Privacy Policy

Approving Authority

Dean Morrison

Reference

Life Support Mental Health Inc. (“Life Support”)

Classification

Privacy and Risk Management

Date approved

May 2021

Date revised

Life Support Mental Health Inc. (“Life Support”, “we”, “our”, or “us”) has developed, and continues to develop and enhance, a suite of mental health assessment tools and services that utilize and leverage technological innovation to bridge the gap between medical and mental health care. Life Support’s proprietary on-line Mental Health Check Assessment Portal (the "Platform") and related services were developed to assist medical and mental health practitioners in the identification, assessment and triage of individuals whose health and wellbeing may be compromised as a result of mental health concerns.

At Life Support, we respect your privacy and we will manage your personal information in accordance with applicable Canadian privacy legislation and any other applicable provincial or federal legislation.

We have developed this Privacy Policy to help explain the privacy features of the Platform as well as our website https://lifesupport247.com (the "Site"). This Privacy Policy describes how Life Support collects, uses, discloses and otherwise manages your personal information, including your personal health information (as defined by applicable law) (collectively, "Personal Information") when you interact or use the Site, and/or if you use any of our products, applications (including the Platform), or any other services made available through or in relation to the Site and the Platform, including but not limited to our Mental Health Check Assessment Service, Referral Service, and Professional Services (the “Services”).

In the event of an inconsistency between this Privacy Policy and the Terms of Use (defined below) or Order Form (where applicable), the Privacy Policy shall apply to Personal Information and the Terms of Use or Order Form (as and where applicable) shall apply in all other respects. For purposes of this Privacy Policy any reference to Terms of Use shall mean either (i) our Terms of Use (Patient); or (ii) our Terms of Use (Practitioner), as the context may require.

For information on the general terms and conditions that apply to a Patient using the Platform and Services, please refer to our Terms of Use (Patient). For the purpose of this Privacy Policy, a “Patient” means an individual who has been invited to create an Account (defined below), or an individual that “self-refers” for an Account to access the Platform, for the purposes of completing a Mental Health Check Assessment and to specifically interact with a Practitioner (defined below) or to select a Referee. A “Referee” means a Practitioner on the Platform that offers psychotherapy services and has subscribed and consented to receive Patient referrals through Life Support’s Referral Services (defined below).

For information on the general terms and conditions that apply to a Subscriber (as defined in the applicable Order Form), Practitioners (defined below), or a Subscriber’s employees, contractors and agents for whom Subscriber has assumed responsibility by requesting or creating a user Account for access to and use of the Platform and Services (“Users”), please refer to our Terms of Use (Practitioner), and in the case of a Subscriber, any applicable Order Form, Statement of Work, or Change Order pertaining.

THE SITE, PLATFORM AND SERVICES MAY COLLECT AND TRANSMIT PERSONAL INFORMATION ABOUT YOU. BY ACCESSING THE SITE, PLATFORM AND SERVICES YOU ACCEPT ALL THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, YOU MUST IMMEDIATELY CEASE USING AND ACCESSING THE SITE, PLATFORM AND SERVICES AND ANY CONTENT, SERVICES, FUNCTIONALITY OR PRODUCTS CONTAINED IN OR AVAILABLE FROM THE PLATFORM FOR WHICH YOU NEED TO PROVIDE PERSONAL INFORMATION.

Personal Information

Personal Information is information that relates to an identifiable individual, including personal health information about that individual. Personal health information includes information that relates to an identifiable individual’s health (physical or mental), including family health history, medical treatment and care information, and information like an individual’s personal health number.

Life Support’s Platform and Services

Life Support’s Platform is a SaaS platform through which Practitioners licensed to use the Platform, excluding Referees, are provided with the ability to refer Patients to an online mental health assessment tool (the Mental Health Check Assessment and related services), which is designed to assess the state of a Patient’s mental health across a spectrum of specific measures and if needed, triage that Patient to qualified, independent, professional mental health support. The Platform and Services are generally licensed for use by licensed or certified medical or mental health care professionals (the “Practitioner”).

