordance with the policy.
In this Policy, we describe what PHI we collect through your interactions with us.
2. How We Collect and Use Your Personal Information
2.1 What types of PHI do we collect and how?
The PHI we collect about you is gathered through your interactions with us. For example, when you contact Workhorse Health you will speak with a psychotherapy assistant, who may collect PHI that includes your name, address, email address, phone number, gender, occupation, therapy history, emergency contact number, and responses to assessment questions. We collect only the amount of PHI that is reasonably required to fulfill the purposes for which it is being collected.
2.2 Why do we collect your PHI?
We collect your PHI for the following primary purposes:
- to identify you and provide you with our healthcare related services, including but not limited to creating a patient file and connecting you to a psychotherapist;
- to communicate with you, including to promote our products and services, respond to inquiries, and address comments and complaints;
- to manage our business operations;
- to enhance your experience using the Workhorse Health products
- as otherwise permitted or required by law.
2.3 Storage, Retention, and Disposal of PHI
We take the security of your PHI very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. For example, the information we create and retain about your services is encrypted by a North-American based third-party encryption service. We restrict access to your PHI on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We use reasonable safeguards, including contractual requirements with our service providers, to protect your PHI wherever it is used or stored. In general, we store, access and use PHI in Canada.
We store your PHI for as long as it is necessary to provide you with our services and for a reasonable time thereafter, or as permitted or required by law. For example, information regarding your psychotherapy is stored in accordance with the College of Registered Psychotherapists of Ontario records policy for 10 years. Once it is no longer required, your PHI will be securely destroyed. Please note that if your PHI is collected by a third party, it will be retained in accordance with the privacy policies of and records retention requirements of that third party.
2.4 Access to Your Personal Information
We want you to clearly understand your choices and make informed decisions about your privacy options. It is your responsibility to provide accurate, correct, and complete information. If you notice any errors in your PHI or need to update it, please let us know through the steps outlined below.
Under Canadian privacy law, you have the right to access, update, and correct inaccuracies in your PHI in our custody and control, subject to certain exceptions prescribed by law. Upon request, we will provide you with access to your PHI within a reasonable timeframe, in compliance with applicable laws. Some of the PHI we hold about you is accessible to you through your online account(s). You can access and update or correct this PHI by logging into your account(s) and making updates accordingly.
You may also request access, updating, and corrections of inaccuracies in PHI we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain PHI for the purposes of verifying the identity of the individual seeking access to their PHI records
3. Sharing of Personal Health Information
Your PHI may generally be shared with your healthcare providers and your authorized representative(s).
We may share PHI within our group of companies or with our service providers. Service providers are companies operating on our behalf who help us operate our business, technology systems, and applications, internal procedures, and infrastructure. We require our service providers to limit their access to and/or use of PHI to what is required to provide their services, and to comply with our privacy requirements.
We may share PHI with other companies with which we provide programs or services. As a result, your PHI may be collected, used, and shared by us and these third parties. The third parties may have their own privacy policies and terms and conditions, which will govern their use of your PHI. You will be informed of any applicable third party arrangement when you sign up for each program or service so that you can review the privacy policies that apply.
We may also share PHI as otherwise permitted or required by law. Canadian law permits or requires PHI to be used or shared without consent in specific circumstances, including when necessary to protect healthcare providers, employees, clients, customers, or others, when investigating and preventing suspected or actual illegal activities, including fraud, or in the course of legal proceedings. In such circumstances, we will not share more PHI than is reasonably required to fulfill that particular purpose.
Otherwise, we will share or disclose your PHI outside of Workhorse Health only with your express consent and in accordance with applicable law.
We do not sell PHI to any organization or person. The only exception to this would be if we sell or transfer any part of our business. If PHI is required in connection with any such transaction, we will comply with the legal requirements for the disclosure of PHI.
4. Active Steps For Protecting Personal Health Information
To protect your PHI, we maintain administrative, technical, and physical safeguards. By having these safeguards, we aim to avoid the loss, misuse, unauthorized access, disclosure, or modification of your PHI.
Our directors, employees, independent contractors, (“ICs”), and any other registered professionals representing Workhorse Health abide by the guidelines of the respective professional governing bodies in the jurisdictions in which they are practicing, as well as by Workhorse Health policies in order to maintain the privacy of client PHI and the integrity of Workhorse Health. For example, where appropriate, we use the following safeguards:
• Multi-Factor Authentication, which is a method of confirming your identity by using more than one way to authenticate you, such as asking for your password and a code that is sent to your email address or phone number;
• Masking, which is the process of obscuring your information so that the structure remains the same but the content is no longer identifiable;
• Anonymization, which is the process of altering your data so that it can no longer be used to identify you personally;
• Encryption, which is the process of obscuring your information in order to make it unreadable without the use of a code or a key; and
• Logging and Monitoring, which is the process of tracking, recording and monitoring.
5. Online and Website Information
5.1 Visiting Our Website
We and/or our service providers collect IP (Internet protocol) addresses from all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. This information is used to help us understand our Website activity, and to monitor and improve the Website.
5.2 Cookies, Tracer Tags & Web Beacons
You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the features of our Website.
Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website for you and other future visitors.
5.3 Third Party Links
This Policy may be updated periodically to reflect changes to our privacy or PHI handling practices. We will post the updated Policy on our Website and inform our employees, directors, officers, and ICs of any changes.
7. Contact Workhorse Health
If you have any questions about this Policy, wish to access or correct inaccuracies in your personal information, or otherwise have any questions or concerns with the manner in which we or our service providers treat your PHI, please contact our privacy officer at email@example.com, or by mail at:
ATTENTION: PRIVACY OFFICER WORKHORSE HEALTH
Workhorse Health Inc.
East Tower, Bay Adelaide Centre
22 Adelaide St West, Suite 3400