At Regional Fertility Program (we, us, and our), we are committed to providing our patients and their families (you and your) with exceptional service. To be able to provide this service, Regional Fertility Program collects, uses and discloses your Personal Information (as defined below), including your health information, in accordance with this Policy.

This Policy, in compliance with applicable law, including Alberta’s Health Information Act (HIA), outlines the principles and practices we will follow respecting Personal Information.

The term Personal Information means any information that on its own or when put together with other information, allows you to be identified. The types of Personal Information we collect includes:

• general personal information (e.g., name, date of birth, home address, telephone numbers, identifying numbers such as health numbers, billing information and related information);
• personal health information (e.g., information related to your fertility and other presenting issues, your health history, health conditions, and health services, diagnoses, treatments and interventions provided to you);
• information about your family relationships, personal goals, and the like;
• credit and financial information, such as credit card information;
• general feedback and information requested by or provided to you; and
• other information that may be necessary when required or permitted by law.

When you utilize our web portal, we collect Personal Information necessary to enable its use, including Personal Information collected through its messaging feature and the exchanging of documents containing Personal Information.

As part of the web portal, you may book services online. When you book services online, we collect Personal Information necessary to provide you with the service you have requested.  We may also collect information such as time of day, browser type and IP address when you browse our site.

When we provide services to you, we generally rely on consent to permit us to collect, use and disclose your Personal Information.  Your consent may be implied, based upon your actions, or explicit through an agreement.

Typically we obtain your consent from you directly. If we plan to use or disclose your Personal Information for a purpose not previously identified (either in this Policy or separately), we will advise you of that purpose before such use or disclosure, unless the law authorizes the collection, use or disclosure without your express consent.

IV. Sources of Personal Information

We collect Personal Information from the following parties, where authorized:

• you directly, before or in the course of providing health care and related services to you;
• your other health care providers;
• your spouses/partners who are authorized to disclose your Personal Information to us;
• your insurers or benefits providers, credit card or other payment providers; and
• other third parties who are authorized to provide your Personal Information to us.

We collect, use and disclose Personal Information to enable us to manage, maintain and deliver services to you, including to:

• establish, maintain and manage our relationship with you so that our health services providers can provide you with diagnoses, care, treatment and other health care services;
• enable us to carry out administrative and operational functions as necessary for the provision of services, including scheduling, administering referrals, evaluating status and content of health services, managing clinical records, processing of invoices, payments from you or your insurance provider and the collection of unpaid accounts;
• review the diagnoses, treatment and services that we or our health services providers provide to you so that we may understand your requirements for these services, for training, quality improvement, audit and educational purposes, and so that we may work to improve our and our health services providers’ service delivery;
• seek feedback from you on our health care services, including through the use of surveys and virtual communications sent our behalf, for internal management purposes, so that we may work to improve our and our health service providers’ service delivery,
• seek a review or rating from you on our health care services, including through the use of virtual communications sent on our behalf, for commercial and marketing purposes;
• provide services through the use of our web portal, including providing instructions regarding testing, appointment reminders, and details regarding treatment;
• comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
• protect us against error, fraud, theft and damage to our goods and property;
• comply with our professional and regulatory duties, including under health, insurance, environmental, health and safety, privacy, employment and other applicable laws and regulations;
• comply with the rules, regulations, guidelines and codes of Colleges, boards and associations governing Regional Fertility Program’s health services providers;
• if required to do so by law or in the good faith belief that such action is reasonably necessary to comply with legal processes; and
• to enable us to meet any other reasonable purpose.

From time to time we may be involved in research studies related to fertility and reproductive health, and sometimes there are opportunities for our patients to become participants in such studies.  We do not use patient Personal Information for the purposes of research unless we first notify you and get your express consent

VI. Prescribed Health Information

Alberta’s Health Information Act defines Prescribed Health Information as health information about an individual that is of a class or type prescribed by the regulations that a regulated health professional or an authorized custodian may or must make accessible to authorized custodians via the Alberta Electronic Health Record. Where your Personal Information is Prescribed Health Information, Regional Fertility Program may be required to make your Personal Information accessible to authorized custodians through the Alberta Electronic Health Record. The expressed wishes of the patient will be considered when making your Personal Information accessible.

