Privacy Policy

The SnapMED Privacy Policy was updated on September 28th, 2022.

Your Privacy Rights

SnapMED recognizes the importance of privacy and the sensitivity of personal information including personal health information (PHI). This Privacy Policy outlines how we manage your personal information and safeguard your privacy. This Privacy Policy summarizes how SnapMED collects, uses, discloses, retains, disposes of, destroys and protects information as well as data (information that does not identify an individual) in the course of providing our services. We are committed to complying with this Privacy Policy and with applicable Provincial and Federal privacy legislation.

Information collected by SnapMED itself is not intended to be personal health information (PHI). However, the information that you provide to health care practitioners through the SnapMED platform is PHI. Note that this Privacy Policy does not apply to the collection, use, retention, disposal, destruction, and protection of PHI by Canadian certified physicians or other healthcare practitioners. Canadian certified physicians and other healthcare practitioners are subject to privacy legislation and professional requirements that govern their management of information, including information they collect, use and retain in the course of providing services through the SnapMED platform. If you have any questions regarding the treatment of your PHI, you may inquire directly of any Canadian certified physician or other healthcare practitioner to whom you are referred. You are entitled to privacy in accordance with the relevant laws in the jurisdiction in which you reside as that is the jurisdiction in which services are to be provided to you through the SnapMED platform. SnapMED reserves the right to amend the Privacy Policy at any time without notice. The date of the last amendment will be indicated at the top of this page. Users are encouraged to review the Privacy Policy regularly to be aware of the changes.

Why Does SnapMED Need Personal Information?

SnapMED collects personal information as required to set up a user account. This information can be used to authenticate your future usage of the platform (such as date of birth, place of residence, phone number, etc.). Additionally, SnapMED reserves the right to customize the information displayed on the platform by using the information provided in your user account. SnapMED has an agreement with each of the healthcare practitioners who provide services through the SnapMED platform. SnapMED uses your personal information for the purposes of providing the SnapMED services.

Your personal information is collected and accessed by the healthcare practitioner who is providing you with a consultation. Each healthcare practitioner remains responsible to use personal health information in accordance with the applicable privacy and security laws as well as the professional regulations related to their healthcare profession. As part of its continuous development and improvement plans, SnapMED may collect information that is non-identifying. Only when necessary to manage the platform, certain personal information may be used, most commonly for statistical operation or process improvements.

SnapMED does not record the audio or video transmissions between users and healthcare practitioners. SnapMED does not permit users to record the audio or video transmissions between users and healthcare practitioners. You are prohibited from recording the audio or video being transmitted between you and any practitioner on SnapMED's platform or website.

How do we collect your personal information?

On the platform, you have control to upload, enter, and store your personal information, including personal health information. You also have control to upload, enter, and store the information of a legally dependent individual (or an individual for whom you are a legally authorized substitute decision maker) who has their own account. Healthcare practitioners may request personal information (including PHI) from SnapMED users. Personal information is collected when a user provides it during a consultation or through entering/uploading the information on the SnapMED platform.

The following information will be available on the platform that will be visible to the healthcare practitioner:

• Name
• Address
• Phone Number
• E-mail address
• Gender identity
• Sex assigned at birth
• Date of birth
• Province of residence
• Medical Information (as provided by the user for the purpose of the consultation)

Additionally, physicians' notes from any previous medical consultations through the SnapMED platform may also be available for healthcare practitioners to view. This information is used for the purpose of providing the service as requested by the user through the platform. Information can also be used to generate medical notes, prescriptions or other medical records as necessary. Additionally, information may be used by other healthcare practitioners, such as pharmacists, to prepare and deliver their services as requested by the user.As needed for their own professional record keeping and use, healthcare practitioners may export or print information that they have gathered through the SnapMED platform.

Consent

By uploading, entering and storing information into the SnapMED platform, you consent to the use and disclosure of your personal information and personal health information for the purpose of providing services through SnapMED and for any purposes described in the Terms of Use and this Privacy Policy.

