Homewood Health Inc. Privacy Policy

Introduction

At Homewood Health Inc. (Homewood), including our business lines The Homewood Clinics and Homewood Health Centre, respect privacy is of utmost importance. We understand that privacy is one of the biggest concerns for our clients and we respect the privacy of every person who uses our services, including our website.

Homewood is required to comply with applicable privacy legislation in the jurisdictions in which it carries on business. We have created this policy to demonstrate our commitment to your privacy and to show the value we place on the personal information you provide to us.

The Ten Privacy Principles that Homewood follows:

1. Accountability: Homewood is responsible for maintaining and protecting all personal information under its control. Homewood has designated an individual to oversee the company's compliance with this Privacy Policy and its principles. Responsibility for compliance with the provisions of the Homewood Privacy Policy rests with the Homewood Chief Privacy Officer, who can be contacted by email at Privacy@HomewoodHealth.com or by mail at: Homewood Health Centre, 150 Delhi Street, Guelph, Ontario, N1E 6K9, attention: Chief Privacy Officer. Other individuals within Homewood may be delegated to act on behalf of the Chief Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

2. Identifying Purposes (for collection of personal information): We will identify the purposes for which personal information is collected, either before or at the time of collection.

Personal information will not be used by Homewood without your consent for purposes other than those for which it was collected. We may collect, use, disclose and process personal information from the public and our clients for a number of purposes, including:

a)to provide services that Homewood has contracted with your employer to provide to you;

b)to conduct quantitative or qualitative marketing and social research;

c)to respond to questions and requests;

d)to conduct competitions and promotions;

e)only if you have so indicated, to communicate with you from time to time;

f)to meet legal and regulatory requirements or for other purposes required or authorized by or under law; or

g)to develop, maintain and modify our websites and social media platforms.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose will be identified and the consent of the respondent will be acquired prior to use or disclosure, unless the new purpose is permitted or required by law.

3. Obtaining Consent (for collection, use or disclosure of personal information): We will only collect, use and disclose your personal information with your knowledge and consent, except where otherwise required or permitted by law.

In attaining consent, Homewood will use reasonable efforts to help ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed, and these purposes will be stated in a manner that can be reasonably understood by the respondent.

Homewood will generally seek consent to use and disclose personal information at the same time that it collects the information. However, Homewood may seek such consent after the personal information has been collected but before it is used and/or disclosed for a new purpose. In determining the appropriate form of consent, Homewood will take into account the sensitivity of the personal information and the reasonable expectations of respondents.

4. Limiting Collection (of personal information): Homewood will limit the collection of your personal information to only those details that are necessary for the purposes identified, and information will be collected fairly and lawfully. Homewood limits the amount and type of personal information it collects and collects only the amount and type of information needed for the purposes identified.

5. Limiting Use, Disclosure and Retention (of personal information): Your personal information will only be used or disclosed for the purpose for which it was collected, unless you have otherwise consented, or when it is required or permitted by law. We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein. We will only retain your personal information only for as long as required to fulfill the purposes for which it was collected.

Homewood may disclose a respondent’s personal information to:

a)a client of Homewood where the respondent has consented to such disclosure;

b)a third party engaged by Homewood to perform functions on its behalf;

c)a public authority or agent of a public authority if, in the reasonable judgement of Homewood, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or

d)a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Access to personal information about respondents is granted only to Homewood employees with a business need-to-know or whose duties reasonably require it.

Personal information is kept by Homewood only as long as it remains necessary or relevant for the identified purposes or as required by law. Homewood will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information will be destroyed, erased or made anonymous.

6. Accuracy (of personal information): We will keep personal information we collect as accurate, complete and up-to-date as necessary to fulfill the purposes for which it was collected. To minimize the possibility that inappropriate information may be used to make a decision about a respondent, personal information used by Homewood will be sufficiently accurate, complete and up-to-date.

7. Security Safeguards: Homewood will protect the personal information we collect with security safeguards appropriate to the sensitivity of the information. We have implemented measures designed to help protect personal information and we maintain reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control. Through such appropriate security measures and regardless of the format in which the personal information is held, we will protect it against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. Unfortunately, no collection or transmission of information such as email addresses over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure, and therefore, we cannot ensure or warrant the security of any such information.

We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

We will protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used. Homewood employees will be required to respect the confidentiality of personal information

8. Openness (concerning policies and procedures): Information about our policies and practices relating to the management of personal information will be made readily available to you as an individual. We will make information about Homewood policies and procedures easy to understand, including:

a)the title and address of the person or persons accountable for compliance with the Homewood privacy policy and to whom inquiries can be forwarded;

b)the means of gaining access to personal information held by Homewood

c)a description of the types of personal information held by Homewood and a general account of its use; and

d)a description of what personal information is made available to related organizations.