Life Support makes the Mental Health Check Assessment available to Patients for use or completion on the Platform. Through the Platform, Life Support facilitates Patients and Practitioners being able to access and use the Mental Health Check Assessment, including the facilitation of assessment review services by Practitioners (the “Mental Health Check Assessment Service”). The Platform can also serve to facilitate the potential referral of a Patient to a Referee (“Referral Services”), where follow-up treatment is recommended or required. Life Support may also provide additional services identified in any Statement of Work or Change Order (the “Professional Services”).

Life Support further enhances its service offering to Subscribers by offering optional add-on subscription access to a web and mobile based solution managed and hosted by a third-party, OnCallHealth Inc. (“OnCall” or the “Virtual Services Provider”). The Virtual Services Provider allows Subscribers and Practitioners to enhance their service through the use of secure video consultations, instant messaging, secure file sharing, interactive forms and scheduling (the “Virtual Services”), thereby allowing the Practitioner and their Patients to consult each other from the privacy and convenience of the location they choose.

Getting Your Consent

There are various ways that you may consent to the collection, use and disclosure of your Personal Information processed through the Site, Platform and/or Services provided by Life Support.

Typically, Patients will voluntarily provide information for use by their Practitioner, as is the case when completing a Mental Health Check Assessment, or will otherwise provide their consent to them. Patients should raise any questions that they may have about the consent they have given to a Practitioner directly with the Practitioner. Subscribers, Practitioners and Users (as applicable) may be able to transfer data, including Personal Information, into or out of the Platform. By accessing the Platform, or otherwise accepting or agreeing to the terms of this Privacy Policy, the Subscriber, Practitioner and User (as applicable) represents and warrants that they have obtained all necessary Patient authorization and consent for such data transfers and that such data transfers comply with all applicable laws.

There are some instances in which individuals provide Personal Information directly to Life Support. All users of the Platform must sign up for an individual Life Support account (“Account”). If you create a Life Support Account, enter into an Order Form, enter into a Statement of Work or Change Order, or use the Site, Platform or Services, you acknowledge the notices in this Privacy Policy and you consent to Life Support’s collection, use, disclosure, and retention of your Personal Information in accordance with this Privacy Policy and as otherwise permitted by law. You may ask to withdraw your consent at any time by giving Life Support reasonable notice, but consent may not be withdrawn in some cases, such as where doing so would frustrate performance of a legal obligation.

In some cases, Life Support may seek your consent for the use and disclosure of your Personal Information after it has been collected, but before it has been used or disclosed (e.g. where we want to use your Personal Information for a purpose not previously identified to you). We will not use or disclose your Personal Information for any new purpose without first identifying the new purpose and providing notice to you or obtaining your consent (as applicable), unless otherwise permitted by law. You can always choose not to provide Life Support with certain requested Personal Information, but then you may not be able to access or utilize all or part of the Site, the Platform and/or the Services.

Collection and Use of Personal Information by Users

In the course of using the Platform and Services for the purpose of assessing and treating a Patient, and other purposes consistent with that purpose (the “Permitted Purpose”), Practitioners may collect, use and/or disclose Personal Information about themselves, other Users (such as their administrative staff) and Patients. This may include information or records regarding a Patient’s medical or mental health history or status and other health related information. A Patient’s Personal Information may be contained in medical records, treatment and examination notes, assessment reports, and other health related records maintained by a Practitioner. At all times, the personal health information collected, used, transmitted and stored in the Platform remains in the custody and control of the Subscriber or Practitioner using the Platform. This Privacy Policy is not about the collection, use, and/or disclosure of Personal Information by such individuals. If you would like to know more about how your Practitioner and their administrative support staff handles your Personal Information as a Patient, you should ask them about their policies and practices.

Personal Information We Collect and Use

Personal Information Life Support Collects from Subscribers:

Life Support collects certain Personal Information from Subscribers in the course of managing our business relationship.

