Personal information protection policy
version 2023.08.1 | Last modified August 18, 2023.
You are invited to read this policy carefully, in addition to consulting it regularly to learn of any changes that may be made to it.
This personal information protection policy (hereinafter the “Policy”) sets out how the Clinique médicale Fémina collects, uses, communicates, stores and destroys your personal information. For ease of reading, we will use the expressions “we” or “the clinic” from time to time in the Policy.
We may provide you with additional information regarding the processing of your personal information, in certain cases, at the time we collect your personal information. We may also obtain your specific consent in certain cases relating to the collection, use, disclosure and retention of your personal information.
The Policy applies to personal information we collect regardless of how, for example in person, by telephone or through our website.
By accepting this Policy or providing us with personal information after having had the opportunity to review the Policy or any additional notice, you agree that your personal information will be processed in accordance with the Policy.
1 – About us
Here are our full credentials:
Clinique médicale Fémina – 1265 Berri (suite 430), Montreal, Qc, H2L 4X4
Please do not hesitate to contact our Privacy Officer with any questions or comments you may have regarding the Policy, how we treat your personal information, or to exercise your rights regarding your personal information.
You can contact our personal information protection manager by email: Dr. Gabrielle Décary-Guimond – firstname.lastname@example.org, or by mail at the address mentioned above.
Within our clinic we have assigned roles and responsibilities as follows:
- Collection of identification data when making an appointment by administrative staff.
- Access and scanning of forms and documents by administrative staff.
- Consultation of forms and files containing personal information by clinical staff.
We train and educate our staff and professionals (including our students and interns) through the following activities:
- Annual team meeting to raise awareness among staff and our professionals of the actions taken to ensure the protection of personal information and to recall its importance in our daily practices.
2 – Important definitions
In the Policy, we mean:
- “Privacy Incident” (i) unauthorized access to personal information by law; (ii) the unauthorized use of personal information by law; (iii) the unauthorized communication of personal information by law; or (iv) the loss of personal information or any other breach of the protection of such information.
- “Personal information” any information which concerns a natural person and allows, directly or indirectly, to identify them.
3 – How will we treat your personal information ?
How do we collect your personal information?
- We collect your personal information via registration in the MYLE Patient Portal as well as by completing a questionnaire either online (available on our site and transmitted via WordPress to our Outlook inbox) or on paper.
- We can also communicate by email or SMS.
- Transmission of requests/results by fax or SRL-Optilab. We can also consult the DSQ.
- Website navigation data.
- Employees and future employees:
- Information transmitted by the individual verbally, by handwritten/printed note or by email.
What personal information do we collect?
- We collect identification data, navigation data and medical information.
- Identification data and banking data.
- Future employees:
- Identification data.
- Identification data and banking data.
From whom do we collect your personal information?
- We collect the information you provide to us directly and can consult the results available at the DSQ (only if active personnel on file).
Why do we collect your personal information ?
- We collect this data to verify the identity of our patients as well as to administer their files and to provide our services in the most optimal and secure way, as well as to respond to questions and requests.
- We may also use the information, but anonymously, for statistical purposes to evaluate our service offering.
- We also use the personal information of our employees to administer scheduling, payroll and administrative documents.
What happens if you do not consent to the collection of your personal information?
- If you do not wish to complete the questionnaire online, you can complete it by hand here at the clinic. If you do not wish to complete the questionnaire by hand, you can answer the questions verbally, the answers to which will be noted in the professionals’ notes.
- If you do not agree to identify yourself, it will not be possible to offer you services.
Who will have access to your personal information?
- Secretariat staff will have access to identification data and the “Documents” section of the EMR as well as email exchanges.
- Other health professionals (counsellors, nurses, doctors) have access to identification data, documents, results and clinical notes. They only consult them if they have to interact with you.
- Some professionals will be able to communicate with you by email or SMS.
- Only the payroll manager(s) and co-managers will have access to the banking data and payroll register of all employees.
How will we share your personal information with third parties?
- We share your information for billing purposes with the RAMQ (via Mediram billing software) or the CIUSSS Centre-Sud-de-l’île-de-Montréal.
- Appointment and contact data is shared with the EMR provider for, among other things, confirmation of appointments.
- If there are security issues or if dictated by law or law enforcement: see point 6.
How long will we keep your personal information?
- Paper files are kept for between 5 and 10 years.
- The data on the EMR will be kept for the duration of the contract and according to the ethical provisions of the CMQ.
