Patient Prompt | Privacy Policy Appointment Reminders

Patient Prompt Privacy Policy.

Prompt Alert Incorporated (“Prompt Alert”) is committed to protecting the privacy of personal information in its care and will do so in accordance with this privacy policy (the “Privacy Policy”). This Privacy Policy explains Prompt Alert’s treatment of personally identifiable information collected in connection with activities on or related to all Prompt Alert’s websites referencing this Privacy Policy (the “Sites“) and all services made available by Prompt Alert, unless noted otherwise.

Prompt Alert may make amendments or modifications to this Privacy Policy from time to time concerning its privacy practices in order to properly implement new services and features, to comply with its obligations at law or to amend its privacy practices. Prompt Alert may otherwise amend its privacy practices from time to time without further notice.

Prompt Alert is a provider of appointment notification and reminder services for the health care industry. Prompt Alert providers its services in accordance with its obligations under applicable Canadian and United States Federal, State and Provincial legislation.

If you are a Prompt Alert customer with respect to appointment notification and reminder services, it will be necessary for you, on behalf of your patients and/or other end users, to provide to us, with all mandatory information required for Prompt Alert to provide appointment notification and reminders in accordance with applicable laws. We do not collect any information about our customers’ patients or other end users that is not required to fulfill our contractual obligations.

‘Personal information’ includes information about an identifiable individual, presented in any form, such as: age, name, ID number(s), diagnostic, health history, treatment and care information, medical records, but does not include the name, title, business address and telephone number of an employee of an organization or aggregated information that cannot be associated with a specific individual.

In handling personal information, we abide by the following ten privacy principles, which are (collectively the “Principles”):

Accountability
Identifying Purposes
Consent
Limiting Collection
Limiting Use, Disclosure and Retention
Accuracy
Safeguards
Openness
Individual Access
Challenging Compliance

Principle #1 – Accountability

1.1 Prompt Alert is responsible for personal information under its control and will designate an individual or individuals who are accountable for the organization’s compliance with these Principles. Accountability for Prompt Alert’s compliance with the Principles rests with the senior management of Prompt Alert and the person or persons designated by senior management as Privacy Officer, even though other individuals within the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within the organization may be delegated to act on behalf of senior management or the Privacy Officer.

1.2 Prompt Alert’s Privacy Officer may be contacted at:

Prompt Alert Incorporated
640-330 Bloor Street West
Toronto, Ontario
M8X 2X2
Attention: Prompt Alert c/o Privacy Officer
E-mail: priacyofficer@promptalert.com

1.3. Prompt Alert is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. Prompt Alert will use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

1.4 Prompt Alert will implement policies and practices to give effect to these Principles, including:

implementing procedures to protect personal information;
establishing procedures to receive and respond to complaints and inquiries;
training staff and communicating to staff information about Prompt Alert’s policies and practices; and
developing information to explain Prompt Alert’s policies and procedures.

Principle #2 – Identifying Purposes

2.1 Prompt Alert collects personal information only for the following purposes (collectively, the “identified purposes”):

to provide service(s) and/or products to its customers (in compliance with contractual obligations);
to maintain commercial relations and to communicate with its customers including, but not limited to, billing, collection, advertising, promotion and account verification;
to manage and develop its business and operations, including personnel and employment matters;
to identify customer needs and/or preferences;
to meet legal and regulatory requirements;
to administer and manage its business operations; and
as otherwise required or permitted by law.

2.2 Prompt Alert will provide notice of the identified purposes orally, electronically or in writing prior to or at the time of collection of the personal information.

2.3 If individual persons within Prompt Alert collect personal information, they will be able to specify the purposes for which the information is being collected, or will refer the individual whose information is being collected to a designated person at Prompt Alert who will specify the purposes.

2.4 When personal information that previously has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless the new purpose is required by law, and subject to the exceptions referred to in Principle #3, Prompt Alert will obtain the consent of the individual before information is used for that new purpose.

