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This Privacy Policy informs you about the types of Personal Information [1] (“PI”) and Personal Health Information [2] (“PHI”) Field Trip Health Inc. (“Field Trip”, “we” or “us”) collects, uses and discloses, the choices you have regarding such use and disclosure, and how you may correct that information.
From time to time, we may make changes to this Privacy Policy. The Privacy Policy is current as of the “last revised” date which appears at the bottom of this page. We will treat PI and PHI in a manner consistent with the Privacy Policy under which it was collected, unless we have your consent to treat it differently.
We are committed to protecting the privacy and security of your PI and PHI. We are committed to meet our obligations under respective Canadian and United States data privacy laws, including the Personal Information Protection and Electronic Documents Act (Canada), the Personal Health Information Protection Act (Ontario), the Health Insurance Portability and Accountability Act (United States), and regulations thereunder. The principles set out below govern the way we collect, use, store and disclose PI or PHI that is obtained in the course of development, sales, promotion and distribution of our services.
We identify the purposes for which we use your PI or PHI at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your PI and PHI for the following purposes (the “Purposes”):
to provide you with ongoing medical care and therapy;
to provide you access to digital tools and services;
to track your use of Field Trip services;
to facilitate communications with third-party service providers with whom we have a contractual relationship such as, Physicians, Nurse Practitioners, Therapists, Psychologists, Psychiatrists, and Pharmacists;
to advise you about new programs and services that may be of interest to you;
to respond to your inquiries, complaints or requests;
to collect opinions and comments in regard to Field Trip’s operations;
to investigate legal claims;
such purposes for which Field Trip may obtain consent from time to time; and
such other uses as may be permitted or required by applicable law.
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your PI or PHI for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the PI or PHI and the reasonable expectations you might have in the circumstances. In limited circumstances, we may rely on a third party to obtain your consent to the sharing of your PI or PHI with us. You may withdraw your consent by providing us notice. You may expressly instruct that your personal health information not be used or disclosed for healthcare purposes without your consent. Notwithstanding the above, we may share anonymized data to contribute to improvements, research, and general knowledge about treatments and therapy programs; in all such situations Field Trip Health Inc. will take reasonable steps to remove personally identifiable information before such results are shared externally.
We will always collect your PI and PHI by fair and lawful means. We may collect PI or PHI from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent, or as otherwise required or permitted by law.
The information we request from you is used for the Purposes; we will seek your consent for any other purposes.
We ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with PI or PHI are contractually required to observe the intent of this Privacy Policy and our privacy practices.
We will use, disclose or retain your PI and PHI for as long as necessary to fulfill the Purposes and as permitted or required by law.
Generally, we will only make disclosures of PI or PHI to such persons for which you provide your consent. Notwithstanding the foregoing:
We may transfer your PI or PHI to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes – such as, Physicians, Nurse Practitioners, Therapists, Psychologists, Psychiatrists, Pharmacists, and service providers that provide technology or communication services, data storage and processing, cloud-based software, or other similar services.
We may also make disclosures of PI or PHI to a potential acquiror in connection with a transaction involving the sale of some or all of the business of Field Trip (in which case the use of your information by the new entity would continue to be limited by applicable law), or as otherwise permitted or required by law.
We may send PI or PHI outside of the country for the Purposes, including for processing and storage by service providers in connection with such Purposes. However, you should note that to the extent that any PI or PHI is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
We endeavour to ensure that all decisions involving your information are based upon accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on you to disclose all material information and to inform us of any relevant changes.
We have implemented physical, organizational, contractual and technological security measures to protect your PI and PHI from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees, who are granted access to your PI and PHI, are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Information about our policies and practices regarding the management of personal health information/individual’s PI and PHI is available to the public on our external website and from the Privacy Officer.
If you make a written request to review any PI or PHI about you that we have collected, used or disclosed, we will provide you with any such PI or PHI to the extent required by law. We will make such PI or PHI available to you in a form that is generally understandable, and will explain any abbreviations or codes.
We encourage you to contact us with any questions or concerns you might have about your privacy or our Privacy Policy. We will investigate and respond to your concerns about any aspect of our handling of your information.
All comments, questions, concerns or complaints regarding your PI and PHI, this Privacy Policy or our privacy practices, should be forwarded to our Privacy Officer at the following email address: privacy@fieldtriphealth.com
We will attempt to respond to each of your written requests not later than 30 days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of your jurisdiction in respect of this time limit.
[1] “personal information (PI)” – “recorded information about an identifiable individual.” Some examples may include: home address, telephone, email address; gender, age, marital status, health information, religion; employee number, employment history; opinions, financial data, and personal health information.
[2] “personal health information (PHI)” – Information about an individual whether living or deceased and whether in oral or recorded form. It is information that can identify an individual and that relates to matters such as the individual’s physical or mental health, the provision of health care to the individual, payments or eligibility for health care in respect of the individual, the donation by the individual of a body part or bodily substance, and the individuals health number. PHI can be information about a physician or other care provider, a hospital staff person, a patient, or a patient’s family member. Examples of PHI include a name, medical record number, health insurance number, address, telephone number, and PHI related to a patient’s care such as blood type, x-rays, consultation notes, etc.