Privacy Policy | Purkinje

Purpose

The protection of the personal information of its clients and their patients is of paramount importance and is part of its mission. Aware of its position as a leader in the field of health solutions and services, our organization has implemented best practices in privacy protection to comply with privacy laws to the best of its expertise and state of the art.

Purkinje's Privacy Policy protecting personal information describes the responsibilities of Purkinje, Purkinje employees, consultants, and temporary staff employed by Purkinje who have access to personal information to carry out the specific mandates our clients entrust to us, whether the information relates to our clients or their patients.

Scope

The scope and application of Purkinje's Privacy and Personal Information Policy are as follows:

Applies to the personal information of Purkinje's clients that is collected, used, or disclosed by Purkinje.
Applies to the management of personal information in all its forms, whether electronic, written, or oral.
Takes into account the requirements or provisions of applicable laws.

Definition of personal information

For the purposes of Purkinje's Privacy Policy, personal information means information about an identifiable individual, including personal health information as examples but does not include aggregated information that cannot be associated with a specific individual.

Privacy Principles

Accountability

Purkinje is responsible for the personal information under its control and has designated individuals who must ensure Purkinje's compliance with the following principles. Purkinje has designated the Privacy Officer as the person responsible for monitoring compliance with Purkinje's Privacy and Personal Information Policy.

The Privacy Officer can be reached at: [email protected]. Any request for information or complaint is tracked and responded to.

Purkinje has implemented principles and procedures to give effect to Purkinje's Privacy Policy, such as:

Contractual agreements regarding privacy and personal information with its employees, consultants, and temporary staff employed by Purkinje.
Training and awareness for its employees on privacy and personal information, including an annual update of Privacy and Personal Information requirements.
Implementation of data security standards, which describe the security requirements applicable to Purkinje's systems or network.
Purkinje's contractual agreements include appropriate privacy requirements in agreements with clients and third-party suppliers when personal information is collected, used, or disclosed.
Mechanisms are in place for receiving requests for information and complaints as well as for following up on such requests and complaints.

Purkinje is responsible for personal information in its custody or control, including information that has been transferred to a third party for processing. Purkinje must use appropriate means to provide a comparable level of protection when information is processed by a third party.

Purkinje may disclose, upon written request, the title of the person or persons appointed to monitor Purkinje's compliance with Purkinje's Privacy Policy.

Limiting Collection

Purkinje must determine the purposes for which personal information is collected before or at the time of collection.

Purkinje collects personal information for the following purposes:

To provide products or services to its clients in accordance with contractual obligations.
To manage and develop its business and internal operations.
To comply with legal and regulatory requirements.

Purkinje makes reasonable efforts to inform the client of the identified purposes for which personal information will be used or disclosed. The purposes are stated in a manner that can be reasonably understood by the client. Unless required by law, Purkinje does not use or disclose for any new purpose personal information that has been collected without first identifying and documenting the new purpose and obtaining the client's consent (whether a corporate client or an individual).

Employees who collect personal information from corporate clients or individuals must ensure that those clients or individuals are informed of the purposes for which the personal information will be used or disclosed.

Consent

The individual must be informed of the collection, use, or disclosure of personal information and consent to it, unless it is not appropriate to do so under applicable law.

Purkinje seeks consent:

From its corporate client, when personal information is collected by that client. This generally does not involve the individuals to whom the personal information relates, but who declare to Purkinje that they have obtained from those individuals the necessary rights to disclose the personal information to Purkinje and third-party suppliers, as applicable.
Directly from the individual, when personal information is collected by Purkinje from that individual.

In order to use or disclose personal information for the purposes identified at the time of collection, Purkinje undertakes to use the collected personal information only for the purposes stated in the consent request.

Purkinje may require clients to consent to the collection, use, or disclosure of personal information as a condition of providing a product or service if such collection, use, or disclosure is necessary to fulfill the identified purposes.

When employees collect personal information, they must contact the person designated by Purkinje to obtain the appropriate consents before the collection, use, or disclosure of the information.

In determining the appropriate form of consent, Purkinje must take into account the sensitivity of the personal information, the context, and the reasonable expectations of its clients. The client may withdraw consent at any time, subject to legal or contractual restrictions and with reasonable notice.