Use of Your Information

SnapMED can use your personal information to comply with applicable regulatory and legal requirements. SnapMED may also use your personal information for its internal quality improvement to help improve the services provided on the SnapMED platform including customizing the experience, providing content, and advertising.

Information released to the Physicians prior to Consultation

At the initial request of consultation, you will be asked to input your medical symptoms, as well as other information that may include vital signs, and applicable images. In addition, your name and other personal and medical profile information will be accessible to the healthcare practitioner. This information is provided to the healthcare practitioner to identify if the consultation is eligible through the platform. Only one physician or healthcare practitioner will have access to this information prior to the start of the call. If the physician/provider accepts the consultation, the user is then able to accept the start of the call, deny the call or to discontinue the call once started. The physician or healthcare practitioner may, after the call, share the user's information within the circle of the patient's care as permitted by applicable regulations to provide additional healthcare services if the user so elects.

SnapMED Communication with Users

Information provided by the user may also be used to communicate with the user or when facilitating third party services such as securely sending a prescription to a pharmacy. Information may also be used by these third party services to contact and verify the user's identification. Under certain circumstances, healthcare practitioners may determine that your health condition warrants going to another provider for an appropriate medical appointment, or to a hospital or emergency room. In those circumstances, the healthcare practitioner or SnapMED personnel have the right to contact you or other emergency services as appropriate. SnapMED and its healthcare practitioners are not a replacement for a family physician or for emergency medical services.

Disclosure of your Personal Information

SnapMED will not disclose or sell any information to a third party except in the following circumstances:

• When we are required or authorized by law to do so, for example if a court issues a subpoena;
• When you have explicitly or implicitly consented to the disclosure;
• When the services we are providing to you requires us to give your information to third parties (e.g. to a pharmacist who is filling your prescription) your consent will be implied, unless you tell us otherwise;
• Where it is necessary to establish or collect fees;
• If we engage a third party to provide administrative services to us (such as computer back-up services or archival file storage) and the third party is bound by our Privacy Policy;
• To the resulting entity, if we are involved in a merger or acquisition of our company; or
• If the information is Publicly Available Personal Information, as it is defined under the Personal Information Protection and Electronic Documents Act.

SnapMED also has the right to use your personal information to defend itself in any legal claims and investigation. SnapMED retains the right to provide your personal information for the purpose of investigations of fraud or crimes related to your use of SnapMED.

Updating Your Information

Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date.

Storing Your Information

Your information is stored in your SnapMED dashboard for as long as you retain an account with SnapMED. Healthcare practitioners will use their own record keeping mechanisms to keep track of the relevant information needed to comply with their professional responsibilities. In the event that the user account is terminated, you will be provided with thirty days to print and copy the relevant notes and medical information. The healthcare practitioner will also be notified of the user account that will be terminated to ensure that the healthcare practitioner has updated his/her own records as needed. After a ten year period, all personal information in terminated accounts will be destroyed. Any data retained by other healthcare practitioners, including pharmacies, are subject to applicable regulations and their own privacy policies.

Upon termination of a user account, SnapMED is no longer required to provide you access to the information stored under your profile. You may request access to your healthcare information from the applicable healthcare practitioner that you consulted through the SnapMED platform. The healthcare practitioner will be subject to access requirements under the rules of their professional college and the access to information legislation applicable to their services.

Taking Responsibility for Your Information

Each user should take responsibility for their privacy. Please act with caution with respect to the sharing of your personal information. SnapMED will not be responsible if you choose to download, print, or share the records containing your personal information. You are not permitted to share your user ID and password with anyone else. You will be required to change your password every so often. The SnapMED platform provides the following choices for privacy options:

• You have a choice of which communication tool to use (i.e. chat service, video or audio call).
• You have the option to turn off the video and/or audio features at any time on the calling page.
• You have the option to not reveal all information to certain healthcare practitioners. However, deciding not to reveal information that is relevant to the consultation may lead to inaccurate diagnoses or advice.