When registering a Subscriber on the Platform, we collect the Subscriber’s Account credentials, including full name, email address and password and certain other business contact information for communication and registration purposes.

In addition, Life Support collects payment information from Subscribers, which may include pre-authorized debit or credit card information to effect the payment of any applicable fees pertaining to the Subscriber and its associated Practitioner(s) and Users with respect to accessing the Platform and the Services.

Personal Information Life Support Collects from health care providers (Practitioners):

Life Support collects certain Personal Information from Practitioners in the course of managing our business relationship.

When registering a Practitioner on the Platform, we collect the Practitioner’s Account credentials including full name, email address, and password. In addition, to assist in identification, billing and Referral Services, we also collect the following professional information from Practitioners:

    • Phone number;
    • Gender;
    • Service delivery/interaction preferences (such as in-person, telephone or video conference);
    • Professional occupation/title;
    • Professional designations;
    • Optional Practitioner provided biography (for Patient use in Practitioner selection process);
    • Preferred service delivery languages/proficiency;
    • Professional registration and association membership information (including registration number);
    • Specializations; and
    • In the case of a Practitioner providing psychotherapy services, we solicit information regarding:
      • therapeutic approach;
      • therapeutic modality;
      • Patient age groups serviced;
      • areas of experience and specialty; and
      • details regarding standard billing practices.

    We also collect Personal Information about Practitioner’s staff who will have access to the Platform, including the User’s Account credentials (which includes the User’s full name, email address and password as well as certain business contact information including their phone number and business address for communication and registration purposes).

    In circumstances where a Practitioner invites a Patient to complete the Mental Health Check Assessment, the Practitioner provides Life Support with the following information: Patient first and last name and e-mail address. This enables Life Support to e-mail the Patient with information on how to register for an Account and how to access the Platform to complete the assessment.

    Personal Information Patients Provide to Life Support

    Life Support collects information that Patients provide directly to Life Support, such as

    • Patient Account, Clinical Service and Health information: When a Patient registers for an Account to complete a Life Support Mental Health Check Assessment on the Platform, and when Patients create or modify their Account, we collect information such as the Patient’s Account credentials (which includes the Patient’s full name, email address and password). This information is used to administer the Patient’s use of the Site, Platform and/or Services. In addition, we also collect Patients’ personal health number (for Practitioner billing purposes), credit card payment information and health insurance information (for purposes of processing payment of the fee for the Mental Health Check Assessment) as well as address information and phone number (for emergency contact purposes), gender, date of birth (to qualify assessment results), and name of family doctor (to facilitate exchange of information between the Practitioner and the Patient’s family doctor if requested by Patient).

    When a Patient completes the Mental Health Check Assessment, we collect the Personal Information provided by the Patient in responding to the questionnaire for the purpose of conducting the assessment, preparing the assessment report, and providing the results of a Patient’s assessment to the applicable Practitioner. We also collect information about a Patient’s treatment preferences (e.g. preferred gender of Practitioner, mode of communication) to assist in referral, if required. If a Patient submits a referral request to a Referee, the Patient will be asked to provide their consent to the Referee accessing the Patient’s Mental Health Check Assessment report. The Patient can choose not to provide their consent, however, this may lead to a non-acceptance of the referral request by Referee. Referees have the sole discretion to decide whether or not to accept a referral request from a Patient who has elected not to share their Mental Health Check Assessment report with the Referee.

    • Payment information: we do not store financial information collected through the Sites or directly from users on the Platform. Life Support uses a third-party payment processor, currently Stripe Payments Canada, Ltd. (“Stripe”) to handle payments your credit or debit card information when you add it to your y can be found here: https://stripe.com/en-ca/privacy.

