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Privacy Policy: Institute for Quality Management in Healthcare

Overview

Institute for Quality Management in Healthcare (“IQMH”) values its relationships with its clients, business partners, board members, committee members, assessors, and advisors and anyone else who helps IQMH achieve its mandate. In furtherance of that mandate, IQMH is committed to protecting your Personal Information that it may collect, use and disclose, in accordance with applicable privacy law. In cases where privacy laws do not directly apply, IQMH aspires to meet the standards under the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

IQMH is also committed to providing you with understandable and easily available information about its privacy practices. This Privacy Policy (the “Policy”) contains information regarding how IQMH collects, uses and discloses your Personal Information, so please read it carefully. If there are any changes to IQMH’s privacy practices or applicable privacy law, IQMH will update this Privacy Policy without notice and post a revised Policy to its website.

What is in this Privacy Policy?

This Policy covers the following:

  1. Application of this Policy.
  2. Consent.
  3. What is Personal Information.
  4. What Personal Information do we collect?
  5. How do we collect your Personal Information?
  6. How we use your Personal Information?
  7. Disclosure of personal Information.
  8. Storage and cross border transfers of Personal Information.
  9. How do we protect your Personal Information?
  10. How long do we retain your Personal Information?
  11. Links to other websites.
  12. What do we do in case of a security breach?
  13. Cookies and embedded scripts.
  14. Resolving your privacy concerns.
  15. Conflicts and Interpretation of Policy.
  16. How to contact us
  17. European Union General Data Protection Regulations (GDPR)


Important Privacy topics that you need to know

The key elements of this Policy are set out in this summary, the details of which are set out in the sections following this summary

IQMH may collect your Personal Information when you contact IQMH, act for or represent IQMH, register with IQMH, use IQMH products and services, or otherwise provide IQMH with your Personal Information. Examples include:

  • Client Information: representative’s name, direct phone number, email address, credit card information.
  • Business Partner Information: name, address, direct phone number, email address, allergy information, as applicable.  
  • User Generated Information: IP address, information provided in the course of communications with IQMH.
  • Patient Experience/Personal Health Information: Patient narratives and other information collected by IQMH on behalf of its clients.

 

Examples of the purposes for which IQMH may use your Personal Information are:

  • To develop products and services.
  • To provide laboratory assessment services.


Examples of to whom IQMH may disclose your Personal Information are:

  • Affiliated or related entities to enable product and service delivery.
  • Third party providers that provide assessment services.
  • Third party providers that provide safety and security services.
  • Third party cloud-based storage and computing services. 


You have the following choices:

Depending on the products, services or your use of the IQMH website or portal services, your choices may include the following:

  • Cookies Settings and Preferences.  You may disable cookies and other tracking technologies through the settings in your browser. While doing so may negatively affect your experience with the use of the IQMH website, it will not prevent IQMH from transacting with you, unless IQMH advises you otherwise.
     
  • Marketing e-mails. You may sign up to IQMH mailing lists in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive marketing e-mails from IQMH, you may choose to unsubscribe at any time by clicking the “unsubscribe” link in the applicable IQMH email or contact the IQMH Privacy Officer as set out in the “How to Contact Us”.
     
  • Opt-in/Opt-Out. You may contact us to opt-in or opt-out of the use or sharing of your Personal Information, including for marketing or advertising purposes, and/or the provision of your personal information to our business partners for such purposes.


Changes to our Policy

We may modify our Privacy Policy from time to time to reflect changes in our business and practices, and you should our Privacy Policy periodically. When we do post changes to our Privacy Policy, we will update the “last modified” date at the end of the Policy.  Continuing to use our Services after we publish changes to our Privacy Policy means you are consenting to the changes.

How to contact us:

For more information about this Policy, our privacy practices or to obtain access to or correction of your personal information, please email IQMH’s Privacy Officer at Privacy@healthstandards.org or write to Institute for Quality Management in Healthcare, 1500-393 University Avenue, Toronto, Ontario, M5G 1E6, Canada.