2.5 Occasionally, Prompt Alert will communicate to its end users to provide new product offers that we think may be of value to you. You have the right to choose not to participate in direct marketing of new products and services from Prompt Alert. If you wish to opt-out of receiving targeted communications from Prompt Alert in electronic, printed or verbal format (other than information included with your monthly bills), simply inform us in writing at:

Prompt Alert Incorporated
640-330 Bloor Street West
Toronto, Ontario
M8X 2X2
Attention: Prompt Alert c/o Privacy Officer
E-mail: priacyofficer@promptalert.com

2.6 The Sites have links to third party websites that Prompt Alert does not own or maintain. Links to other websites or other resources which are not created or controlled by Prompt Alert (“Linked Sites”) are intended for convenience only. Linked Sites are wholly independent from Prompt Alert, therefore Prompt Alert has no control over any products, services, materials, or other information contained in or available through these third party websites. Prompt Alert makes no representations or warranties about the privacy practices of those websites. Therefore, access to any third party websites through the Sites, regardless of whether the third party website is a Linked Sites or not, is entirely at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive devices, programs. Prompt Alert is not responsible for the collection, use, or disclosure of information collected through the Linked Sites, and Prompt Alert expressly disclaims any and all liability related to such collection, use, or disclosure.

Principle #3 – Consent

3.1 Prompt Alert, as a processor of information under contract with its customers, does not obtain consent directly from its customers’ patients or other end users with respect to personal information processing or for other similar activities where Prompt Alert is acting as third party agent. Where personal information received by Prompt Alert is provided by its customers directly, it is the obligation of the customers to have obtained appropriate consent, according to applicable privacy laws, from their patients or other end users before transferring, in printed, electronic, facsimile or any other format, personal information to Prompt Alert.

3.2 Except as otherwise set forth in this Privacy Policy, with respect to Prompt Alert’s services, where information is collected directly from individuals, Prompt Alert will only collect only the minimal amount of information required to provide the requested services. In such circumstances, Prompt Alert will assume that you have consented to the collection of your personal information where you have voluntarily entered the information on our Sites or otherwise provided your personal information to us, and such consent will be assumed only for the purposes that can reasonably be inferred from the context of the service being offered. The form of consent sought by Prompt Alert may vary, depending upon the circumstances and the type of information disclosed. Prompt Alert will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate when the information is less sensitive.

3.3 In certain circumstances, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; where used or disclosed in the case of an emergency that threatens the life, health or security of an individual; where personal information is publicly available as defined by regulation; where collection with knowledge or consent might compromise the availability or accuracy of the information and the collection relates to investigation of a breach of agreement or contravention of law; and where disclosed for debt collection purposes or to comply with a subpoena, warrant or court order.

3.4 Where required, Prompt Alert will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Prompt Alert wants to use information for a purpose not previously identified).

3.5 Prompt Alert will make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used. To make the consent meaningful, the purposes will be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.

3.6 Prompt Alert will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes.

3.7 A patient or an end user of any Prompt Alert customer withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by through his or her health care provider contact.

3.8 In the case of services to individuals, an individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Prompt Alert will inform the individual of the implications of such withdrawal. In order to withdraw consent, an individual must provide notice to Prompt Alert in writing.

3.9 With respect to personal information already collected by Prompt Alert prior to the publication of this Privacy Policy, this Privacy Policy will constitute reasonable notice to Prompt Alert’s current customers and, if applicable, their patients or end users, of the purposes and uses for which such personal information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to Prompt Alert in writing.