    Additional Personal Information You Provide to Life Support

    Life Support may also collect the following information from Patients, as well as users of the Site and the Services:

    • Contact information: we collect your Personal Information when you contact Life Support directly to inquire about the Site, the Platform, and/or the Services. For example, when you complete any of the contact or inquiry forms on our Site, we will collect your name, phone number, e-mail address, and any other information that you choose to provide to us. When you report a problem, or submit questions, concerns or comments regarding the Site, Platform and/or Services, we may also collect your name, e-mail address, phone number, and other information that you choose to provide to us. We use your contact information to contact and correspond with you directly about our relationship, and your use of the Site, Platform and/or Services. We may use your contact information to provide you with the information, quote, or services that you have requested and to respond to customer service requests. Where we have your consent to do so, we may send you information about Life Support’s services, including general updates and announcements, promotions, and events (see below for information on how to “opt-out” of receiving certain communications from us)
    • Feedback: we collect the information that you include in any feedback you provide to Life Support through the Site, Platform, or when you contact our customer service. We use feedback information to improve the Site, Platform and/or Services, including to administer and resolve technical issues on the Site or Platform. We may also use this information to investigate and address your concerns. In addition, we may use this information to suspend or deactivate the user accounts, and to assist in training our employees and service providers.
    • Other information: we collect any other Personal Information that you submit directly to Life Support on a voluntary basis.

    Information Automatically Collected When Using the Site or the Platform

    Life Support uses various technologies which automatically collect certain information. These technologies include cookies and third-party analytics tools. The information we collect includes device, technical and usage information.

    • Device, technical and usage information: we collect your IP address, web browser type, Java status, Flash version and operating system when accessing our Site and the Platform. We also collect information about the sections of the Site and Platform that you visit, the date and time of your use of the Site and Platform, the amount of time you spend on the Site or Platform, specific actions you request or perform on the Site or Platform, the URL you used to access the Site or Platform, information about the type of device you are using and device carrier, crashes and other system activity on the Site and Platform, and certain content that you download from the Site and/or Platform. We use device information to understand traffic and activity on the Site and Platform, to audit use of the Platform for licensing purposes, to enable us to improve the Site, the Platform and/or the Services, to understand what drives traffic to our Site, to understand interest in our Services, and to tailor our marketing.
    • Virtual services information: If a Subscriber subscribes for Virtual Services, then the Practitioner(s) associated with that Subscriber will be able to access Virtual Services from the Platform to have video consultations with Patients. Practitioners can also use these optional services to send Patients instant messages, securely share files and for scheduling purposes. Life Support uses the Virtual Services Provider to provide the Virtual Services on the Virtual Services Provider’s own proprietary platform. The Virtual Services Provider may collect Personal Information when a Practitioner and Patient use the Virtual Services including: the name, contact information and specialization of the Practitioner and the name and email of the Patient. In addition, the Virtual Services Provider will collect the date and time of the appointment, any information added to the “notes for patient” by Practitioner, and any files attached or uploaded to the platform by the Practitioner or the Patient. All Personal Information that you provide while using Virtual Services is subject to the policies and procedures of the Virtual Services Provider with respect to the handling of Personal Information. OnCall’s Privacy Policy is available here: https://bit.ly/2C4f6BK.
    • Site Analytics: We use Google Analytics to track and analyse usage information about our Site and the Platform. Google Analytics uses cookies to track certain usage information on the Site and the Platform, to create reports about users activities for Life Support, and to provide other services associated with the use of the Site and the Platform. Such information may include aggregated information about the devices, geolocation, networks, page visits, duration of visits and click through information of visitors to our Site and the Platform. We use this information to understand traffic and activity on the Site and Platform, to audit use of the Platform for licensing purposes, to enable us to improve the Site, the Platform and/or the Services, to understand what drives traffic to our Site, to understand interest in our Services, and to tailor or optimize the user experience on the Site and the Platform. This data is used for aggregate reporting purposes. To learn more about Google’s privacy practices, including how you can view and edit your preferences, please see the Google Privacy Policy.
    • Cookies: Life Support collects Personal Information when you access the Site and/or the Platform via cookies. A cookie is a tiny element of data that our Site and Platform send to your browser, which may then be stored on your hard drive so that we can recognize you when you return. We use this information to remember your preferences, to authenticate you, and to track the activity of users on the Site and the Platform. Cookies may remain on your device after you leave the Site and/or the Platform (until the cookie expires or is deleted by you). You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, disabling cookies may affect your ability to take advantage of all of the Site, Platform or Services’ features or functionality.

