This Personal Information Protection Policy (hereinafter the “Policy”) sets out how GMF-U La Pommeraie collects, uses, discloses, retains, and disposes of your personal information. For ease of reading, the terms “we” or “the clinic” will be used throughout this Policy.
In certain cases, we may provide you with additional information regarding the processing of your personal information at the time it is collected. We may also obtain your specific consent in certain cases regarding the collection, use, disclosure, and retention of your personal information.
This Policy applies to all personal information that we collect, regardless of how it is obtained—for example, in person, over the phone, or via our website.
By accepting this Policy or by providing us with personal information after having had the opportunity to review this Policy or any supplementary notice, you agree that your personal information will be processed in accordance with this Policy and any supplementary notice.
1. About Us
Our complete contact information:
1599 Rue du Sud, Suite 110, Cowansville, QC J2K 2Z4
Please feel free to contact our Privacy Officer if you have any questions or comments about this Policy, about how we handle your personal information, or if you wish to exercise your rights regarding your personal information.
You may contact our Privacy Officer by phone at 450-266-4296 or by mail at the above address.
We train and raise awareness among our staff and professionals (including students and interns) through the following activities:
- Review and signing of the GMF confidentiality commitment policy;
- Reminders in the EMR regarding confidentiality obligations;
- GMF information reminders.
2. Key Definitions
For the purposes of this Policy:
- “Privacy Incident” means (i) unauthorized access to personal information by law; (ii) unauthorized use of personal information by law; (iii) unauthorized disclosure of personal information by law; or (iv) the loss of personal information or any other breach of the protection of such information.
- “Personal Information” means any information that relates to an individual and allows them to be identified directly or indirectly.
3. How We Handle Your Personal Information
How do we collect your personal information?
Our administrative staff will ask for your name and address to properly identify you. Health professionals will ask questions about your health information and are required to record it in your medical record. This information is confidential and may only be accessed by the health professionals providing you with care.
What personal information do we collect?
Name, first name, health insurance number, address, telephone number, email address, pharmacy used, personal and family medical history, vital signs. Health professionals must write medical notes containing relevant health information. Medical test and laboratory results are also included in your record. This information is only accessed by the health professionals providing you with care.
From whom do we collect your personal information?
From the patient directly, or from the person legally responsible if the patient is a minor or incapacitated.
Why do we collect your personal information?
To verify patient identity, manage patient records, and contact patients in the event of abnormal results. Medical information is necessary to fully understand your health and provide you with the best possible care, ensuring continuity of care.
What happens if you do not consent to the collection of your personal information?
We may not be able to properly identify you or contact you with important information. Without access to relevant medical information, health professionals may not be able to provide you with optimal care, which could pose a risk to your health (e.g., failure to report an allergy). Note: We no longer use paper records.
Who will have access to your personal information?
Administrative staff and healthcare providers who interact with you (nurses, physicians, pharmacists, social workers, etc.). Your personal information appears on specialist referrals and medical test requisitions (e.g., blood tests), as well as on documents for CNESST and SAAQ. Information from your record may also be shared with insurance companies, but only if you sign an authorization. Certain information must be shared with billing companies and with the Régie de l’assurance maladie du Québec (RAMQ). GMF-U La Pommeraie occasionally participates in ethics-approved research projects, in which case research staff may have access to some identifying information to seek your consent to participate.
How do we share your personal information with third parties?
Your personal information is stored in our electronic medical record (EMR). With your consent, we may use your email address to send you information. Certain data is shared with billing companies and with RAMQ. Upon request and with your signed authorization, we may share your record with insurance companies. Laboratory results and your medication list are accessible to healthcare professionals and pharmacists through the secure Dossier Santé Québec system, unless you have opted out of such sharing.
How long do we retain your personal information?
For life, as it remains available in the EMR.
What are the risks associated with processing your personal information?
Despite all measures taken, we cannot fully guarantee the protection of your personal information (see section 5).
Where is your personal information stored?
In our secure electronic medical record system.
4. What Technology Solutions Do We Use?
| Software | Provider | Purpose | Update Frequency |
|---|---|---|---|
| Omnimed | Omnimed | Electronic Medical Records | At each patient visit |
5. Security Measures and Inherent Risks
We follow industry-standard security practices to protect the personal information we collect and receive. In particular, we have implemented appropriate physical, technical, IT, and administrative safeguards to protect your personal information against a privacy incident.
Despite these measures, given the inherent risks of using IT systems, we cannot guarantee the absolute security and confidentiality of the personal information you transmit or provide to us—you do so at your own risk. If you believe that your personal information has been compromised, please contact us using the contact details provided in Section 1 of this Policy.
6. Disclosure of Personal Information for Public Safety or Law Enforcement Purposes
6.1. Serious risk of death or serious bodily harm
We may disclose personal information in our possession to protect an individual or group when there are reasonable grounds to believe that there is a serious risk of death or serious bodily harm, including a disappearance, an act of violence, or a suicide attempt, and the nature of the threat creates a sense of urgency.
In such cases, the information may be disclosed to the individuals at risk, their representatives, or anyone likely to help them. Only the information necessary to achieve the purpose of the disclosure will be shared.
6.2. Law enforcement
We may disclose information to the Director of Criminal and Penal Prosecutions or to an organization responsible for preventing, detecting, or suppressing crime or violations of the law, where the information is necessary for prosecution under Québec law.
We may also disclose information to police authorities when it is required for planning or carrying out an intervention tailored to the characteristics of an individual or situation, in either of the following cases:
- The police intervene, at our request, to assist or support us in providing services to a person;
- We act in collaboration or partnership with the police as part of joint psychosocial and law enforcement intervention practices.
7. Transfer of Personal Information Outside Québec
Your personal information may be transferred outside Québec, but only with the written authorization of the patient or their legal representative.
8. Your Rights Regarding Your Personal Information
The law grants you several rights with respect to your personal information, including the right to:
- Access: Know whether we hold personal information about you and, if so, request access to it.
- Rectification: Request correction of incomplete or inaccurate personal information we hold.
- Withdrawal of consent: Withdraw your consent to the use or disclosure of your personal information.
- Restriction or denial of access: Request that a particular professional or category of professionals be denied access to certain identified information.
- Complaint: File a complaint with our Privacy Officer (see Section 1) or with the Commission d’accès à l’information du Québec if you believe that a violation of privacy laws has occurred. Complaint forms are available here: Commission d’accès à l’information du Québec.
- Portability: Request that your personal information be communicated to you or transferred to another organization in a structured, commonly used technological format.
To exercise any of these rights, please contact our Privacy Officer as indicated in Section 1 of this Policy.
9. Use of Cookies
Our website uses cookies to collect non-identifying traffic statistics.
10. Updates to This Policy
We may update this Policy from time to time to reflect changes in our business practices or applicable law.