We may share your Personal Information with other Regional Fertility Program’s affiliates, authorized contractors, service providers, and other third parties for the purposes described in this Policy and in accordance with applicable law.

We share your Personal Information with affiliates, authorized contractors, service providers, and other third parties we use to support the operation of our business, and who are under statutory and / or contractual obligations with respect to the protection, use and confidentiality of your Personal Information.

RFP shares Personal Information with the following types of affiliates and service providers. RFP may engage additional or different service providers from time to time and will update this Policy accordingly.

Some of our staff members, affiliates, contractors and service providers may be located outside of Canada, including in the United States. Personal Information outside of Canada is subject to the laws in the foreign country that may allow law enforcement, courts, and regulatory agencies to access the Personal Information. If you would like more information, please contact our privacy team at the address under “Contact Us”.

We understand the importance of protecting Personal Information. For that reason, we have taken the following steps to secure your Personal Information:

• your Personal Information recorded on paper is under supervision or secured in a locked or restricted area; and
• we store your Personal Information recorded in electronic form on secure servers managed by a third party IT service provider. This data is then periodically backed up to a secure cloud based storage system managed by a third party cloud storage service provider.

Our staff is trained to collect, use and disclose Personal Information only as necessary to fulfill their duties and in accordance with our Policy. We use commercially reasonable efforts to limit access to your Personal Information to staff members that have a valid business reason for accessing the information, and to ensure that Personal Information in our control is reasonably protected against accidental or unlawful loss, access or disclosure.

Where we provide services to you through virtual means, we obtain a specific consent that explains the limits on our ability to protect data sent or received using those methods.

IX. Retention and Destruction of Personal Information

We keep your Personal Information for a reasonable period of time after it is no longer needed to fulfill the purposes identified, and in accordance with relevant laws. Where there is no longer a business or legal purpose for us to keep your Personal Information, it will be securely destroyed, erased or anonymized so that it no longer identifies you, in accordance with our record retention obligations and practices. Where allowed by law, we may anonymize your Personal Information so that it cannot identify you and retain the anonymized information for statistical purposes. Anonymized information cannot be linked to an identifiable individual, and is not Personal Information.

X. Access to Your Personal Information

When requesting access to your Personal Information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the Personal Information that we hold about you. Where allowable, we may charge you a fee to access your Personal Information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our privacy team.

In Canada, patients have a right to access the information in their medical record. However, an individual’s rights of access are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Information that we hold. In addition, we cannot give access to Personal Information we no longer hold, ie., if the Personal Information has been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you believe there is a mistake in the Personal Information that we have retained, subject to the laws of your jurisdiction, you may have the right to ask for it to be corrected. This only applies to Personal Information, and not to any professional opinions we may have formed. We may ask you to provide documentation evidencing that the Personal Information is incorrect. Where we agree that your Personal Information should be corrected, we will make the correction and make reasonably commercial efforts to notify anyone to whom we have sent this information within the previous year. If we do not agree, we will note this in the file, and will similarly make reasonably commercial efforts to notify anyone to whom we have sent this information within the previous year.

XI. Contacting Us

Our privacy team can be reached at hharrison@regionalfertilityprogram.ca

If you wish to make a complaint about our Policy or the privacy practices it concerns, you may make it in writing to contact information outlined above. We will endeavor to ensure your complaint is investigated promptly and that you are provided with a written response addressing such complaint.

From time to time, we may make changes to this Policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your Personal Information. We will post any revised version of this Policy on our website, https://regionalfertilityprogram.ca/, and we encourage you to refer back to it on a regular basis. This Policy was last updated on September 26, 2024.