This Personal Information Protection Policy (hereinafter the "Policy") outlines how Clinique Médigo Inc. (Family Medicine Group, Specialized Clinics, CMS Endoscopy) collects, uses, communicates, retains, and destroys your personal information. For ease of reading, we will occasionally use the terms "we" or "the clinic" throughout the Policy.

We may provide you with additional information regarding the processing of your personal information, in certain cases, at the time of collecting your personal information. We may also obtain your specific consent in certain cases regarding the collection, use, communication, and retention of your personal information.

The Policy applies to the personal information we collect, regardless of the method, whether it is, for example, in person, by phone, or through our website.

By accepting this Policy or providing us with personal information after having had the opportunity to review the Policy or any other supplementary notice, you agree that your personal information will be processed in accordance with the Policy and the supplementary notice.

1. About Us
Here is our full identification information:

Clinique Médigo inc.
Ms. Paula Germain, responsible for the protection of personal information
165 boul. St Raymond, Gatineau, J8Y 0A7

Please feel free to contact our responsible for the protection of personal information for any questions or comments you may have regarding the Policy, how we handle your personal information, or to exercise your rights concerning your personal information.

You can contact our responsible for the protection of personal information online at the following web address:

https://cliniquemedigo765.sharefile.com/filedrop/dx176876-299e-4ec7-974f-9c6184dfa785
or via the button at the top of the page.

or by mail at the address listed above, addressed to the Responsible for the Protection of Personal Information.

Within La Clinique Médigo Inc., we have assigned roles and responsibilities as follows:
We train and raise awareness among our staff members and professionals (including our students and interns) through the following activities:

Explanation of the Personal Information Protection Policy
Teaching the personal information protection mechanisms implemented by the Clinic
Teaching the tools for transmitting information via electronic means, telephone, and through the Clinic's electronic medical record system.

2. Important Definitions
In the Policy, the following terms mean:
" Confidentiality incident" (i) unlawful access to personal information; (ii) unlawful use of personal information; (iii) unlawful disclosure of personal information; or (iv) loss of personal information or any other breach of the protection of such information.
" Renseignement personnel" Any information about an individual that allows, directly or indirectly, to identify them.

3.How we will handle your Personal Information
As an example, without limiting this to:

Appointment scheduling:
-Appointment scheduling through the Medical Clinic's portal will be preferred, given the security measures already implemented by the tool.
-Phone appointment scheduling will be done by ensuring a two-step identification of the patient.

Current patients:
-The identification kiosk in place will be preferred to ensure minimal verbal exchange of sensitive information.
-Separator panels are currently in place to reduce the transmission of accessible verbal information.
-Patients who do not wish to be called via the microphone or on the screen to avoid being identified may use an alternative method to be directed to their appointment location.
-Paper documents will be scanned into the confidential medical record and cannot be kept in paper form; they will be electronically uploaded to the portal and subsequently securely destroyed. Patients who are unable to access the portal will be able to view the paper document on-site following identification through their health insurance card with photo, or through two-step identification if applicable.

Sending documents to the Medigo Clinic
Any document sent to the Medigo Clinic—such as information forms, insurance documents to be completed, images, etc.—must go through the document upload tool provided on the website or via a secure address on the MSSS health network.
No other transfer of information may be conducted via an unsecured email address, unless the security between the two addresses exchanging personal information is ensured.
Employees and Job Candidates
Employees' personal information is kept confidential in a secure digital file and can only be accessed by employees authorized by Management.
Email or document exchange regarding employment eligibility must be done through the Clinic's confidential document upload system or via secure messaging between the candidate, their references, and the Clinic.

4. What Technological Tools do we Use?
Medfar Integrated Care Platform
https://www.medfarsolutions.com/fr/politique-de-confidentialite/

Exchange of information between healthcare network stakeholders
Microsoft 365, MSSS secure platform

Secure document upload website
ShareFile
https://www.sharefile.com/industries/healthcare

5. Security Measures and Inherent Risks
We follow industry security standards to protect the information we collect and receive. Specifically, we have implemented appropriate physical, technical, IT, and administrative protection measures to safeguard your personal information against a confidentiality incident.

Despite these measures, given the inherent risks associated with the use of computer systems, we cannot guarantee the security and confidentiality of the information you transmit or provide to us, and you do so at your own risk. If you have reason to believe that personal information has been compromised, please contact us using the details provided in Section 1 of the Policy.

6. How and Under What Conditions Will we Disclose Your Personal Information for Public Safety Purposes or for the Prosecution of Offenses?

6.1 In the Event of a Serious Risk of Death or Serious Injury
We may disclose personal information that we hold in order to protect an individual or a group of individuals when there is reasonable grounds to believe that a serious risk of death or serious injury, particularly related to a disappearance or an act of violence, including a suicide attempt, threatens this person or group, and the nature of the threat creates a sense of urgency.
The information may then be disclosed to the individual(s) exposed to the risk, their representative, or anyone capable of providing assistance. Only the information necessary for the intended purpose will be disclosed.

6.2 Law enforcement
We may also disclose information to the Director of Criminal and Penal Prosecutions or to a person or organization responsible for preventing, detecting, or prosecuting crime or violations of the law when the information is necessary for a prosecution related to a violation of applicable law in Quebec.
Finally, we may disclose information to a police department when it is necessary for the planning or execution of an intervention tailored to the characteristics of an individual or situation, in either of the following cases: 1° the police department intervenes, at our request, to provide assistance or support in the services we are providing to an individual; 2° we are working in coordination or partnership with the police department as part of joint psychosocial and police intervention practices.

7. Are Your Personal Information Transferred Outside of Quebec?
Outaouais being a border region, it is possible that your personal information may be transferred outside of Quebec, while respecting the rules established for access to personal information in both provinces.

8. What Are Your Rights Regarding Your Personal Information?
The law grants you various rights regarding your personal information. You specifically have the following rights:

Access : the right to ask whether we hold personal information about you and, if applicable, to request access to that personal information.

Rectification : the right to request the rectification of any incomplete or inaccurate personal information we hold.

Withdrawal of Consent : the right to withdraw your consent to the disclosure or use of the personal information we hold.

Restriction ou refusal of access : the right to request that a specific individual or a person belonging to a specified category of individuals be denied access to one or more pieces of information that you have identified.

Complaint : the right to file a complaint with our person responsible for the protection of personal information, as identified in Section 1, regarding this Policy, or to file a complaint with the Commission d'accès à l'information du Québec if you believe that a violation of personal information protection laws has occurred. To file a complaint with the Commission d'accès à l'information (Quebec), please use the appropriate form available at the following address:Pour les citoyens | Commission d'accès à l'information du Québec (gouv.qc.ca)

Portability : the right to request that your personal information be provided to you or transferred to another organization in a commonly used, structured technological format.

To exercise any of these rights, please contact our person responsible for the protection of personal information in the manner indicated in Section 1 of this Policy.

9. Third-Party Websites
This Policy does not apply to third-party websites, pages, or applications that can be accessed through our services, and we are not responsible for such third-party services.
If you follow such links, those third-party sites or services are likely to have their own privacy policies, which you should review before submitting your personal information.

10. How Do We Update This Personal Information Protection Policy?
We may, from time to time, modify the Policy to reflect changes in our business processes or in the law.