Full Version

1. Application of this Policy

1.1 IQMH

This Privacy Policy applies to Personal Information collected by IQMH about any person, including without limitation its clients, board members, business partners, and website visitors. This Policy does not apply to the Personal Information of employees.         

1.2 Business Partners

IQMH’s business partners include: (1) assessors; (2) other contractors, faculty and advisors; (4) patient partners; (5) partners to save lives; (6) sales representatives; and (7) technical committee members. Business partners, in the course of conducting their duties, on behalf of IQMH, may also have access to and collect Personal Information and Personal Health Information. This is addressed in section 4.

2. Consent

By using our website or services, or otherwise interacting with us, you consent to the collection, use and disclosure of your Personal Information by IQMH in accordance with the terms of and for the purposes set out in the Policy. If IQMH wishes to collect, use or disclose your Personal Information for any additional purposes, it will obtain your express consent (by verbal, written or electronic agreement).

You are free to refuse or withdraw your consent, subject to legal and contractual restrictions. The refusal or withdrawal cannot be applied retroactively. In cases where your Personal Information is required, we may not be able to provide those products and services to you without your Personal Information. We will inform you of the consequences of refusal or withdrawal as appropriate.

Where consent is obtained by a client or business partner of IQMH for the processing of that Personal Information by IQMH, we will undertake reasonable measures to ensure that the consent on which we rely – as the basis for the collection, use or disclosure – is in compliance with applicable privacy laws, as appropriate.

If you do not agree to the terms of this Policy, you should exit the website, Client Portal, Partner Portal or Assessor Portal, and cease use of all of IQMH’s services immediately, or contact IQMH to withdraw your consent where applicable. Your continued use following the posting of any changes to this Policy means you agree to be bound by the terms of this Policy to the greatest extent permitted by law.

3.            What is Personal Information?

“Personal Information” means any information, in any form, about an identifiable individual or an individual whose identity may be inferred or determined from such information. IQMH considers business contact information that identifies an individual (e.g. individual’s name, direct telephone number, and direct email address) to be Personal Information as intended by this Policy.

This Policy does not apply to aggregate or anonymous information, which subject to agreement, remains in the custody and control of IQMH.

4. What Personal Information do we collect?

4.1 Types of Personal Information

Information about our Clients

-Representative’s name

-Identifying address (i.e. office number)

-Direct phone number

-Email address

-Credit card information

-Identifying billing information

Information held by our Clients

-Personal health information, when IQMH operates as an agent and provides survey services to its clients.

Business Partners and Board Members

-Name and contact information (i.e. address, email address)

-Emergency contact information and allergy information

-Information required for onboarding (i.e. interview notes)

-Information required to govern the contractual relationship (i.e. SIN), where applicable

Webinar Attendees

-Name and contact information (i.e. address, email address)

-Billing information


We collect only such Personal Information as we deem to be reasonably required in the circumstances for the purpose(s) for which it is collected.

4.2 Personal Health Information that we collect

IQMH may collect personal health information directly from individuals, when it acts as a service provider/agent to its clients. For example, IQMH may be engaged by health care providers to provide survey services. This personal health information, at all times, remains in the custody and control of its clients and IQMH only operates under the direction of its clients in these circumstances. IQMH ensures that any of its obligations as an agent, as required by applicable privacy laws, are  addressed in each specific circumstance, via contractual measures and by employing reasonable measures to ensures its clients have obtained valid consent to the collection of personal health information, for example.

4.3 Personal Health Information accessed/collected by our business partners

Assessors may access personal health information in the custody and control of IQMH’s clients when providing clients with licenced laboratory assessment products and services. Assessors do not collect any Personal Information, do not remove it offsite and do not disclose it to IQMH or any third party.

Business partners and IQMH may also collect personal health information inadvertently during the survey development process (i.e. during a patient experience interview, where personal health information is disclosed by the patient). This information is de-identified at IQMH’s earliest opportunity and no identifying information is retained by IQMH. Appropriate consents are acquired at the time the personal information is collected, in line with applicable privacy laws for each particular situation.

