Privacy Policy
Effective Date: April 1, 2022
This privacy policy governs your use of the software application Ned Clinic (“Application”) that was created by the Centre for Global eHealth Innovation and the University Health Network (UHN) in collaboration with Niagara Health System (NH), Trillium Health Partners (THP), the Southern Alberta Institute of Urology (SAIU) at Rockyview General Hospital, and the Centre of Applied Urology Research at the Queen Elizabeth II Health Sciences Centre (QEII). The Centre for Global eHealth Innovation is a digital health research and development group that is hosted at UHN.
Ned Clinic is intended to support prostate cancer patients who are in the survivorship phase of their cancer journey. The Ned Clinic system consists of a patient-facing application (Patient Application) as well as a clinician-facing Dashboard (Clinician Dashboard).
Ned Clinic is intended to facilitate the delivery of virtual follow-up care for prostate cancer patients, and to improve clinical management by sharing health information with their clinicians. Health data shared with their clinicians include patient-reported symptoms and lab results. In Ontario, Ned Clinic interfaces with the Ontario Laboratory Information System (OLIS) to query prostate-related lab results. Outside of Ontario, lab results are independently uploaded to the Ned Clinic platform by the appropriate staff.
Based on the results of the patient-reported outcome survey and lab tests, clinicians would then generate a care plan, in the form of a doctor’s note, for patients to view on the Patient Application. The feedback in the doctor’s note may tell patients of their next virtual follow-up visit date, schedule a phone or video call, or tell patient that an in-person visit is needed.
Ned Clinic is not a medical device, and is not intended to diagnose, cure, mitigate, treat or prevent disease or other conditions.
Our Commitment to Privacy
This Privacy Policy gives you information on how the Ned Clinic collects, manages, and protects your data, including any Personal Health Information, which you share within the Application, and further describes which specific data may be shared with others, as well as what data will not be shared, and how you are able to control and manage this sharing.
When you choose to create an account with the Ned Clinic, you will need to agree to this Privacy Policy and to the Terms and Conditions (which is presented separately). By agreeing to the Privacy Policy, you are providing consent for your Personal Health Information to be stored and used by Ned Clinic as presented below.
Data Collection & Usage
Registering for an Account
If you agree to use the Ned Clinic to complete your follow-up visits, you will be required to provide your full name, email address, birth date, province, and provincial health insurance number, to the Ned Clinic Coordinator. This information will be used by the Ned Clinic Coordinator to create your account in the Ned Clinic system. Subsequently, you will receive a registration email at your provided email address. Without this information, the Ned Clinic Coordinator will not be able to create an account for you, and you will not be receiving a registration email.
Setting up your Account
Once you receive the registration email, there will be a link where you will able to set up your account in the Ned Clinic. In this link, you will be required to verify your identity by providing your birth date and provincial health insurance card number. Once verified, you will be asked to create a password and set security questions for your account in the Ned Clinic.
Once your Ned Clinic account is set-up, you will be able to complete your virtual follow-up visits on this Application.
Completing Tasks
At the beginning of each virtual follow-up visit, you will be asked to complete a patient-reported symptom survey, which provides the Application with your Personal Health Information, and to get a blood test at your community or hospital’s lab centre.
You will be asked to complete the Wellness Survey:
• This survey allows you to report on any physiological symptoms that you may be experiencing as a prostate cancer survivor. The survey responses that you provide in the Application will be stored in your account for you to view, and are also sent to your clinician to review and assess your health progress.
You will be asked to take a blood test at your community or hospital’s lab centre:
• To get a blood test, you will be required to bring your personalized lab requisition form to a community or hospital’s lab centre. The Application provides you with your personalized lab requisition form as your clinician generates this form for you in the Ned Clinic system. You will be able to download your lab requisition form onto your device.
Receiving Lab Results
Once you have completed your lab test at a lab centre, your prostate-related lab results will be made available for you and your clinician to view in the Ned Clinic system.