Principle #4 – Limiting Collection

4.1 Prompt Alert collects personal information from its customers for the purposes described under Principle #2.

4.2 Portions of the Sites and e-mails or communication sent by Prompt Alert use statistical tools that may be operated by third party providers (collectively, the “Analytical Tools”). The Analytical Tools may use “cookies” and/or web beacons. A cookie is a small piece of information that a website transfers to the hard drive of a visitor’s computer for record-keeping purposes. A web beacon, also known as a “clear GIF” (a common format for image files), is an invisible file located on web pages that an individual visits or in e-mails that an individual opens and views. If an individual visits a page on the Sites or opens an e-mail that contains a web beacon, it communicates with the individual’s computer and Prompt Alert’s servers to determine, among other things, whether the individual has visited that page before, or viewed a particular e-mail Prompt Alert’s cookies and web beacons do not collect personal information. Internet web browsers may be set to notify when a cookie is received or to prevent cookies from being sent. Limited functionality of some portions of the Sites may occur if cookies are prevented from being sent.

4.3 The information generated by the cookies and/or web beacons about use of the Sites (including a visitor’s IP address) may be transmitted to and stored on servers located outside of Canada including, but not limited to, the United States, by the applicable third party provider of an Analytical Tool. This information will be used for the purpose of evaluating use of the Sites, compiling reports on the activities of a Site and providing other services relating to a Site’s activity and Internet usage. The third party providers of Analytical Tools may also transfer this information to other third parties where they are required to do so by law, or where such third parties process the information on their behalf. Use of any the Sites, constitutes consent to the processing of data by third party providers of Analytical Tools in the manner and for the purposes set out above.

Principle #5 – Limiting Use, Disclosure, and Retention

5.1 Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as otherwise required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes or as otherwise required or permitted by law.

5.2 Prompt Alert may collect, use or disclose personal information without the individual’s knowledge or consent in certain circumstances as described in Principle #3.3.

5.3 Prompt Alert may disclose personal information that Prompt Alert is responsible for to:

another company for the provision of its services;
a person involved in the development, promotion, marketing or enhancement of Prompt Alert services; and
any other third party, upon receiving the consent of the customer or as required by law.

Such disclosures may in some cases be to recipients outside of Canada.

5.4 Personal information may also be disclosed in connection with a sale, transfer or reorganization of one or more of Prompt Alert’s businesses, in which case Prompt Alert will require that any personal information will continue to be treated in accordance with this Privacy Policy or as otherwise permitted by law.

5.5 Prompt Alert will retain personal information that has been used to make a decision about an individual long enough to allow the individual access to the information after the decision has been made, and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law.

Principle #6 – Accuracy

6.1 Personal information will be updated as necessary for the purposes for which it is to be collected and used. The extent to which personal information will be updated will depend upon the use of the information, taking into account the interests of the individual. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.

6.2 Prompt Alert will not routinely update personal information unless such a process is necessary to fulfill the purposes for which the information was collected.

6.3 Personal information that is used on an ongoing basis, including information that is disclosed to third parties, will generally be accurate and up-to-date to the best of Prompt Alert’s knowledge, unless limits to the requirement for accuracy are clearly set out.

6.4 An individual patient or end user of any Prompt Alert customer can have any personally identifiable information that we have stored about that individual corrected through his or her health care provider contact. Prompt Alert will change information as soon as reasonably practical following receipt of such a request by the designated health car provider contact.

6.5 In the case of services to individuals, those individuals will have the ability to offer corrected information for Prompt Alert in order for Prompt Alert to update its records. Prompt Alert will correct inaccurate or incomplete information, subject to verification of the requested amendment, as soon as reasonably practical following receipt of such a request.

Principle #7 – Safeguards

7.1 Prompt Alert will use reasonable efforts to protect personal information by security safeguards appropriate to the sensitivity of the information. Prompt Alert has invested and deployed a wide variety of technology and security features to ensure the privacy of personal and anonymous information on its network. In addition, Prompt Alert has implemented strict operations guidelines to safeguard information privacy at every level of its organization. Prompt Alert will continue to revise policies and implement additional security features as new technologies become available. Unfortunately, no system is perfect; therefore, Prompt Alert makes no representations or warranties with regard to the sufficiency of these security measures. Prompt Alert shall not be responsible for any actual or consequential damages (or any other damages or liability of any kind whatsoever, whether as a result of negligence or otherwise) that result from a lapse in compliance with this Privacy Policy because of a security breach or technical malfunction.