5. How do we collect Your Personal Information?

Personal Information is collected in the course of the following interactions with IQMH:

a) When individuals create accounts on our website or create (or are provided) accounts with any Client Portal, Partner Portal or Assessor Portal operated by IQMH.

b) When individuals place orders through our website for goods and services.

c) When individuals respond to online or email surveys, or provide information to us in person, in writing, by fax or over the telephone when asked for such information.

d) In the course of a licensed assessment process, where information is uploaded by clients and business partners.

6. How do we use Your Personal Information?

6.1 Purposes

We use Personal Information for the following purposes:

a) For the performance and delivery of licensed laboratory assessment products and services.

b) To generate anonymized or statistical data.

c) For the performance and delivery of education and training sessions and webinars.

d) To process transactions for the purchase of goods and services.

e) To improve our products, services and website.

f) To enter and maintain contractual relationships with business partners.

g) To inform clients of, or offer goods or services.

h) To comply with our statutory obligations or any lawful order.

6.2         Transfer of Personal Information to Affiliates, Related Entities and Business Partners

Your Personal Information will be accessible to our affiliates, related entities and business partners, as required for the delivery of licensed laboratory assessment products and services.

6.3         Transfer of Personal Information to Third Party Service Providers

Your Personal Information may be collected by or transferred to third party service providers for processing. Such uses include:

a)           The delivery of surveys.

b)           The de-identification of personal information.

c)            The maintenance, review and development of our systems, procedures and infrastructure, including testing or upgrading our computer systems.

d)           To ensure the safety of our business partners that travel to foreign jurisdictions.

IQMH uses Mailchimp, and in accordance with its Data Processing Addendum, its privacy policy can be found at Privacy Policy.

Unless permitted or required by the applicable laws, IQMH does not use Personal Information for other purposes.

6.4         How do we use your Personal Information for marketing?

We may, occasionally, send you information by electronic means (this includes email, telephone, text message (SMS) or automated calls about our products and services.

Other entities within our group, or which we have selected carefully, may also send you similar marketing messages, depending on whether you have consented.

We will also regularly send you information via email/SMS/other automated means to ask about your marketing preferences. You can confirm whether you would like us and other businesses to send you marketing messages by checking the appropriate option.

If you have consented to receive marketing from our group or other businesses, you can opt out and opt back in at any time.

7.            Disclosure of Personal Information

We do not disclose Personal Information to any organization or person for any reason except as set out in this Policy, where we have obtained your express consent, or where otherwise permitted by law. Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted without your consent or where IQMH is obliged to disclose your Personal Information without consent. 

Where obliged or permitted to disclose Personal Information without consent, IQMH will not disclose more Personal Information than is necessary for the relevant purposes of such disclosure.

8.            Storage and cross border transfer of Personal Information

Hard copies of records containing Personal Information, where they exist, are stored by IQMH in Ontario, Canada. In most cases, electronic copies of records containing your Personal Information are stored on servers located in Ontario, Canada. Some third party service providers engaged by IQMH may store your personal information in foreign jurisdictions. Such third party service providers are not engaged to provide services in jurisdictions with foreign storage restrictions.

Where Personal Information is accessed, transferred or stored outside of Canada, your Personal Information may be subject to access by and disclosure to law enforcement agencies under the applicable foreign legislation.

9.            How do we protect your Personal Information?

9.1         Physical, technical and organizational security measures

We employ a variety of physical, technical and organizational security measures to maintain the safety of Personal Information.

We offer the use of a secure server. All sensitive financial (e.g. credit card) information, any information provided via IQMH’s websites, Client Portal and Assessor Portal is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers’ database, where it is only accessible by those authorized with special access rights to such systems, and who are required to keep the information confidential.

9.2         When engaging third party service providers

The transfer of personal information to third party service providers for processing will occur only after those entities have entered into a contractual arrangement that:

a)           prohibits the third party from using the information for purposes other than those specified by IQMH;

b)           prohibits them from allowing access to or disclosing Personal Information to any other party (unless required to do so by law); and

c)            requires them to have appropriate safeguards in place to ensure the ongoing protection of Personal Information.

