Privacy Policy
Effective Date: [Insert Date]
Applies to: Adventist Health Canada and its affiliated Long-Term Care Association Care Homes (the “Organization,” “we,” “our,” or “us”).
1. Introduction
This Privacy Policy explains how we collect, use, disclose, and protect personal information when individuals visit adventisthealth.ca and related pages, including the Canadian Long-Term Care Association Care Homes information page.
As an organization connected to health-related services across Canada, we comply with federal privacy law (PIPEDA) as well as applicable provincial privacy legislation, including:
- Ontario: Personal Health Information Protection Act (PHIPA)
- British Columbia: Personal Information Protection Act (BC PIPA)
- Alberta: Personal Information Protection Act (AB PIPA)
- Québec: Act Respecting the Protection of Personal Information in the Private Sector (Law 25)
- Other provinces and territories: PIPEDA applies as the governing private-sector law
We also follow the Fair Information Principles recognized nationally.
2. Scope
This Policy applies to personal information collected through the Website, including:
- Contact forms
- Newsletter sign-ups
- Analytics tools (e.g., cookies, traffic logs)
- Any submissions or inquiries related to long-term care services and care homes
This Policy does not replace the separate health-information privacy policies used within individual long-term care homes or health facilities. Those policies are governed by provincial health-information laws such as PHIPA (ON), HIA (AB), E-Health Acts, and others.
3. Personal Information We Collect
We collect only the information necessary for the purposes described below.
3.1 Information You Provide
- Name, email address, phone number, or mailing address
- Information submitted in forms, questions, feedback, or service requests
- Optional details related to long-term care service inquiries
3.2 Automatically Collected Information
- IP address, browser type, device information
- Pages viewed, time spent, referring website links
- Cookies or similar tracking technologies for functionality and analytics
3.3 Sensitive Information
The Website does not request or store personal health information (PHI).
If a user voluntarily submits PHI (e.g., medical details in a contact form), we handle it according to the applicable provincial health-privacy law.
4. How We Use Personal Information
We use personal information strictly for purposes that a reasonable person would expect, including:
- Responding to inquiries or service-related questions
- Providing information about long-term care services
- Managing newsletter subscriptions or email updates
- Improving the Website’s performance and user experience
- Ensuring security and preventing misuse
- Meeting legal or regulatory obligations
We do not use personal information for unrelated secondary purposes without consent.
5. Consent
By using the Website or submitting information, individuals provide implied consent to the collection and use of their information for the purposes described.
Explicit consent is obtained where required by provincial or federal law — for example:
- Québec (Law 25) requires explicit consent for cross-border data transfers
- Certain provinces require explicit consent when handling sensitive information
Users may withdraw consent at any time, subject to legal or operational limitations.
6. Cookies and Tracking Technologies
We use cookies and analytics tools (e.g., Google Analytics) to:
- Improve website functionality
- Understand visitor behaviour
- Measure performance
Users may disable cookies in their browser; however, certain features may not function correctly.
7. Disclosure of Personal Information
We do not sell or rent personal information.
We may disclose personal information only to:
7.1 Service Providers
Trusted providers that help with hosting, analytics, email distribution, or security.
These providers must follow privacy protections comparable to PIPEDA or provincial equivalents.
7.2 Legal Requirements
We may disclose information if required to comply with:
- Provincial regulators
- Court orders
- Health-sector reporting obligations
- Federal or provincial investigations
7.3 Cross-Border Transfers
If service providers store or process data outside Canada (e.g., U.S.-based servers), we ensure compliance with:
- PIPEDA requirements for comparable protection
- Québec Law 25’s privacy impact assessment
- Any provincial restrictions on transferring PHI
8. Retention and Storage
We retain personal information only as long as required:
- To fulfill the purpose for which it was collected
- To meet legal, regulatory, or audit requirements
Information is stored securely using administrative, technical, and physical safeguards.
9. Your Rights
Depending on your province of residence, you may have the right to:
- Access your personal information
- Request corrections
- Withdraw consent
- Request deletion (Québec grants enhanced deletion rights under Law 25)
- Request details about cross-border data transfers
- Ask how automated decision-making may affect you (Québec Law 25 requirement)
We respond to such requests in accordance with PIPEDA and provincial laws.
10. Security Measures
We protect personal information using industry-standard safeguards, including:
- Secure servers and encrypted connections (HTTPS)
- Access controls and limited staff permissions
- Regular monitoring for vulnerabilities and unauthorized access
While no system is perfectly secure, we take all reasonable steps to protect information.
11. Links to External Websites
Our Website may include links to third-party sites (e.g., care homes, partner organizations).
We are not responsible for the privacy practices of those external websites.
12. Changes to This Privacy Policy
We may update this Policy periodically. Updates will be posted with a new “Effective Date.”
If required by law—such as under Québec’s Law 25—we will notify users of material changes.
13. Contact Information
For questions, access requests, or concerns about privacy, contact:
Privacy Officer
Adventist Health Canada
Email: [Insert Email]
Address: [Insert Address]
Phone: [Insert Phone Number]