Privacy Policy	Coast to Coast Coverage

ACTIVE™ Health Management Inc. (“ACTIVE”, “we”, “our”  or “us”), provides health referral services, development and training in treatment and assessment protocols, billing services, clinical & administrative consulting, data storage and data mining services, and assessment and treatment services, (“ACTIVE Services”) to a network of health practitioners, including, without limitation, physiotherapists, doctors, occupational therapists, massage therapists (collectively, “Service Providers”) as well as to such other third parties (“Third Party Payers”) which subscribe to ACTIVE Services in Canada.  As part of the provision of ACTIVE Services, ACTIVE collects and stores personal information relating to the Patients or Claimants of the Service Providers or Third Party Payers.

I.                   PERSONAL INFORMATION

In this Privacy Policy, “Personal Information” means information that specifically identifies a Patient and is provided to, or collected by, ACTIVE in connection with providing ACTIVE Services.  The type of Personal Information ACTIVE collects, uses and discloses may include, without limitation, a Patient’s name, age, mailing address, residential phone numbers or email address, employer, health benefit information, Personal Health Information (as defined below).

In this Privacy Policy, “Personal Health Information” includes all information concerning a Patient’s physical or mental health which is collected or generated by ACTIVE in the course of it providing ACTIVE Services.

Other information ACTIVE deems necessary to fulfill its stated purposes, such as occupational, psycho-social or other demographic information potentially affecting a patient’s ability to recover from injury, may also be collected by ACTIVE.

II.                 ACCOUNTABILITY

ACTIVE is responsible for the Personal Information under its control.  All managers and individuals involved in maintaining or collecting Personal Information are trained via the Privacy Policy.  ACTIVE has appointed a Privacy Officer (the “Privacy Officer”) to ensure that we comply with all applicable privacy legislation affecting our use of your Personal Information, as well as the terms of this Privacy Policy. The Chief Privacy Officer addresses and investigates questions or concerns regarding a Patient’s Personal Information.  To reach the Chief Privacy Officer, please contact the Chief Privacy Officer at info@activehealth.ca or

ACTIVE Privacy Officer
ACTIVE Health Management Inc
1867 Yonge St., Suite 901
Toronto, ON M4S 1H8

Tel: 1-800-315-4417 or 416-481-0834
Fax: 1-800-747-5208 or 416-481-2168

III.              IDENTIFYING PURPOSE OF USE OF PERSONAL INFORMATION

ACTIVE collects, uses, and discloses your personal information for the following purposes (the “Identified Purposes”):

a)    To Invoice Third Party Payers for services provided to the Patient

The Personal Information on a Patient’s invoice may include, but is not limited to: the Patient name, address, date of birth, claim / policy / employee numbers, clinical diagnosis, type of service provided to the Patient, the date, duration and cost of that service.  Refusal to consent to providing this information will result in the inability of ACTIVE to invoice the third party payer on the Patient’s behalf.

b)    To provide Third Party Payers with progress reports/assessment findings resulting from services provided to the Patient

Reports written for Third-Party Payers, Physicians and / or Legal Counsel may be released to ACTIVE from time to time to ensure quality of care and best practices, to ensure that the service provider is following proper protocol, to provide data for research, to provide clinical consulting services to the service provider, or to store information securely on ACTIVE’s systems.  In some cases, the service provider will forward the report directly to the Third Party and to ACTIVE, and in other cases the Service Provider will forward the report to ACTIVE, who will then provide it to the Third Party.

c)     To analyze for research purposes

Anonymized Personal Information collected about services provided to the Patient may be used to determine measures such as the effectiveness of the services provided by the service providers, to determine the length of time required to recover from injury, to develop new treatment protocols, or to prove the effectiveness of existing treatment protocols and approaches.

d)     To market services provided by ACTIVE and ACTIVE Service Providers

ACTIVE uses its collected Personal Information to demonstrate the quality and value of the services provided by its service providers.  Personal Information released to Third Parties for this purpose is either in aggregate form, meaning no personally identifiable information is released, or is information that the Third Party already possesses.

e)    To determine best clinical practices, and ensure quality of service by Service Providers

Personal Information collected may be used to ensure the effectiveness of the Service Providers, and to ensure service providers are following proper protocols.

f)      To store information on behalf of Service Providers or Third Party Payers

