RxISK eCONSULT services are provided by a division of Data Based Medicine Americas Ltd., a company incorporated under the laws of Canada.
Data Based Medicine Ltd. and its affiliates (“DBM” or “we”) are committed to maintaining the accuracy, security, and privacy of Personal Information in accordance with applicable Canadian legislation. This Privacy Policy is a statement of principles and guidelines concerning the protection of Personal Information of our clients, service providers, and other individuals (“you”).
Consent
BY SUBMITTING PERSONAL INFORMATION TO DBM OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT WE MAY COLLECT, USE, AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting the DBM Chief Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information that may be of value to you. If you provide DBM or our service providers and agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use, and disclose such personal information for the purposes set forth in this Privacy Policy.
What Personal Information Do We Collect?
Canadian privacy legislation defines “Personal Information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, Personal Information means information about an identifiable individual as defined from time to time in applicable privacy legislation. Generally speaking, Personal Information does not include what is considered business contact information: your name, title or position, business address, telephone number, facsimile number, or email address.
The types of Personal Information that DBM may collect about you includes your name, home address, telephone number, personal email address, billing and account information, information about personal medical conditions, and other information incidental to providing a medication opinion to you, including to your health care providers, and litigation support services (including Personal Information about witnesses, family members, beneficiaries, health providers, directors, officers, employees, adverse parties, parties-in-interest, investigators, decision-makers, experts, and other professional advisors).
We also collect from former employers and other third parties, and from publicly available sources, personal information about prospective or current employees, contractors and partners that is reasonably required to establish, manage, or terminate an employment, contractual, or partnership relationship.
Why Do We Collect Your Personal Information?
In general, DBM collects, uses, and discloses Personal Information about our clients and service providers in order to provide our clients with RxISK eCONSULT services, and about applicants for positions with DBM for the purpose of evaluating the application and deciding whether to establish (and subsequently to manage or terminate) an employment, contractual, or partnership relationship. More specifically, we collect, use, and disclose your Personal Information for the following purposes:
- providing or assisting in providing you with RxISK eCONSULT services;
- planning or delivering RxISK eCONSULT services, including evaluating or monitoring those services;
- purposes permitted or required by law (e.g., if legislation requires disclosure, in the case of a legal proceeding);
- risk management, error management, or activities to improve or maintain the quality of our RxISK eCONSULT services;
- obtaining payment;
- to be aggregated and analyzed for the purpose of study and research as approved by a research ethics board. Client confidentiality of specific medical information will be protected. Any additional testing for research purposes will involve a separate informed consent process;
- providing you with information, newsletters, invitations, and other communications from DBM; and
- contacting family or a potential substitute decision-maker if you are injured or unable to give consent.
To Whom Do We Disclose Your Personal Information?
From time to time, DBM may disclose your Personal Information to:
- health professionals involved in your care (e.g., physician in the community or other health care practitioner, public hospital, pharmacy, laboratory, ambulance service), unless instructed otherwise by you;
- service providers, including an organization or individual retained by DBM to perform functions on its behalf, such as marketing, data processing, document management, and office services;
- a person who, in the reasonable judgment of DBM, is providing or seeking the information as your agent;
- an organization or individual retained by DBM to evaluate your creditworthiness or to collect debts outstanding on an account;
- our insurers and to regulatory agencies, or others in connection with regulatory or other activities relating to the obligations of DBM and its services;
- personnel in DBM, government authorities, insurers, benefits providers, consultants, or agents as reasonably required to establish, manage, or terminate employment, contractual, and partnership relationships; and
- any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.
Where Do We Store Your Personal Information?
Your Personal Information is stored in secured locations and on servers controlled by DBM, located either at our offices or at the offices of our service providers.
How May You Obtain Access to Your Personal Information?
Upon your written request, subject to certain exceptions, DBM will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information. Access requests should be sent to our Chief Privacy Officer, using the contact information below.
How Do We Protect Your Personal Information?
To help protect the confidentiality of your Personal Information, DBM employs administrative and technological safeguards appropriate to the sensitivity of your Personal Information. Where Personal Information is sent to a third party for processing we ensure, through our contacts with them, that all Personal Information is kept secure. We operate secure data networks protected by industry standard firewall and password protection systems.
Privacy and Our Website
Cookies: When an individual visitor accesses a DBM website, we may use a browser feature called a “cookie” to collect information, such as the type of Internet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed, and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g., by registering for an event or sending us correspondence from the website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.
Online Communications: In order to provide our website visitors with a service or information, visitors may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, subscribing to a newsletter or a mail or email list, participating in a seminar or other event, and participating in contests and surveys. If you are known to DBM as a registered user of an online service, we may combine and store Personal Information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.
Email Communications: Occasionally, we may send marketing or promotional email communications to you with information that may be useful, including information about the services of DBM and other third parties with whom we have a relationship. In this process, we may collect certain information such as the date/time you first opened our e-mail communications, the number of times you open our email communications, the number of click-throughs per article, total click-through activity on the contents of our email communications, and compile generally the related statistics. We may combine and store any such information to manage and improve our email communications to you. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional emails from DBM.
Links: Our website may contain links to other websites, which are provided as a convenience only. Visitors are advised that other third-party websites may have different privacy policies and practices than DBM, and DBM has no responsibility for such third-party websites.
Changes to the Privacy Policy
DBM reserves the right to modify or supplement this Privacy Policy at any time. Should you require more information on changes to the Privacy Policy, you may do so by contacting our Chief Privacy Officer, using the contact information below. However, DBM will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use, or disclose your Personal Information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.
Further Information
DBM has appointed Dr. Dee Mangin, Chief Privacy Officer, to oversee compliance with this Privacy Policy and applicable privacy laws. For information on DBM’s privacy practices, please contact Dee at:
Dr Dee Mangin
David Braley Nancy Gordon Chair in Family Medicine
Associate Professor
Department of Family Medicine
McMaster University
100 Main Street West, 3rd Floor
Hamilton ON L8P 1H6
Published: 4 December 2014