10.         How long do we retain your Personal Information?

We keep your Personal Information only for as long as it is required. The length of time we retain Personal Information varies depending on the purpose(s) for which it was collected and for which consent was obtained. This period may extend beyond the end of your relationship or contract with us.

Where Personal Information is no longer required for IQMH’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form. 

11.         Links to other websites

IQMH may provide links to, or automatically produce search results for third party websites or resources or third party information referencing or linking to third-party websites or resources. IQMH has no control over such third-party websites and resources, and website users acknowledge and agree that IQMH is not responsible for the content or information contained therein. When website users follow such a link, they are no longer protected by our Policy, and we encourage you to read the privacy statements or other disclaimers of such other third parties. IQMH is not responsible for privacy or security practices or the content of others’ websites, services or products.

12.         What do we do in case of a security breach?

A “breach of security safeguards” is the loss of, unauthorized access to or unauthorized disclosure of Personal Information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards. In case of a breach of security safeguards involving Personal Information under IQMH’s custody or control, we will notify you and the appropriate federal or provincial Privacy Commissioners in Canada, in line with the applicable privacy laws. We may also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach. We will keep a record of any breach of security safeguards.

13.         Cookies and Embedded Scripts

13.1       Cookies

We use cookies, which are small data files that are saved to your device when you visit our website and use this service. Cookies help analyze web traffic and help us provide you with a better website experience, by enabling us to monitor which pages you find useful and which you do not. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, his may prevent you from taking full advantage of the website.

The table below explains the cookies we use and their purpose.

Developer

Name

Purpose

Universal Analytics (Google)

_ga

_gali

_ gat_UA-91005729-1

_gid

These cookies are used to collect information about how visitors use our website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

Read Google’s overview of privacy and safeguarding data (https://support.google.com/analytics/answer/6004245)

Web Analytics (ClickDimension)

cusid

cuvid

cuvon

cd_optout_accountkey

These cookies are used to collect information about how visitors use our website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

DoubleClick

__ar_v4

This targeting/advertising helps with tracking conversion rates for ads.

YouTube cookies

PREF*

VSC*

VISITOR_INFO1_LIVE*

remote_sid*

We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.

Read more at YouTube’s embedding videos information page. (http://www.google.com/support/youtube/bin/answer.py?hl=en-GB&answer=171780)

Hotjar cookie

_hjClosedSurveyInvites

This cookie is set once a visitor interacts with a Survey invitation modal popup. It is used to ensure that the same invite does not re-appear if it has already been shown.

Hotjar cookie

_hjDonePolls

This cookie is set once a visitor completes a poll using the Feedback Poll widget. It is used to ensure that the same poll does not re-appear if it has already been filled in.

Hotjar cookie

_hjMinimizedPolls

This cookie is set once a visitor minimizes a Feedback Poll widget. It is used to ensure that the widget stays minimizes when the visitor navigates through your site.

Hotjar cookie

_hjDoneTestersWidgets

This cookie is set once a visitor submits their information in the Recruit User Testers widget. It is used to ensure that the same form does not re-appear if it has already been filled in.

Hotjar cookie

_hjMinimizedTestersWidgets

This session cookie is set to let us know whether that visitor is included in the sample which is used to generate funnels.

 

You can disable cookies completely, or be prompted prior to a cookie being loaded, by adjusting your browser’s settings. Consult each individual browser’s “help” feature for more information.

Find out how to manage cookies on popular browsers:

Google Chrome

Microsoft Edge

Mozilla Firefox

Microsoft Internet Explorer

Opera

Apple Safari

Mailchimp: Cookie Statement.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

13.2       Embedded Scripts

An embedded script is a programming code that is designed to collect information about your interactions with our website, such as information about the links on which you click. The code is temporarily downloaded onto your device from our web server or a third party service provider. The code is active only while you are connected to our website, and is deactivated or deleted once you disconnect from the website.

14.         Resolving Your Privacy Concerns

14.1       Questions and Comments

In the event of questions about: (i) access to Personal Information; (ii) our collection, use, disclosure or storage of Personal Information; or (iii) this Policy; please contact IQMH’s Privacy Officer by sending an e-mail to Privacy@healthstandards.org.