Completion of various forms or reporting templates may be done electronically on ACTIVE’s systems by service providers for the purposes of storing this information in a secure and readily retrievable, editable and presentable format.

g)    To provide Assessment and Treatment Services

ACTIVE provides Assessment and Treatment services from time to time directly to patients.  ACTIVE collects and stores Personal Information, as needed, to complete these services.  Information concerning assessments and treatments may be released to Third Parties responsible for overseeing or paying for the services, or to physicians involved in the patients’ cases.  ACTIVE stores this information in patient files, in formats, and for periods of time, as required to comply with Professional Regulatory Bodies such as the College of Physiotherapists.  ACTIVE may be required by law from time to time, to allow these regulatory bodies to audit these patient files, to ensure the Service Provider’s compliance with regulations, best practices and ethical guidelines.

ACTIVE may use, share among us and disclose a Patient’s Personal Information to its subsidiaries, affiliates, associates, agents, suppliers, and such other Third Parties as ACTIVE, acting reasonably, may deem necessary for the fulfillment of the purposes noted above or where otherwise permitted by law.  In the event that substantially all of ACTIVE’s assets are acquired by a Third Party, a Patient’s Personal Information may be one of the transferred assets.

IV.                PATIENT’S CONSENT

ACTIVE does not collect, use or disclose a Patient’s Personal Information without their knowledge and consent, except in certain extraordinary circumstances. Such extraordinary circumstances include, without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent.

A Patient’s consent will be obtained at the time of collection of the Personal Information, or when a new use for the Personal Information is identified.  A Patient may withdraw consent at any time, subject to any legal or contractual restrictions and reasonable notice. If a Patient chooses to withdraw his or her consent, he or she is required to do so in writing to the ACTIVE Privacy Officer.  Any implications to withdrawing the said consent will be explained to the Patient, which may include the inability of ACTIVE to provide its services to the Patient, the Service Providers, or the Third Party Payers, as applicable.

V.                 LIMITING COLLECTION

ACTIVE limits the collection of a Patient’s Personal Information to that which is necessary for the purposes identified above in this Privacy Policy, or for any additional purpose identified to the Patient before collection of the Personal Information.

VI.               LIMITING USE, DISCLOSURE AND RETENTION

Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Patient, or as permitted by law. Personal Information is only retained as long as necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, after which it is destroyed, erased, or rendered anonymous.

VII.            ACCURACY

ACTIVE strives to ensure that the Patient’s Personal Information is as accurate, complete, and up to date as possible.  Personal Information is updated only when necessary to fulfill specified purposes.

VIII.          SAFEGUARDS

ACTIVE has security safeguards in place designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Patient’s Personal Information in the care of ACTIVE. The nature of the safeguards depends on the sensitivity, format, location and storage of the information, and such measures include locked cabinets, computer passwords and encryption software.

IX.               OPENNESS

All inquiries for Personal Information regarding a Patient are to be directed to the ACTIVE Privacy Officer.

X.                 INDIVIDUAL ACCESS

ACTIVE will provide a Patient access to his or her Personal Information. ACTIVE will correct or amend any inaccuracies in the Patient’s Personal Information, and such amended information will be forwarded to any Third Parties who require access to the information.  ACTIVE has the right to refuse a request for access to Personal Information if:

·         The information is protected by legal privilege;

·         Granting access would reveal confidential commercial information;

·         Doing so would reasonably be expected to threaten the life or security of another individual;

·         The information was collected for purposes related to the detection and prevention of fraud;

·         The information was generated in the course of a formal dispute resolution process; or

·         The information would likely reveal Personal Information about another individual (unless such Personal Information can be removed, whereas the remaining information will be provided).

If a Patient’s request for Personal Information is denied, the Patient will be informed in writing of the reasons for the request denial, in addition to any recourse available.

Any Patient may request of the ACTIVE Privacy Officer to review his or her Personal Information at a pre-determined date and time.  Access will be at no cost to the Patient, however minimal charges may apply for the transcription, reproduction or transmission of the Personal Information. 

XI.               CHALLENGING COMPLIANCE

Patients are encouraged to discuss any privacy issues with the ACTIVE Privacy Officer. Upon request, ACTIVE will inform a Patient on the procedures in place to receive and respond to complaints or inquiries about the Patient’s policies and practices relating to the handling of Personal Information.

XII.            CURRENCY OF THIS PRIVACY POLICY

ACTIVE reserves the right to change this Privacy Policy at any time.