修订日期：2014年5月12日
一、总则
ProResp Inc. 坚信，没有信任，就无法建立长久的业务关系。我们致力于与客户、业务合作伙伴、网站访客和员工建立并维持友好、值得信赖的关系。
在隐私政策中，“我们”和“我们的”指的是 ProResp Inc.
我们保留随时修改隐私政策的权利，恕不另行通知。这些修改仅影响修改生效后提供的个人信息。
加拿大《个人信息保护和电子文件法》规定了各组织必须遵循的原则。这些原则以及我们目前与每项原则相关的实践描述如下。我们还在下方列出了我们目前与通过电子邮件或网站向我们披露的个人信息相关的实践。
二、原则
1. 个人信息责任
我们负责维护和保护您的个人信息。我们从客户、业务合作伙伴或网站访问者处收集的信息与员工信息不同。在本政策中，“个人信息”是指可识别个人身份的信息，例如：年龄、家庭住址、家庭电话号码、出生日期、个人电子邮件地址、健康卡号以及相关健康信息。一般而言，个人信息不包括员工或组织的姓名、职称、办公地址、办公电子邮件以及办公电话或传真号码等。
我们已任命一名隐私官，以确保我们的组织继续对您的个人信息保持适当的安全。
2. 明确目的
- 我们在收集个人信息之前或收集时明确其收集或使用目的。一般而言，我们收集信息用于以下目的：
- 获取有关我们客户的相关信息，从而确保我们提供服务的能力；
- 在您同意的情况下与您沟通，以开发、增强、营销或提供产品或服务；
- 了解您的需求和偏好，包括自愿调查、研究和评估；
- 满足法律或监管要求，包括保护或捍卫合法权益；
- 处理和跟进信息请求，或；出于您同意的或本隐私政策中确定的任何其他目的，我们可能会不时向您表明
- 信息收集自您自愿，也可能通过第三方获取。例如，医生或其他医疗保健专业人员提供的任何相关医疗信息就属于从第三方收集的信息。
3. 同意
我们将确保仅在您同意的情况下收集信息，并确保您了解所提供信息的用途和用途。在某些情况下，我们会在信息收集后、使用前征求您的同意。您可以在特定法律限制内全部或部分撤回您对我们使用您个人信息的同意。
4.限制收集
我们将限制所收集的信息，使其仅限于确定目的所必需的信息。
5. 限制使用、披露、保留和使用例外，但须遵守以下使用例外情况，
- 除非法律要求征得您的同意，否则我们不会将信息用于收集目的以外的其他目的；
- 我们不会出售或出租您的个人身份信息
- 我们不会与外部各方共享您的个人信息，除非经确定并获得书面同意
- 我们将仅在实现已确定的目的所必需的时间内或根据法律的要求保留您的信息。
6.准确性
无论您的个人信息以何种方式收集，我们都将竭尽全力确保其准确、完整且最新。如有任何信息变更，请务必通过您的医疗保健专业人员或直接告知我们。
7.保障措施
建立并维护您的信任的关键因素之一是保护您的个人信息。我们已建立包括办公室访问权限、数据记录和密码在内的控制措施。我们的员工仅可在履行职责、为您提供服务时访问您的个人信息。
8.开放性
您可以通过书面请求访问您的个人信息。如果您对其准确性或完整性有任何疑问，我们将在收到您的书面请求后 30 天内回复。
9. 个人访问
您可以通过书面请求访问您的个人信息。我们将在收到您的书面请求后30天内回复。我们预计大多数问题都可以通过电话解答。我们致力于快速解答任何问题，从而澄清或解释我们的隐私政策。
10. 质疑我们的合规性
我们向您保证，我们将竭尽所能与您保持信任关系。一旦您提出请求，我们将立即进行调查，并就我们个人信息保护政策的任何方面做出解释。
欢迎您就隐私问题提出疑问。患者、业务合作伙伴和员工可以联系当地分支机构或隐私官：
privacy@proresp.com
隐私官
#1 1909 牛津街东
伦敦，ON N5V 4L9
519-686-2615 分机 1194
III. 网站具体实践
外部连接
为了您的方便，我们的网站可能包含第三方网站的链接。您应该查看这些第三方网站的隐私政策，因为他们的隐私政策可能与我们的不同，并且我们不控制这些第三方网站或其隐私惯例。
我们不对其他网站的隐私惯例负责，并且我们不认可或对第三方网站做出任何陈述。
请注意，通过电子邮件或通过我们网站传输给我们的个人信息均未经加密。换言之，这些信息不会被转换为代码文本，而是以您在我们网站上提交的相同形式发送。虽然第三方拦截传输的可能性不大，但这种情况始终存在。
As used in this Patient Privacy Notice (“Notice”), the terms “we”, “us”, and “our” mean ProResp. At ProResp, privacy is important to us, and we are committed to protecting your privacy and ensuring the confidentiality of your Personal Health Information to provide excellent care.