14.2       Complaints

 

IQMH will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.

 

14.3       How Can You Access or Correct Any Inaccuracies In Your Personal Information?

IQMH endeavors to ensure that all Personal Information provided by or about you and in its possession is accurate, current and complete, as necessary for the purposes for which we use that Personal Information. If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the Personal Information and, if necessary, use our best efforts to inform third party service providers or contractors which were provided with inaccurate information to enable those third parties to also correct their records.

IQMH permits the reasonable right of access and review of Personal Information held by us and will endeavour to provide the Personal Information in question within a reasonable time, generally no later than 30 days following the request subject to applicable law. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.

We will provide copies of the Personal Information in our possession in a form that is easy to understand or in a summary form where appropriate. IQMH reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate. IQMH will not charge you for verifying or correcting your information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.

15.         Conflicts and Interpretation of Policy

Should there be, in a specific case, any inconsistency between this Policy and Canada’s federal and provincial privacy laws, as applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

To the extent of any conflict between the Policy in English and any version in another language, the English version shall prevail.

16.         Contact Us

Institute for Quality Management in Healthcare
1500-393 University Avenue Toronto
Ontario
M5G 1E6
Canada

privacy@healthstandards.org

17.         The European Union General Data Protection Regulation

This Policy also contains certain information required by the European Union (“EU”) Regulation No. 2016/679 of 27 April 2016, known as the General Data Protection Regulation (“GDPR”), and mirroring legislation (with the GDPR, the “European Data Privacy Laws”) of the other countries (Norway, Iceland and Liechtenstein) forming with the EU Member States the European Economic Area (the “EEA”), which apply when we process personal data about individuals located in the EEA in relation to (i) the offering of goods and services to these individuals or (ii) the monitoring of their behaviour in the EU or EEA – at the moment we consider that only processing of personal data about individual assessors in the EEA would fall within the scope of European Data Privacy Law.

17.1       Storage of personal data of individuals in the EEA for processing activities falling within the scope of European Data Privacy Laws

The following provisions apply only to personal data of individuals in the EEA for processing activities falling within the scope of European Data Privacy Laws:

(i)           As regards customers, assessors and other persons with whom we have a contractual relationship as well as their individual representatives, we will hold all personal information for so long as IQMH is in a contractual relationship. We may then (i) archive the data up to one year after the applicable limitation period has expired or final settlement of any dispute whichever is last and (ii) keep contact details for the purposes of direct marketing for a period of up to 3 years after termination of the contract or last contact made by the relevant individual.

(ii)          As regards prospects, we keep their contact details for the purposes of direct marketing for a period of up to 3 years after time of collection or last contact made by the relevant individual.

(iii)         As regards website/app/email users who do not provide us with their contact details, we maintain a log during 18 months before anonymising the data; as regards expiration of cookies, please see above.

Individuals in the EEA are hereby informed that we may transfer and store their personal data in the EEA, Canada and other countries deemed to offer an adequate level protection according to the European Commission as well as the United States of America, provided that any recipient of personal data based in the United States of America adopted corporate binding rules or entered into a data transfer agreement containing clauses offering an adequate level protection according to the European Commission.

17.2       What’s the legal basis for these uses under European Data Privacy Laws?

When European Data Privacy Laws apply and you are an individual in the EEA, we inform you that IQMH is allowed to process your personal data on the following legal bases.

(i)           Legitimate interests. IQMH is permitted to process your personal data if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing your personal data which is in our interests. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. The following personal data processing activities are based on this ground:

a)           contacting or verifying the authority of an individual representing an organisation in relation to the execution or performance of a contract with that organisation and keeping exchanges with that individual as evidence in case of a possible dispute with that organisation.

b)           anonymising personal data for generating statistics that can be used for, amongst others, improving our products and services and our website.

c)            improving our products and services and our website when this cannot be done without first anonymising the data.

d)           providing information to debt or equity investors or donators in order to incite them to invest or donate or continue to do so.

e)           presenting or communicating on our good or services or requests for donations when we do not need consent.