    Business and Legal Uses of Personal Information by Life Support

    In addition to the purposes listed above, in general, Life Support may also use the Personal Information we collect about you to:

    • ensure compliance with and identify violations of the applicable Terms of Use;
    • enforce our rights arising from any contracts between you and us;
    • enforce billing and collections;
    • identify and prevent fraudulent activity and to protect security of the Site and the Platform;
    • meet legal and regulatory requirements; and
    • facilitate such other services and activities, as we may identify to you at the time.

    Life Support will only use your Personal Information for the purpose for which it was originally collected, or for a use consistent with that purpose, unless you expressly consent or it is permitted or required by law.

    How we protect the information we collect

    We understand that data security is a critical issue for you and we are committed to safeguarding the Personal Information in our custody and under our control.

    Life Support’s technological security requirements are powered by a third-party service provider, MedStack Inc. (“MedStack”), a leading privacy compliance hosting platform built specifically for the needs of the digital health industry. All aspects of the Platform are hosted and retained on MedStack’s cloud hosting and server management platform, Control Platform-as-a-Service. MedStack uses Amazon Web Services and Microsoft Azure Cloud Computing Services as the hosting infrastructure for its Control Platform- as-a-Service.

    We have selected MedStack because we believe it does not access, process or share personal health information beyond what is minimally required to enable Life Support to deploy the Platform in a secure environment, it maintains a comprehensive privacy management program, it provides secure, flexible, single-tenant cloud infrastructure tailored to Life Support’s unique requirements, including encryption, network security, monitoring, audit logging, backups, and certificate and key management. We have reviewed MedStack’s Privacy Impact Assessment (PIA) and Threat Risk Assessment (TRA) for Canada. MedStack’s Privacy Officer can be contacted at privacy@medstack.co.

    As described above, LifeSupport uses a third-party Virtual Services Provider. The Virtual Services Provider’s secure video and/or text consultation is encrypted and it destroys or anonymizes all Personal Information when it is no longer necessary to deliver the service.

    In addition to the security features which are built into the MedStack’s Control Platform-as-a-Service, Life Support has also implemented a comprehensive privacy and information security program for its business, employees and consultants that includes written policies, procedures and security controls. We have implemented reasonable administrative and technical safeguards in an effort to protect against unauthorized access, collection, use, modification, disclosure, and disposal of Personal Information in our custody and control, in a manner appropriate to the sensitivity of the information. For example, employees are trained regarding policies and procedures for safeguarding Personal Information and audit and access logs are maintained and monitored.

    The safety and security of your Personal Information also depends on you. Life Support is not responsible for any lost, stolen, or compromised Account credentials or for any activity on your Account via unauthorized password activity. You should take steps to protect against unauthorized access to your Account by, for example, choosing a robust password and keeping your Account credentials private. Life Support is not responsible for any failure by you to secure your own devices and their access to the Internet or your use of public, unsecured networks.

    The Site and the Platform may include links to external websites or platforms that Life Support does not own or operate. Also, links to our Platform may be featured on third-party websites or platforms on which we advertise or with which we partner. Except as provided in this Privacy Policy, we will not provide Personal Information to these third-parties without consent. We provide links to third-party websites or platforms as a convenience to you. These links are not intended as an endorsement of or referral to the linked websites or platforms. Once you leave the Site or the Platform, this Privacy Policy does not apply. Life Support is not responsible for the privacy practices, collection of Personal Information, or content of external websites.

    Unfortunately, information systems, the transmission of information via the Internet and mobile platforms are not completely secure. Although we have designed features and employed security techniques to protect your Personal Information, we cannot guarantee the security of Personal Information at all times. Any transmission of your Personal Information is at your own risk.