Is My Personal Information Secure?

SnapMED takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• Premises security;
• Restricted file access to personal information;
• Use of challenge questions (personal questions about you) during calls with users to authenticate the user;
• Deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access; and
• Internal password and security policies.

SnapMED has highly prioritized the security of information. The information on its platform is stored electronically in a computer system with restrictions. These systems are housed in a physical space that has high security. Appropriate technical personnel are monitoring information safeguards to protect personal information from loss, theft and unauthorized access. Strict office practices are in place to ensure that SnapMED staff have been trained and are well versed on the safeguarding of personal information.

SnapMED and healthcare practitioners may communicate with the user in multiple forms including email, text, telephone, etc. These are not 100% secure and your use of these media with SnapMED constitutes your consent to the risk associated with the use of these media. If you have a concern about the security of transferring personal information, please notify us so that we can determine with you the most appropriate way to transfer information. SnapMED may at times collect location data though the use of GPS technology. This allows SnapMED to provide the appropriate services. Your computers' IP addresses help SnapMED monitor the security and activity of the account.

Access to Your Personal Information

You have access to your information in the user dashboard. You may also request access to your personal health information from the applicable healthcare practitioner who is the health information custodian.

Correcting Errors

You may update and modify your information under the profile page of your account. If SnapMED holds information about you and you can establish that it is not accurate, complete, and up-to-date, SnapMED will take reasonable steps to correct it. Any information that was posted prior to a consultation, which the healthcare practitioner reviewed as part of the consultation is considered permanent and will remain as part of the consultation note until a change is approved by a healthcare practitioner as set out below. To request that incorrect information be modified, you will have to submit a written request and the healthcare practitioner who provided the consultation will need to approve the change prior to any modification. Such safeguards are necessary to protect the accuracy of the record of the consultation.

Can I be denied access to my Personal Information?

Your rights to access your personal information are not absolute. We may deny access when denial is permitted by applicable privacy law and the professional regulations applicable to the healthcare practitioner. If we deny your request for access to, or refuse a request to amend information, we shall provide you with an explanation.

Can I request anonymity?

No. In order to provide the services supplied by the SnapMED platform, anonymity is not permitted.

Web Site

On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information. SnapMED may at times choose to link or post content from a third party website. SnapMED does not endorse nor benefit from the referral to those websites. SnapMED is also not responsible for the terms and privacy policies of such websites. Users are recommended to review the privacy policy on each website prior to using it.

Other Websites/Linked Services

This website may include links to other websites or services that require you to provide personal information such as credit card billing services. Those organizations are responsible for the personal information they collect. SnapMed does not control and is not responsible for those services. Your use of those other websites/services is subject to the Terms of Use for those sites. If the user elects to use pharmacy services, SnapMED will honour the user's choice of pharmacy and nothing in this Privacy Policy shall be construed as creating a partnership or any other type of relationship with that pharmacy. Pharmacies made available on the SnapMED platform are responsible to provide their services to the user directly.

Cookies and similar technologies

As part of SnapMED's commitment to understand our users, “cookies” and other technologies such as pixel tags and web beacons may be integrated with the SnapMED platform, email messages and advertisements. Cookies are small files that are sent to your device that are then used to monitor you and remember certain information about you. These tools and the results are used to enhance and personalize the user experience. Users have the ability to control the technologies by refusing to accept cookies through the setting in the user's web browser. SnapMED may also install cookies in our ads to better understand the effectiveness of our messaging. Users who choose to use the platform and accept cookies, are consenting to the use of cookies.

Changes to this Privacy Policy

Since SnapMED regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time without notice or liability.

Requests for Access

If you have any questions, or wish to access your personal information, please write to our Chief Compliance Officer at SnapMED, 202-444 Concession St., Hamilton, Ontario, L9A 1C2. When communicating with SnapMED, please include your contact information so that we may respond as needed. If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at 112 Kent Street, Ottawa, Ontario, K1A 1H3, 1-800-282-1376.