7.2 Prompt Alert protects all personal information regardless of the format in which it is held. The methods of protection include:

physical measures, such as locked filing cabinets and restricted access to offices;
organizational measures, such as security clearances and limiting access on a ‘need to know’ basis;
technological measures, such as the use of passwords and encryption.

7.3 Prompt Alert makes its employees aware of the importance of maintaining the confidentiality of personal information. Prompt Alert employees are governed by non-disclosure obligations prohibiting disclosure or use of any confidential or personal information for any purposes other than in accordance with this Privacy Policy.

Principle #8 – Openness

8.1 Prompt Alert will, upon written request, make readily available to individuals specific information about its policies and practices relating to the management of personal information, other than confidential commercial information.

8.2 Prompt Alert will make its policies and practices with respect to the management of personal information comprehensible and accessible, by providing upon request:

the name, title, and address of the Privacy Officer accountable for Prompt Alert’s policies and practices and to whom complaints or inquiries can be forwarded;
the means by which an individual can gain access to his or her personal information held by Prompt Alert; and
a description of the type of information held by Prompt Alert and/or its subsidiaries, including a general account of its use.

8.3 Prompt Alert will make this Privacy Policy available online at the Sites.

Principle #9 – Individual Access

9.1 Upon written request, Prompt Alert will inform an individual whether or not the organization holds personal information about that individual, and will provide that individual with a reasonable opportunity to review the personal information in his or her file.

9.2 Prompt Alert will allow the individual access to his or her personal information once the individual has provided Prompt Alert with a written request application. The application will include sufficient information to permit Prompt Alert to provide an account of the existence, use, and disclosure to any third parties of this personal information. Prompt Alert will use the application only for this purpose.

9.3 Prompt Alert will respond to an individual’s written request within 30 days, unless this period is extended in accordance with applicable legislation, in which case notice will be sent to the individual within 30 days regarding the extension, the reasons for it and the individual’s rights in connection with it. Prompt Alert will assist any individual who informs it that they need assistance in preparing a request. While the response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, Prompt Alert reserves the right to impose a cost. In these circumstances, Prompt Alert will inform the individual of the approximate cost to provide the response and proceed upon payment. The requested information will be provided or made available in a form that is generally understandable.

9.4 Prompt Alert will be as specific as possible in providing an account of third parties to which it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, Prompt Alert will provide a list of organizations to which it may have disclosed information about the individual.

9.5 In certain instances, Prompt Alert will not be able to provide the individual access to his or her personal information. Where permitted, the reasons for denying access will be provided to the individual. This will be done upon the individual’s request, unless Prompt Alert is required by law to provide such written reasons. Exceptions to the grant of an access request may include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information protected by solicitor-client privilege; information properly collected without the knowledge or consent of the individual for purposes related to investigating a breach of an agreement or a contravention of law; information generated in the course of a formal dispute resolution process; and as required or permitted by law.

9.6 When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Prompt Alert will amend the information as required. Depending upon the nature of the information challenged, amendment may involve the correction, deletion or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.

9.7 When a challenge is not resolved to the satisfaction of the individual, Prompt Alert will record the substance of the unresolved challenge. When appropriate in Prompt Alert’s judgment, the unresolved challenge will be transmitted to third parties having access to the information in question.

Principle #10 – Challenging Compliance

10. 1 An individual will be able to address a challenge concerning compliance with the above Principles to Prompt Alert’s Privacy Officer.

10.2 Prompt Alert will maintain procedures to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. Prompt Alert will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures.

10.3 The person or persons accountable for compliance with this Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4 Prompt Alert will investigate all complaints. If a complaint is found to be justified, Prompt Alert will take appropriate measures, including, if necessary, amending its policies and practices.

Last updated on January 15, 2012.