    Disclosure of Personal Information

    We may share your Personal Information as follows, in accordance with applicable laws.

    Virtual Services Provider

    As described above, when using the Platform, Practitioners can choose to subscribe to an optional virtual services platform powered by the Virtual Services Provider. If a Practitioner is using the Virtual Service Provider’s services when using the Platform, the Virtual Services Provider may receive Personal Information about the Practitioner and the Patient.

    Health Insurance Companies

    Life Support will share a Patient’s health insurance information with the applicable insurance company in order to process payment for the Mental Health Check Assessment. Life Support will also share a Patient’s personal health number with the Practitioner in order for the Practitioner to process payment for the Mental Health Check Assessment review or intake appointments.

    Circle of Care

    If you access or use the Platform to administer or receive Services, your Personal Information may be disclosed to and among Practitioners for the Permitted Purpose and as necessary to assist in the provision of Services to you that are consistent with the Permitted Purpose. For example, upon completion of the Mental Health Check Assessment, your Practitioner will be able to access the assessment report. The Platform also allows for Practitioners within an organization or clinic to facilitate the exchange of Personal Information with other Practitioners and health care providers within that same organization or clinic. For example, your Personal Information may be provided to third-parties such as other health professionals, specialists, consultants or pharmacists for the purpose of providing or assisting in the provision of Services to you. As a further example, if a referral to a Referee is recommended in the assessment report, the Practitioner can provide the Patient with access to a list of mental health practitioners. Once the Patient selects a Referee and submits the request for referral, the selected Referee is notified through the Platform that the Patient is requesting an appointment. The Patient will receive the Referee’s contact information. When the Patient submits their referral request, the Patient will be asked to provide their consent to the Referee having access to the Patient’s assessment report. Referrals by Practitioners can also be done outside of the Platform in accordance with the Practitioner’s usual referral practice.

    Third-Party Service Providers

    Life Support may share certain Personal Information with third-party service providers with whom we have contracted to provide certain services on behalf of Life Support:

    • As described above in this Privacy Policy, we use MedStack to host and retain the Platform and we use OnCall to provide Virtual Services through the Platform. OnCall’s privacy policy can be found here: https://bit.ly/2C4f6BK.
    • As described above in this Privacy Policy, MedStack provides us with cloud hosting and server management for the Platform. MedStack’s privacy policy can be found here: https://lifesupport247.com/medstack-information-privacy/.
    • As described above in this Privacy Policy, we use Stripe to facilitate payment transactions for the Mental Health Check Assessment and other amounts owed by users of the Platform to Life Support. Stripe’s privacy policy can be found here: https://stripe.com/en-gb-ca/privacy.
    • We use SiteGround Hosting Ltd. (“SiteGround”) to host the Site. SiteGround’s privacy policy can be found here: https://www.siteground.com/privacy.htm.
    • We use Red Hat Keycloak (“Red Hat”) enable single sign-on authentication services for our enterprise clients. Red Hat’s privacy policy can be found here: https://www.redhat.com/en/about/privacy-policy.
    • We use Google Analytics (“Google”) to perform analytics on website usage and activity. Google’s privacy policy can be found here: https://policies.google.com/privacy?hl=en-CA.
    • We use Microsoft (“Microsoft”) Dynamics 365 to manage and store Personal Information collected in relation to Customer Support requests and inquiries and Microsoft 365 to facilitate our electronic communications. Microsoft’s privacy statement and related policies can be found here: https://privacy.microsoft.com/en-CA/.

    Life Support’s third-party service providers will have access to the Personal Information necessary to perform their functions, but are only provided the limited amount of information required to perform their services. When Life Support uses third-party service providers, it requires the providers to protect your Personal Information in accordance with the law and with appropriate safeguards for the protection of the Personal Information. Any such sharing of your Personal Information by Life Support to a service provider will be conditional upon the information being used solely for the purpose for which it has been shared.