What are the risks associated with processing your personal information?
- Low risk of data leaks.
- It is important to remember that the transmission of information by email is not completely secure. This is why it is not recommended to disclose personal information by email. Electronic messages are treated with the same confidentiality measures as mail received by post. If you transmit personal information by email or by completing an unsecured online form, the Clinique médicale Fémina team will conclude that you are giving your consent and rest assured that clinic staff members will only use the information required to respond to your request and follow up on it.
Where will we store your personal information?
- Certain information is kept in “paper” form inside the secretariat, where only people with a code can enter.
- Identification and clinical data are stored on the electronic medical record servers (EMR – MYLE (Medfar)).
4 – What technological products do we use ?
- Software name: MYLE
- Name of supplier: MEDFAR
- Utility(s): Electronic medical record
- Update schedule: Regular
- Software name: WordPress (and necessary extensions – Gravity Form / Complianz / Google Analytic / Google Tag Manager)
- Name of supplier: Gestion SFR
- Utility(s): Website / navigation data
- Update schedule: Annual
- Software name: Microsoft 365 Business Standard
- Vendor Name: Microsoft
- Usefulness(ies): Communication and clerical work
- Update Schedule: Latest – Office 2021
- Software name: Mediram
- Supplier name: Softinfo
- Utility(s): RAMQ billing
- Update schedule: Regular
- Software name: Employer D
- Supplier name: Desjardins
- Utility(s): Payroll processing
- Update schedule: Regular
5 – Security measures and inherent risks
We follow security standards in our industry to protect the information we collect and receive. In particular, we have implemented appropriate physical, technical, IT and administrative safeguards to protect your personal information against a confidentiality incident.
Despite these measures, given the risks inherent in the use of computer systems, we cannot ensure or guarantee the security and confidentiality of the information that you transmit or provide to us, and you do so at your own risk. If you have reason to believe that personal information has been compromised, please contact us using the contact information provided in section 1 of the Policy.
6 – How and under what conditions will we communicate your personal information for the purposes of public security or the prosecution of offenses ?
6.1 In case of serious risk of death or serious injury
We may communicate personal information that we hold in order to protect a person or group of people when there is reasonable cause to believe that a serious risk of death or serious injury, linked in particular to a disappearance or an act of violence, including a suicide attempt, threatens this person or group and the nature of the threat inspires a sense of urgency.
The information can then be communicated to the person(s) exposed to this risk, to their representative or to any person likely to help them. Only information necessary for the purposes pursued by the communication will be communicated.
6.2 Law enforcement
We may also communicate information to the Director of Criminal and Penal Prosecutions or to a person or group responsible for preventing, detecting or repressing crime or legal offenses when the information is necessary for the purposes of prosecution for a violation of a law applicable in Quebec.
Finally, we will be able to communicate information to a police force when it is necessary for the planning or execution of an intervention adapted to the characteristics of a person or the situation, in one or other of the following cases: 1° the police force intervenes, at our request, to provide us with help or support in the context of the services we provide to a person; 2° we act in consultation or in partnership with the police force within the framework of mixed practices of psychosocial and police interventions.
7 – Is your personal information transferred outside of Quebec ?
Your personal information will not be transferred outside of Quebec.
8 – What are your rights with regard to your personal information ?
The law gives you different rights with respect to your personal information. In particular, you have the following rights:
- Access : the right to ask whether we hold personal information about you and, if so, to request access to that personal information.
- Rectification : the right to request rectification of any incomplete or inaccurate personal information we hold.
- Withdrawal of consent : the right to withdraw your consent to the communication or use of personal information held.
- Restriction or refusal of access : the right to request that a particular stakeholder or one who belongs to an indicated category of stakeholders cannot have access to one or more pieces of information that you have identified.
- Complaint : the right to make a complaint addressed to our personal information protection manager as identified in article 1 in connection with this Policy or to file a complaint with the Commission for Access to Information of the Quebec if you believe that an infraction of the laws on the protection of personal information has been committed. To file a complaint with the Commission d’access à l’information (Québec), please use the appropriate form available at the following address: For citizens | Quebec Information Access Commission (cai.gouv.qc.ca)
- Portability : You have the right to request that your personal information be communicated to you or transferred to another organization in a structured and commonly used technological format.
To exercise any of these rights, please contact our Privacy Officer as indicated in section 1 of this Policy.
9 – How do we use browsing cookies ?