 

(ii)          Contract. IQMH is also permitted to process your personal data every time it is necessary for the entry into or the performance of the contract you have agreed to enter with us. If you do not provide the necessary personal data, we will not enter the contact for which it is necessary or we will not be able to carry out our obligations thereunder in case of personal data necessary for its performance.

(iii)         Legal obligation. IQMH is also permitted to process your personal data every time it is necessary for the purposes of complying with applicable regulatory, accounting and financial rules, health and safety and to make mandatory disclosures to government bodies and law enforcements.

(iv)         Consent. Your consent may be asked for the presenting or communicating on our goods or services or requests for donations when this cannot be done on the sole basis of our legitimate interests, You can withdraw this consent at any time but any withdrawal of consent cannot be retroactive.

(v)          Public interest or official authority. IQMH is also permitted to process your personal data when necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us by the relevant authorities, namely the assessment of laboratory facilities.

17.3       Rights afforded under European Data Privacy Laws

When European Data Privacy Laws apply and you are an individual in the EEA, we inform you that you have the rights set out below.

You may exercise these rights by contacting us at the email address indicated in this Policy. We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months.

Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the European Data Protection Laws.

(i)           Right to object to processing of your personal data

You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing. If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so.

In particular, you can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:

•             email, call or write to us (at Communications@healthstandards.org). You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 14 business days for this to take place.

•             provide proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

•             provide us with details of your preferred method of contact (for example, you may be happy for us to contact you by email but not by telephone).

(ii)          Right to access personal data relating to you

You may ask to see what personal data we hold about you and be provided with:

•             a copy of the personal data;

•             details of the purpose for which the personal data is being or is to be processed;

•             details of the recipients or classes of recipients to whom the personal data is or may be disclosed, including if they are outside the EEA and what protections are used for those transfers;

•             the period for which the personal data is held (or the criteria we use to determine how long it is held); and

•             any information available about the source of that data.

To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.

(iii)         Right to correct any mistakes in your information

As indicated above, you can require us to correct any mistakes in your information which we hold. If you would like to do this, please let us know what information is incorrect and what it should be replaced with.

(iv)         Right to restrict processing of personal data

You may request that we stop processing your personal data temporarily if:

•             you do not think that your data is accurate (we will start processing again once we have checked whether or not it is accurate);

•             the processing is unlawful but you do not want us to erase your data;

•             we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or

•             you have objected to processing because you believe that your interests should override our legitimate interests.

(v)          Right to data portability

You may ask for an electronic copy of your personal data which we hold electronically and which we process on the basis of a contract with you or with your consent.

(vi)         Right to withdraw consent

You may withdraw any consent that you have given us to process your personal data at any time. This means that we will not be able to carry out any processing which required use of that personal data.

(vii)        Right to erasure

You can ask us to erase your personal data:

•             should we not need your data anymore in order to process it for the purposes set out herein;

•             if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;

•             if you object to our processing and we do not have any legitimate interests that mean we can continue to process your data; or

•             if your data has been processed unlawfully or have not been erased when it should have been.

(viii)       Rights in relation to automated decision making

You have the right to have any decision that has been made by automated means and which produces legal effects or has a similar significant effect on you reviewed by a member of staff, it being noted that our processing activities do not fall in that category.

(ix)         France only – directives for handling personal data after death

If you are in France, we inform you that you may write directives about the handling of your personal information after your death.

(x)          Complaints to a European supervisory authority

It is important that you ensure you have read this Privacy Policy and, if you do not think that we have processed your data in accordance therewith, you should let us know as soon as possible. You may also complain to any European competent supervisory authority.

17.4       Personal Data Breach

Individuals in the EEA are hereby informed that we will also comply with the documentation and notification requirements of articles 33 and 34 of the GDPR in case of a personal data breach as defined in the GDPR.

 

This Privacy Policy was last modified on: October 8, 2020.

Effective Date: October 8, 2020.

 

Institute for Quality
Management in Healthcare

1500-393 University Avenue
Toronto, Ontario M5G 1E6 Canada

T:416-323-9540 

 TF:1-877-323-9540 

 F:416-323-9324 

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