Privacy Statement

 

Last Revised:  June 2013

Thank you for visiting the Telemedicine Centre website (the "Website") of the Ontario Telemedicine Network ("OTN", "we" or "us"). This Privacy Statement sets forth the online data collection and usage policy and practices that apply to the Website.

OTN places a high value on privacy and is committed to respecting the privacy of our users. The purpose of this Privacy Statement is to inform you about the types of Personal Information that OTN collects, uses and discloses through the Website.  It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.  By visiting or using our Website, you consent to the practices described in this Privacy Statement.

From time to time, we may make changes to this Privacy Statement.  The Privacy Statement is current as of the "last revised" date which appears at the top of this page.  We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected and our Privacy Policy, unless we have your consent to treat it differently.  This Privacy Statement applies to any information we collect or receive about you, from any source.

"Personal Information"

"Personal Information" means information about an identifiable individual. This information may include but is not limited to your name, home address and content that you post on this Website.  Personal Information, however, does not include your name or your business title, business address or business telephone number in your capacity as an employee of an organization (if applicable).

Collection of Personal Information

We will always collect your Personal Information by fair and lawful means.  We do not automatically collect Personal Information. Personal Information is only collected if you supply it voluntarily. OTN collects   Salutation, First & Last Name, Middle Initial, Profession, Provider Service, Organization Name and Address, City, Province, Postal Code, Phone, Fax, and Email to register you for a Telemedicine Account.

Use of Personal Information

We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.  We generally use your Personal Information for the following purposes (the "Purposes"):

·                     to validate and authenticate your identity to ensure authorized access to OTN information systems and assets;

·                     to maintain and manage your user account;

·                     to respond to your inquiries;

·                     to send you communications concerning the Website;

·                     to send you information about OTN's services; and

·                     to evaluate the utility of the Website based on what areas you visit and what services you access.

OTN will not use your Personal Information for spamming, unsolicited bulk or commercial email, or third-party or commercial marketing purposes.

Disclosure of Personal Information

We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. 

For example, we may disclose your Personal Information 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 – for example, service providers may be used to administer the Website and data storage. OTN may disclose Personal Information to e-Health Ontario's ONE ID Service for the Purposes and provide you with ONE ID account credentials to access OTN information systems and assets.

We will only make disclosures of Personal Information to such persons for which you provide your consent.  Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquiror in connection with a transaction involving the sale of the operations of OTN or as otherwise permitted or required by law.

OTN will not disclose your Personal Information to a third-party for marketing purposes.

In addition, we may send Personal Information outside of the country for the Purposes, and you should note that while such information 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.

Consent

Generally, we obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose, unless otherwise required or permitted by applicable law.  You may provide your consent to us either orally, electronically or in writing.

Security of Personal Information

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification.  The only personnel who are granted access to your Personal Information are those with a business ‘need-to-know' or whose duties reasonably require such information.

We store the Personal Information that we collect in a database on a secure server. Our service providers may, from time to time, also hold your Personal Information in connection with purposes for which you provided your consent.

We ensure that all affiliates and other third parties that are retained to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Statement and our Privacy Policy and practices.

We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

Access Requests and Accuracy of Personal Information

If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by law.  We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible.  We will not routinely update your Personal Information, unless such a process is necessary.  We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

At any time, you can challenge the accuracy or completeness of your Personal Information in our records.  If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required.  Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

We will attempt to respond to each of your written requests not later than thirty (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 federal Privacy Commissioner in respect of this time limit.

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information.  Any such identifying information shall be used only for this purpose.

Linked Websites

The Website may contain links to external websites. OTN is not responsible for the privacy practices or the content of any other website.  This Privacy Statement does not apply to other websites.

Cookies

In order to evaluate the Website, and for site security and law enforcement purposes, OTN may collect certain information from your computer, including, without limitation, your IP address, browser type, domain names, access times and referring website addresses. To obtain this technical information, OTN may use various kinds of software devices, including "cookies." A "cookie" is a small text file that is stored on a user's computer for record-keeping purposes. We do not link the information we store in cookies to any Personal Information you submit while on the Website.

We use both session ID cookies and persistent cookies.  We use session cookies to make it easier for you to navigate the Website. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "Help" file.  We use persistent cookies to allow subscribers to navigate based on past usage to provide ease of use for return visits to the Website.

You can set your browser to disable cookies, but this Website may not function properly if you do this.

Privacy Officer

All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and practices, should be forwarded to our Privacy Officer as follows:

Ontario Telemedicine Network

105 Moatfield Drive, Suite 1100

Toronto, ON    M3B 0A2

Attention: Chief Privacy Officer

E-mail: information@otn.ca.