In Ontario, this is possible through our partnership with Ontario Health, which allows the Ned Clinic system to interface with Ontario Laboratory Information System (OLIS). Outside of Ontario, your clinician will manually collect and upload your lab results to the Ned Clinic system.
You can use view your most recent and past prostate-related lab results in the Application. Your lab results will also be shared with your clinician during each virtual follow-up visit to assess your health progress.
Receiving Doctor’s Note
Your survey responses and lab results will be shared with your clinician. Based on this information, your clinician will assess your health progress and create a care plan, in the form of a doctor’s note, for you to view in your account of this Application. The information provided in the doctor’s note may tell you of your next virtual follow-up visit date, or request to schedule a phone call, video call, or in-person visit with you. Upon receiving a doctor’s note, your most recent virtual follow-up visit will be complete.
The information you provide and receive in the Ned Clinic is considered Personal Health Information. This includes your registration information (e.g., name, email address, birth date, province, provincial health insurance card number), your prostate cancer related health information (treatment group, virtual follow-up visits, survey responses, lab requisition, lab results, doctor’s notes), and other personally identifiable information. Together such information is referred to as “Personal Health Information” (or “PHI”) within this Privacy Policy.
Automatically Collected Information
Ned Clinic collects certain information from you automatically, which is limited to analytics around the Application screens you use. This automatically collected data will only be used by the administrative team within UHN responsible for maintaining the Application, and for hosting the data submitted to the Application, and may include third party agents of UHN, acting solely on UHN’s behalf and will only be used for system administration purposes, with access to such data will be limited to diagnosing problems with servers (such as software bugs), if any; to monitor traffic patterns; to determine which services are used most frequently; to assess site usage; to help to improve the usability of the Ned Clinic.
By creating an account with the Ned Clinic, you are agreeing to the automatic collection of the data listed above, solely for use by the Application Team.
In addition to the use of the Automatically Collected Data described above, the Application Team may also use information provided by you in response to the patient-reported symptom survey that has been stripped of all directly identifying personal information (such as your name, email address and other information which directly identifies you) for the purposes of improving the quality of the Application.
Cookies
Ned Clinic may use “cookies” for the convenience of users and to enhance your experience using this Application. A cookie is a small text file that is recorded either temporarily or persistently on your computer by a web page server and is not intended to deliver viruses or other harmful programs to your computer.
On the Ned Clinic, cookies are used primarily for authentication and security purposes:
- Cookies are used to avoid signing into your account repeatedly with 1+ authentication within a period of 30 days. By using cookies, Ned Clinic is able to deliver a more efficient service that is more personalized for each user.
Web browsers generally accept cookies automatically. When you sign in to the Ned Clinic, you can:
- Opt for the Application to remember you and then it will use cookies to do so
or
- If you prefer, you may choose to set your web browser to decline cookies
or
- You may be able to modify your browser setting to notify you each time a cookie is created and permit you to accept or decline cookies on an individual basis or to accept cookies from web sites that meet certain disclosure and use specifications.
Note that some functionality of Ned Clinic may be limited if you direct your browser to reject all cookies.
How We Share Your Data
With Your Clinician and Ned Clinic Coordinator
Only with your explicit consent when you are providing registration information to the Ned Clinic Coordinator and by agreeing to the Terms and Conditions when you are setting up your account, will Ned Clinic share your Personal Health Information with your clinician and Ned Clinic Coordinator, who is working on behalf of your clinician.
With Ontario Laboratory Information System (OLIS)
In Ontario, Ned Clinic uses your provincial health insurance card number to retrieve your prostate-related lab results from OLIS. By doing so, you and your clinician can view your lab results in the Ned Clinic system, and allow your clinician to complete their assessment of your health progress for your virtual follow-up visits.
With Third Parties
We will not sell, rent, or share your Personal Health Information with third parties other than as outlined herein.
We may disclose your Personal Health Information as required by law, such as to comply with a subpoena, or similar legal process.