For the purpose of this Notice, “Personal Health Information” or “PHI” shall mean identifying information about an individual that relates to: the individual’s physical or mental health, the provision of healthcare to the individual, payments or eligibility for health care, the individual’s health number (ex. health card number), or the identity of the individual’s substitute decisionmaker, or as otherwise defined by applicable privacy legislation.
This Notice complies with the Personal Health Information Protection Act, 2004 (“PHIPA”)
We collect Personal Health Information that you voluntarily provide us either directly or from the person acting on your behalf (ex. substitute decision maker). We may also collect your Personal Health Information from other sources if the law permits or we have your consent to do so. ProResp collects, uses, and discloses PHI with consent or as otherwise permitted or required by PHIPA.
ProResp may rely on express or implied consent when collecting, using, or disclosing PHI for the purpose of providing patient care.
Collection of your PHI
To provide you with quality health care, we collect your Personal Health Information in line with PHIPA:
- Direct Collection: We collect information from you when you provide it to us directly.
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Indirect Collection: As permitted by PHIPA, we may collect PHI indirectly from other sources - such as other health information custodians within your circle of care - for the purpose of providing health care, if we have your consent or where the law permits or requires it.
How we Use and Disclose or Share your PHI
Your Personal Health Information is primarily used and shared for the purpose of providing health care, which includes administration activities necessary for your treatment and care (ex. billing and scheduling). This includes communicating with other health care providers who are involved in your care.We will not use your Personal Health Information for new purposes without your express consent.
We may share your information with:
- Legal or regulatory bodies: if necessary to comply with laws, for example, in response to a subpoena or government request.
- In a business transfer: such as a merger or acquisition. We will notify you of such a change in ownership or transfer of assets, to the extent we are able to do so.
- Other companies within our corporate group, where necessary to provide requested services or for internal administrative purposes.
We are accountable for all Personal Health Information under our control, including information transferred to a third-party for processing. We do not sell your Personal Health Information.
Disclosures without Consent
We may disclose your Personal Health Information without your consent to:
- Your legal guardian or substitute decision-maker
- Report suspected abuse
- Report certain diseases to public health authorities
- Prevent serious bodily harm to you or others
At ProResp, we only collect photographic records when necessary for your care, such as for identity verification. To protect the privacy of our patients and staff, no other photography, video or audio recording is permitted during the provision of services to a patient without express permission.
How We Protect Personal Health Information
ProResp is committed to safeguarding your Personal Health Information through the following measures:
- Robust measures are implemented to protect your Personal Health Information from theft, loss and unauthorized access.
- Regular audits and reviews are conducted to monitor, assess and strengthen privacy compliance.
- Personal Health Information is used strictly for purposes to which individuals have consented, in accordance with applicable privacy legislation.
- Personal Health Information is retained only for as long as necessary and disposed securely when no longer required.
All staff receive ongoing training to ensure understanding of responsibilities and protection of your Personal Health Information.
We maintain administrative, physical and technical safeguards consistent with legal requirements and recognized privacy standards.
You or a person who can make decisions for you about your Personal Health Information have the right to:
- Access a copy of your Personal Health Information in our custody, subject to limited exceptions.
- Request a correction to your Personal Health Information if you believe it is incomplete or inaccurate for the purposes for which we use it. If a correction is denied, we will attach your Statement of Disagreement to the record.
- Withdraw or withhold consent (the “Lockbox” right) at any time for the collection, use or disclosure of your Personal Health
- Information for health care purposes, subject to legal requirements and the potential consequences for the provision of your care.
- Be notified if your Personal Health Information is stolen, lost or used or disclosed without authority, subject to the notification requirements set out in PHIPA.
To exercise these rights, contact our Privacy Officer using the details provided in the “Contact Us” section of this Notice. We will respond within the required legal timelines and notify you if more time is needed. If a request is denied, we will explain why and inform you of your available complaint options, including how to contact the relevant authority.
Please be aware that certain rights are subject to limited and specific exceptions set out in PHIPA and other laws.
If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Information and Privacy Commissioner of Ontario (the IPC):
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8
1-800-387-0073
www.ipc.on.ca
For privacy questions or concerns, please contact our Privacy Officer in writing at:
ProResp Inc.
1909 Oxford Street East, Unit 1 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8
London, ON N5V 4L9
Attention: Privacy Officer
Email: privacy@proresp.com
We may revise this Notice from time to time. The current version will always be posted on our website at www.ProResp.com with the date of the last review clearly indicated.
