myCareBase PRIVACY NOTICE
Last updated September 17, 2018
myCareBase Solutions Inc. (“myCareBase”) provides Care Agencies with online care journals that keep everyone connected. We recognize the importance of privacy and the sensitivity of personal information, in particular personal health information. As a private sector Canadian company, we are subject to the federal Personal Information Protection and Electronic Documents Act and all substantially similar provincial legislation (the “Privacy Laws”). This Privacy Notice outlines how we manage and safeguard the personal information that you submit to us through any means, including through the myCareBase mobile application (“App”) and our website (“Website”) (collectively, the “Services”).
What is personal Information?
Personal information is any information that can be used to uniquely identify a specific individual. Personal health information is considered sensitive information and includes, but is not limited to, general health information (blood pressure, weight, heart rate, mood), disease/medical conditions, medications, allergies, treatments, physical and mental fitness, and health related images.
What types of personal information does myCareBase collect and for what purposes?
We collect information, including personal health information, directly from individuals and from third parties, with consent from individuals, in order to deliver the Services.
1. myCareBase collects information to create accounts for different types of users:
- myCareBase uses information provided by Care Agencies to create accounts for Administrators and Care Managers: full name and work email address.
- Care Managers use information provided by clients to create their accounts: full name, name, photograph, address, phone number, email address.
- Care Managers use employment information to create accounts for Caregivers: full name, photograph, phone number, email address, skills and availability.
- Care Managers use email information provided by clients to send invitations to family members and friends to join a client’s account.
2. Information collected by Care Managers from clients at account setup and by Caregivers during the course of caring for a client is used for planning and care giving purposes, employment tracking, quality assurance, and billing purposes: birthdate, 1 type of home, pets, personal information including general health data, medical information, mental and physical fitness, photos, and other information related to client care.
3. Emergency contact information provided to Care Managers by clients when an account is created is used by Care Agency staff in the event of an emergency: full name, phone number(s), and email address.
4. myCareBase also collects personal information provided by users when they communicate with each other on our platform.
We may also use the information collected to fulfill the following purposes:
- Provide technical support or respond to inquiries. Most technical issues can be resolved without our support team viewing personal information .
- Comply with any laws, regulations, court orders, subpoenas, or other legal process or investigation and to protect ourselves and other individuals as permitted by law.
- Contact users to see about interest in participating in surveys or research initiatives that will help us enhance our services. myCareBase does not knowingly or intentionally collect personal information from individuals who are under the age of 18.
Who can access personal information?
Authorized Care Agency staff will have access to Care Manager and Caregiver account information, including personal information used to create the account.
Authorized Care Agency staff, including Care Managers and Caregivers, and family and friends invited to the client account will have access to client and emergency contact information.
Authorized myCareBase staff will have limited access to personal information only if required to perform their role in delivering the Services.
Does myCareBase collect anonymous information about users?
We may collect anonymous data that does not identify an individual to:
- Monitor system usage, server and software performance, to improve system design, to create benchmarks and to conduct trending analyses.
- Perform statistical analyses and generate data related to the use and improvement of our Services.
We may share this de-identified data with our partners, for example service providers, but the information will not identify individuals specifically.
Does myCareBase get consent to use personal information?
Users consent to information being collected, used, disclosed and stored by us, only as described in this Privacy Notice, when providing information during the course of using the Services. Where users are providing personal information of a third party, for example a Care Manager creating a client account, the user is responsible for obtaining consent from third party to provide the personal information to myCareBase.
myCareBase may collect, use or disclose personal information without knowledge or consent in certain circumstances, including but not limited to:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual's life, health, or personal security;
- When the personal information is available from a public source;
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
How do I update or delete personal information?
As agents of the Care Agencies, Care Managers can update and delete Caregiver and client accounts. While the account belongs to the Care Agency, the personal information belongs to the individual it is about, therefore, deleting an account permanently deletes the personal information from myCareBase’s active database. Once an account is deleted, non-identifiable information may be retained for business purposes but the individual to whom the account belonged can no longer be identified.
Users can opt-out of most email communication from myCareBase by clicking on the unsubscribe link at the bottom of our emails. We may still contact users for administrative purposes, for example to notify of a change to the Services, a change to the Privacy Notice, or if there is a service interruption.
What personal information is disclosed to third parties?
We will only use or disclose personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes.
We do not disclose any additional personal information to any third party to enable them to market their products and services.
We may transfer personal information in connection with a merger or sale involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.
How long is personal information kept?
We keep personal information only as long as is reasonably necessary to fulfill the identified purposes, or as may be required by law, whichever is longer.
How is personal information kept up-to-date?
Care Managers and Caregivers are responsible for ensuring that the personal information provided while using the Service is accurate, complete, and up-to-date. For questions or requests regarding changes, deletion or corrections to Care Manager, Caregiver, family contact or client personal information, please contact the Care Agency directly.
How is personal information secured?
myCareBase takes all reasonable precautions to ensure that personal information is kept safe from loss, unauthorized access, modification, or disclosure. The steps taken to protect information include but are not limited to:
- Premises security
- Restricted file and account access
- Technological safeguards such as server security and firewalls
- Internal password and security controls
- Team training on privacy and security
We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security, however please bear in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that shared with us.
Where are the Services located?
myCareBase is located in Canada and we use service providers located in Canada. How does an individual get access to personal information? Individuals can review, edit or remove their personal information at any time subject to limited exceptions. Upon written request, myCareBase will also provide a list of entities (e.g. third party service providers) to which we have disclosed personal information, if applicable.
It’s important to guard your privacy when you are online. If our Services contain links to other websites, this Privacy Notice does not govern those websites. Whether we have posted those links or other organizations or individuals have, you should read their 4 privacy policies and make an informed decision about whether you want to use those websites or their services.
Will myCareBase let users know if this Privacy Notice changes?
We may update this notice to reflect changes to our information practices but we will not reduce your rights under this Privacy Notice without your explicit consent. We’ll post any changes to this page and, if the changes are significant, we will provide a more prominent notice (including email notification if appropriate).
We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices and to contact us if you have any questions or concerns.
What do I do if I have questions or a complaint about myCareBase privacy practices?
You may send your privacy-related questions, concerns or complaints to our Privacy Officer who is responsible for ensuring our compliance with this notice and with the appropriate privacy legislation.
Stephanie Chan, CEO
If our Privacy Officer is unable to resolve the concern, you may also write to the Information and Privacy Commissioner of British Columbia .