As soon as you access the Clinique médicale Fémina site, your computer and the site server automatically exchange information. However, this exchange does not allow you to be personally identified, without your having to intervene. The information exchanged is:
- the domain name;
- the IP address that could allow an Internet provider to disclose the identity of the person associated with it;
- the type of browser and operating system you use;
- the pages you visit;
- the date and time you access these pages;
- the address of the referring site from which you reached our site.
The site collects this information due to the technological requirements inherent in browsing the Internet. In fact, the server needs it to send you files compatible with the computer equipment you use. Please be assured, however, that under no circumstances will these requirements allow you to be identified.
The information is retained and used for statistical purposes. They are used to count the number of visits, the most visited pages, the technology used by these visitors, the referring sites and the country of origin of the visitors. Under no circumstances are they used to draw up lists of users.
No commercial use is made of any data collected by the Clinique médicale Fémina.
10 – Third Party Sites
This policy does not apply to any third party websites, pages or applications that may be accessed through our Services and we are not responsible or liable for any such third party services.
If you follow such links, these third party sites or services will likely have their own privacy policies which you should review before submitting your personal information.
11 – Fully automated decisions
12 – Identification, profiling, or localization technologies
Data is collected to evaluate performance, but does not contain personal data. They aim to identify which hashtags lead to our site, on what type of device people consult our site, and how many calls or site consultations are made from our company profile.
13 – Your user responsibilities
To benefit from maximum security, it is recommended:
- to use the most recent version of a browser that meets security requirements;
- clear your computer’s cache after transmitting your data;
- to keep your identification data, your access code and your password confidential (the site cannot under any circumstances be held responsible for unauthorized use of these. If their confidentiality were to be compromised, please immediately notify the site administrators to avoid fraudulent use of your identity).
We may, from time to time, modify the Policy to reflect changes in our business processes or in the law. To find out more about Bill 25, consult the Government of Quebec website.
By accessing and browsing the Clinique médicale Fémina website, you accept the terms and conditions of use found there. If this is not your intention, please leave our website.
Description and use of services
The Clinique médicale Fémina website brings together information on the services offered at the clinic as well as references for personal, non-commercial use.
The information presented on this site, intended for the general public, is legitimate, provided for strictly indicative purposes and is updated as regularly as possible. The information available on the site is chosen with caution and diligence, but the site is not immune to errors. The information contained on this site does not, under any circumstances, replace diagnosis, evaluation, treatment and follow-up by a health professional. If you need help or additional information, you are invited to consult your doctor or call the health and social services center in your area. In case of emergency, call 911 or go to the nearest hospital.
The Clinique médicale Fémina, nor its employees or administrators, can be held responsible for the consequences arising from the interpretation of the data displayed on its site. It is intended to provide information and not health advice.
No employee, manager or administrator of the Clinique médicale Fémina can be held responsible for the information contained on the site, the hyperlinks leading to it or any other actions taken following reading of the information contained on the site.
The Clinique médicale Fémina reserves the right to modify the text of the testimonies it receives without altering their meaning.
Hyperlinks and others
No products, services, sites, brands or companies are supported through the Clinique médicale Fémina website. Even if the site may refer to certain products, services, sites, brands or companies, for convenience, this does not constitute a recommendation from the Clinique médicale Fémina or its doctors. The confidentiality policy and conditions of use of the Clinique médicale Fémina site no longer apply in the event of activation of a hyperlink. The Clinique médicale Fémina is not responsible for the information associated with these links.
You are not authorized to modify, reproduce, republish, transfer, send, transmit, publish, distribute, or make works or create derivative works from the content, without the prior written consent of Clinique médicale Fémina. However, you may download, print and reproduce the content for personal use and/or as otherwise provided by law, provided that you retain all copyright and other proprietary notices it contains. Any unauthorized use of this content will infringe the intellectual property rights of Clinique médicale Fémina.
You hold Clinique médicale Fémina, its directors, its employees and its content suppliers harmless from any monetary judgment in capital, interest, legal and extrajudicial costs and any other damages, including, but not limited to, all reasonable legal costs incurred by the Clinique médicale Fémina relating to any claim, suit, action or formal notice arising from your non-compliance with these conditions of use.
These Conditions of Use as well as the Confidentiality Policy of Clinique médicale Fémina are governed and interpreted under the laws in force in the province of Quebec and the laws of Canada applicable there.
Last updated: August 2023