Any significant changes affecting patient rights, such as new uses or sharing of your PHI, will be communicated within a reasonable time via a summary provided during a health care appointment or a direct email notification.
Last Reviewed: March 20, 2026
Privacy Policy
I. General
We at ProResp Inc. believe there can be no enduring business relationships without trust. Our commitment to our clients, business partners, website visitors and employees, is to develop and maintain friendly, trustworthy relationships.
As used in the Privacy Policy, the terms “we”, “us” and “our” mean ProResp Inc.
We reserve the right to make changes to the Privacy Policy from time to time without prior notification. The changes will only affect personal information provided after the change comes into effect.
Canada’s Personal Information Protection and Electronic Documents Act sets out principles which organizations must follow. These are noted below along with a description of our current practices relevant to each principle as noted below. We have also noted below our current practices as they relate to personal information disclosed to us by email or via our website.
II. The Principles
1. Accountability for Personal Information
We are responsible for maintaining and protecting your personal information. The information we collect from clients, business partners or website visitors will differ from employee information. As used in this policy, “personal information” means information about an identifiable individual, such as; age, home address, home telephone number, birth date, personal email address, health card number and relevant health information. In general, personal information does not, for example, include the name, title, business address, business email, and business telephone or fax number of an employee or an organization.
We have appointed a privacy officer to ensure that our organization continues to maintain appropriate security with respect to your personal information.
2. Identifying Purposes
- We identify the purpose for which the personal information is collected or used before or at the time of collection. Generally, we collect information for the following purposes
- to obtain relevant information about our clients thus ensuring our ability to provide service;
- to communicate with you to develop, enhance, market or provide products or services, upon your consent;
- to understand your needs and preferences, including voluntary surveys, research and evaluations;
- to meet legal or regulatory requirements, including to protect or defend a legal interest;to process and follow up on information requests or; for any other purpose we may indicate to you from time to time to which you have provided your consent, or as identified in this Privacy Policy
- Information is collected voluntarily from you and may also be obtained through a third party. An example of information being collected from a third party would be any relevant medical information provided from a physician or other health care professional.
3. Consent
We will ensure that information is only gained with your consent and that you have knowledge of the purpose and use of the information which you provide. In certain circumstances, consent is sought after the information has already been collected but before use. You may withdraw all or part of your consent for us to use your personal information within certain legal restrictions.
4. Limiting Collection
We will limit the information we collect to that which is necessary for the purposes identified.
5. Limiting Use, Disclosure, Retention and Exceptions to Use Subject to the Exceptions to Use below,
- we will not use or disclose the information for purpose other than those for which it was collected except with your consent as required by law; and
- we do not sell or rent your personally identifiable information
- we do not share your personal information with outside parties, except as identified and with written consent
- we will retain your information only as long as it is necessary to fulfill the identified purpose, or as required by law.
6. Accuracy
Regardless of how your personal information is collected we will do our best to ensure it is accurate, complete and up to date. It is important that you let us know, through your Health Care Professional, or directly, of any changes to this information.
7. Safeguards
One of the key elements in establishing and maintaining your trust is the protection of your personal information. We have established controls including the access to our office, data records and passwords. Our employees have access to your personal information only for the purposes of performing their duties in providing service to you.
8. Openness
Your may request access to your personal information through a written request. Should you have any questions about its accuracy or completeness we will respond within 30 days of receiving your written request.
9. Individual Access
You may, access your personal information through a written request. We will respond within 30 days of receiving your written request. We expect that most questions can be answered by a telephone call. We are committed to quickly answering any questions, thereby clarifying or explaining our privacy policies.
10. Challenging Our Compliance
You have our assurance that we will do everything possible to maintain a relationship of trust with you. Upon your request we will immediately investigate and respond with our explanation of any aspect of our policies for the protection of your personal information.
We welcome your privacy questions. Patients, business partners and employees may contact their local branch office or the Privacy Officer at:
privacy@proresp.com
Privacy Officer
1909 Oxford Street East, Unit 1
London, ON N5V 4L9
519-686-2615 ext. 1194
III. Website Specific Practices
External Connectivity
For your convenience, our web site may contain links to third-party web sites. You should review the Privacy Policy of these third-party web sites as their Privacy Policy may differ from ours and we do not control those third- party webs sites or their privacy practices.
We are not responsible for the privacy practices of other web sites and we do not endorse or make any representations regarding third party web sites.
Keep in mind that personal information transmitted to us by e-mail or otherwise through our web site is transmitted without encryption. In other words, the information is not converted into code text but instead is sent in the same form as submitted by you on our web site. Although it is unlikely that a third party will intercept the transmission, there is always a possibility of that occurring.
Last Reviewed: May 12, 2014