9. Individual Access: At your request, we will inform you of the existence, use and disclosure of your personal information, as well as give you access to the information. You will be able to challenge the accuracy and completeness of your information, and to amend it as necessary. You can obtain information or seek access to their individual information by contacting the Homewood Chief Privacy Officer. Upon written request to the Chief Privacy Officer, Homewood will inform an individual of the existence, use and disclosure of his/her personal information and will be given access to it.

In certain situations Homewood may not be able to provide access to all such personal information, such as when, for example, doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual or where disclosure would reveal confidential commercial information.

In order to safeguard personal information, we may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. You as a respondent may be required to provide sufficient identification information to permit Homewood to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information will be used only for this purpose.

Subject to certain exceptions prescribed by law, you may request access, updating and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. Homewood will correct or complete any personal information found to be inaccurate or incomplete, and note any unresolved differences. Where appropriate, Homewood will transmit amended information or the existence of unresolved differences to third parties having access to the personal information in question.

10. Challenging Compliance: You may contact Homewood with any questions; complaints or suggestions with respect our compliance with the above principles. Homewood will have procedures for addressing and responding to all such inquiries or complaints regarding the handling of personal information and will, on written request, inform respondents about the existence of these procedures and the availability of complaint procedures.

The person or persons accountable for compliance with the Homewood Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints. Homewood will investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, Homewood will take appropriate measures to resolve the complaint, including amending its policies and procedures if necessary. The respondent will be informed of the outcome of the investigation regarding the complaint.

Internet Privacy

In addition to the above privacy guidelines, Homewood has implemented privacy practices and policies for its websites, including the Homewood Health Corporate, Employee, Insurers, Clinicians, Individuals, and Health Centre websites. Below, we describe how we collect, use, disclose and process information concerning you and how Homewood manages the personal information that we collect through our websites, including the following:

as well as related Homewood websites, social media pages, internal website, intranet and any Homewood mobile application (collectively the “Website”).

In general, you can visit our Website without telling us who you are or submitting any personal information. However, Homewood might also collect general anonymous information about visitors to our site, including date and time of the visit, particular pages of the site visited, type of browser used, the IP (Internet Protocol) address of your device, the number of clicks during your visit, the type of device you used, your general geographic location (state/province or country), the advertisements or videos that you watched during your visit, the name of the internet service provider.

We do not in any way link IP addresses with any personal information about individual visitors. We use this information only to determine how to make future visits more convenient and productive.

On its Website, Homewood uses navigational data, by means of "cookies", which are small text files a website can use to recognize repeat users. They provide the convenience to recognize visitors and more quickly provide personalized content or grant you unimpeded access to the website. With cookies enabled, you will not need to fill in information that you have already entered.

Information gathered through cookies also helps us measure use of our website. Cookie data allow us to track usage behavior and compile data that we can use to improve the site. This data will be used in aggregate form; no specific users will be tracked. Generally, cookies work by assigning a unique number to the user that has no meaning outside of the website that he or she or they is visiting. You can easily turn off cookies. Most browsers have a feature that allows the user to refuse cookies or issues a warning when cookies are being sent. However, the Website will not function properly without cookies. Enabling cookies helps ensure a smooth, efficient visit to our website.

Our Website may contain links to other sites that Homewood does not own or operate. Except as provided herein, our policy is that we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

Email Privacy

Homewood will not share or provide third parties access to emails that have been collected from Homewood email opt-in pages. All records are stored and secure on a server with Amazon Web Services, LLC in United States of America.* As referenced in section 7, security safeguards, no collection or transmission of information such as email addresses over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure, and therefore, we cannot ensure or warrant the security of any such information.

Customers can unsubscribe from Homewood email program, including emails which contain commercial electronic messages, at any time.

ADDITIONAL INFORMATION

Please contact us if:

  • a)you have any questions or comments about this Privacy Notice, or how your privacy is protected at Homewood;
  • b)you wish to opt-out of marketing print, emails, or access, update, and/or correct inaccuracies in your personal information; or
  • c)you otherwise have a question or complaint about the manner in which we treat your personal information.

We suggest that you review this Privacy Policy periodically as we may update it from time to time. We may amend this Policy from time to time. We will post the revised Policy on our website www.homewoodhealth.com. This Policy does not cover personal information collected or held by Homewood about its employees.

For more information regarding the Homewood Privacy Policy, please contact the Homewood Chief Privacy Office by email at: Privacy@HomewoodHealth.com or by mail at: Homewood Health Centre, 150 Delhi Street, Guelph, Ontario, N1E 6K9, Attention: Chief Privacy Officer

*Homewood Health acknowledges the Service Provider has adopted and confirmed they are complaint with Canada’s Personal Information Protection and Electronics Documents Act (PIPEDA) or other provincial and/or jurisdictional legislation or regulations which are deemed to be substantially similar to PIPEDA.