How You Can Control Your Data
You will have control over your Personal Health Information. If at any point you identity information that needs to be corrected, you can contact the Ned Clinic Support Team by email at support@nedclinic.ca
Participation
Participation in the Ned Clinic is voluntary. If you decide at any point that you no longer want to complete virtual follow-up visits in the Ned Clinic, and you want to return to in-person follow-up visits, you may do so by calling your doctor’s office to pause your Ned Clinic account and make an appointment for you return to an in-person follow-up visit.
How We Store Your Data
All information gathered from you will be stored and processed in Ontario, Canada on University Health Network servers. If you access your account in the Ned Clinic from a location other than Canada, your information will be transferred to Canada. Ontario and Canadian law are different from that of other jurisdictions. Ontario and Canadian laws apply.
Ned Clinic may retain your PHI for as long as you use the Application. You may submit a request with your provider to discontinue your participation in Ned Clinic, subsequently the collection of any new Personal Health Information in the Application will be stopped. Historical Personal Health Information in Ned Clinic will be handled in accordance with this Privacy Policy.
When a patient is discharged from the program, we will retain the records for at least ten years as per UHN policy.
How We Keep Your Data Secure
Ned Clinic has implemented security measures intended to protect your Personal Health Information both online and offline, including measures intended to restrict unauthorized persons from accessing Personal Health Information. Encryption technologies are used when transferring and receiving data provided through Ned Clinic. We also have security measures in place at our physical facilities to protect against the loss, misuse, or alteration of Personal Health Information stored at Ned Clinic. We also have restricted access to the servers to the Application Team, and have the ability to audit who accesses your data and when. Although we have implemented various measures to protect your information, Ned Clinic does not and cannot guarantee absolute security of any information.
Theft, Loss or Unauthorized Access of Your Information
In the event that UHN becomes aware that your Personal Health Information submitted through Ned Clinic has been stolen or lost, a person has obtained unauthorized access to it, or someone has used, disclosed or disposed of in in a manner other than as described in this policy, UHN will investigate the incident and notify you if a breach has occurred. If you become aware of any unauthorized use of your Personal Health Information submitted through this Application, please immediately notify UHN Privacy Office at the address below.
Modifications and Updates to the Privacy Policy
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the updated version here and informing you via Ned Clinic’s website. We are also, by virtue of your registration with the Application, confirming your permission to notify you through email, that you provide to us when registering, of any changes to, or requests to update or expand your consent as outlined in this document. Please also check this Privacy Policy regularly for any changes.
Applicable Law
This Privacy Policy governs your use of the Application. This policy was created by the Centre for Global eHealth Innovation, UHN in compliance with requirements of Ontario’s privacy legislation, the Personal Health Information Protection Act (PHIPA). Without regard to conflicts of law principles, and exclusive jurisdiction and venue for any dispute arising out of this Privacy Policy, shall be the Provincial courts of Ontario or Federal courts of Canada.
Contact Us
For information, questions, or complaints, please write to:
University Health Network
Centre for Global eHealth Innovation
Toronto General Hospital,
R. Fraser Elliot Building, 4th Floor
200 Elizabeth St.
Toronto, Ontario, M5G 2C4
Telephone: 416-340-4800 ext. 4765
Email: support@nedclinic.ca
For more detailed information about who sees your information and about your choices, please contact the Privacy Office at any of the following institutions:
University Health Network Privacy Office:
Telephone: 416-340-4800 ext. 6937
Email: privacy@uhn.on.ca
Complaints
If you have complaints about UHN’s compliance with this privacy policy or PHIPA, please contact UHN’s Privacy Office at the above contact information as appropriate. Further questions and concerns can be directed to the Office of the Information and Privacy Commissioner of Ontario at:
2 Bloor Street East
Suite 1400
Toronto, ON
M4W 1A8
Phone: 1-800-387-0073
Website: www.ipc.on.ca
Last Updated on April 1, 2022