Limiting Use, Disclosure, and Retention

Purkinje shall not use or disclose personal information for purposes other than those for which it was collected, unless the corporate client or individual consents or the law requires it.

Purkinje may only disclose personal information relating to a client in the cases permitted under the terms of the contractual agreement with that client or as required by law.

Purkinje retains personal information only as long as necessary or relevant for the identified purposes or in accordance with legal requirements.

Accuracy

Personal information used by Purkinje must be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information is used for the provision of products and services.

However, it is the responsibility of the corporate client to ensure the accuracy of personal information when it is provided to Purkinje by the corporate client and not directly by the individual.

In such cases, Purkinje must rely on the corporate client to ensure that such information is accurate, complete, and up-to-date.

Purkinje shall, where appropriate and feasible, update personal information concerning its clients upon receipt of notice to that effect from them.

Security Safeguards

In accordance with Purkinje's corporate security policies and Purkinje's Data Security Policy, Purkinje shall, to the extent reasonable, protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification, or destruction, through security measures appropriate to the sensitivity of the information.

Purkinje must protect personal information disclosed to third parties through contractual agreements stipulating, among other things, the confidentiality of the information, the purposes for which it is intended, and its retention period; this period is usually defined by the use as provided for in the purposes of collection.

All Purkinje employees who have access to personal information are required to respect the confidentiality of personal information. Failure by an employee to comply with Purkinje's Privacy and Personal Information Policy may result in disciplinary measures up to and including termination of employment.

Purkinje must protect personal information through security measures appropriate to the sensitivity of the information.

Openness

Purkinje makes information about its policies and practices accessible to all through its website.

Purkinje shall provide, upon written request to [email protected], the title and email address of the person or persons responsible for Purkinje's compliance with this policy.

Purkinje must make available to its clients the information necessary to help them make choices, if applicable, regarding the use of the personal information concerning them.

Individual Access

Upon written request, Purkinje must inform its client of the existence of personal information concerning them, the use made of it, and its disclosure. Purkinje must give them a reasonable opportunity to consult their relevant personal information in their personal file. Personal information must be provided in an understandable form within a reasonable time and at a reasonable cost for processing their request or free of charge.

Any client may challenge the accuracy or completeness of their information and have it amended as necessary.

Purkinje must promptly correct or complete personal information found to be inaccurate or incomplete. Any unresolved challenge regarding accuracy or completeness is noted in the individual's file. If necessary, Purkinje transmits to third parties having access to the personal information in question any amended information or informs them of the existence of an unresolved challenge.

In certain cases, Purkinje may not be able to provide access to the personal information it holds about a client. Purkinje cannot, for example, provide access to information if such access:

Is requested by a corporate client, an individual, or a legal institution whose identity could not be verified or confirmed with certainty, or whose identity does not give them the right to access that information.
Is the responsibility of a corporate client (e.g., a patient's data cannot be modified by Purkinje because it is confidential and it is the responsibility of the clinic holding the information to correct it).
Would likely reveal personal information about a third party.
Is reasonably likely to endanger the life of another person.
Is reasonably likely to threaten the safety of another person.
Is available through other more appropriate means.
Would involve disproportionate effort or cost.

Purkinje may not be able to provide access to information if its disclosure:

Is the responsibility of a corporate client (e.g., a patient's data cannot be disclosed by Purkinje because it is confidential and it is the responsibility of the clinic holding the information to disclose it).
Would likely reveal confidential commercial information.
Could compromise the security of other information.
Is protected by solicitor-client privilege.
Would contravene the fact that the information was obtained in the course of a formal dispute resolution process or if the information was collected in the course of an investigation into a breach of an agreement or a contravention of a federal or provincial law.

If Purkinje cannot provide access to personal information, it must be able to provide the reasons for its refusal upon written request to [email protected].

Challenging Compliance

Purkinje must have a mechanism to receive information requests and complaints from its clients in order to handle them appropriately and log them. Purkinje may seek external advice before responding to various requests or complaints.

Purkinje must investigate all complaints regarding compliance with this policy. If a complaint is found to be justified, Purkinje must take appropriate measures to remedy the situation — including if necessary, modifying its policies and practices. The client must be kept informed of the progress and outcome of the investigation relating to their complaint.