Oncology Simplified Inc. – Introduction and Privacy Policy Last Modified – July 2024
This policy describes the information practices of Oncology Simplified Inc. (“Oncology Simplified”, “we”, “us”, “our”) including the purposes for which we collect, use and disclose personal health information.
Who We Are and Why We Created Oncology Simplified.
We are a Canadian Company headquartered in Southwestern Ontario, founded in response to requests for assistance from individuals struggling to understand or manage their cancer related testing and treatment needs. The founders worked with experts specializing in different types of cancers to design and implement services to fill gaps in oncology related services currently available in the healthcare system. Oncology Simplified delivers its services (“Services”) through consultations with registered nurses, nurse practitioners, registered dieticians and pharmacists licensed to practice in Ontario (“Healthcare Providers” or “HCPs”) through electronic means (“Consultations”), as described below in the Section “Online Delivery of Services”. As of the date posted above, Oncology Simplified only offers Services in Ontario.
HCP Accountability
Oncology Simplified recruits HCPs with expertise in oncology and verifies that they are in good standing with their regulatory body. HCPs are independent contractors to Oncology Simplified and are responsible to Oncology Simplified clients (“Clients”) for the care that they provide. Clients have a health professional/patient relationship with the HCPs from whom they receive Services. Oncology Simplified designs the Services, and provides administrative functions, including registering Clients and billing. To facilitate access, even where an HCP ceases to provide Services, we are the custodian of Client records including records of personal health information created or compiled by HCPs (“Records”). As such, Oncology Simplified is responsible for maintaining Records in compliance with applicable privacy law.
Services
Our Services are supportive cancer care services, tailored to a Client’s needs and clinical history. It is important to understand that they supplement and support but do not replace the healthcare services available or being provided to Clients through their family physician, oncologist or other providers. We offer three types of supportive services: everyday cancer services (“ECS”) via phone, video or chat functions, advanced cancer services (“ACS”) via phone or video, and caregiver emotional support services (“CES”) via phone or video. We include an overview below, but encourage you to read the full description of each of the Services on our website: Oncology Simplified | Personalized Cancer Services
Eligibility Criteria:
You (Client) represent and warrant (promise) to Oncology Simplified and acknowledge that Oncology Simplified is relying on your representations and warranties that:
Our Privacy Practices
Collection/Use of Client Data
Oncology Simplified collects and uses Client Data for the purpose of delivering, and to the extent necessary to deliver the Services and to comply with legal requirements. We do not record the audio or video portions of consultations with HCPs. Medical Office Administrators (Personal Health Information Privacy Agent of Oncology Simplified) may support the intake of personal information or PHI necessary to tailor your call with HCPs. However, HCPs are responsible for creating and compiling records of the Services they provide, which records will be maintained by Oncology Simplified in Canada. HCPs will have access to Records through the TELUS CHR system.
The Client Data that we collect or create may include some or all of the following:
Disclosure of Client Data
If you provide us with a list of your care team members, such as your family doctor or oncologist, or your substitute decision maker, we will understand that you are authorizing us to disclose information including PHI in your Records to them. Notwithstanding this authorization, it is your responsibility to keep your care team members updated about the Services you are receiving. We do not guarantee that we will provide information in your Record to any member of your care team. In some cases, we may have to disclose your PHI to comply with the law, such as if we receive a subpoena or court order. We might also need to disclose your PHI to advance our legal rights, defend against legal claims, and deal with illegal activities such as fraud or threats to Client or third-party safety or reputation.
Third Party Service Providers
We use third-party software and service providers for a variety of services, such as technical, operational, and marketing services. For example, our credit card processing is provided through a third-party service provider. We require our third-party service providers to limit their use of Client Data to that which is necessary for their services and to have appropriate security measures in place to protect Client Data from unauthorized access, use and disclosure. Some of our third-party services operate from outside of Canada, which means that Client Data to which they have access to provide their services to us will be subject to laws other than the laws of Ontario or Canada and may be available to foreign governments and authorities under the operation of those laws or orders made under those laws. Additional information about our third-party service providers is available through links in Appendix 1 to this policy.
Access and Correction of Client Data
Clients may update or otherwise correct the Client Data that they provided at any time, but not Client Data that an HCP has created or compiled.
Clients can access their Record by sending a request to info@oncologysimplified.com or by calling us at 1-437-500-5000. Subject to our discretion under the law to withhold PHI, we will provide the Record through a secure message via CHR Connect. The security of any copy of a Record that a Client downloads is the Client’s responsibility. After six months of account inactivity, we will archive Client Records and close the related Client account. We will retain archived Records as required by applicable regulations which is generally set as ten years and during that timeframe, Clients can request their archived Records by sending a request to info@oncologysimplified.com or by calling us at 1-437-500-5000. Clients may name individuals (substitute decision maker) who may request their Records if for any reason, they are unable to do so. If no individual is named as substitute decision maker, we may not be legally authorized to release the Records to the requestor.
Security Measures
We prohibit our personnel (“Personnel,” which includes our employees, independent contractors and HCPs) from accessing Client Data except as necessary for the provision of their services. We require Personnel to complete privacy and security training and to commit to complying with our policies, procedures and applicable privacy law.
Oncology Simplified has implemented security measures to protect Client Data including but not limited to the following:
Notwithstanding the safeguards we employ to deliver the Services, we cannot guarantee the security or error-free transmission, storage or maintenance of Client Data. There are risks inherent in the use of electronic means to transmit and hold information in electronic format. These risks can be minimized but not eliminated by the use of appropriate security measures, such as those we employ. These risks include interception, loss, corruption, unauthorized access to, use and disclosure of Information, and delay in the availability of Information.
Clients play an important role in protecting and the privacy of their Client Data, including by:
Links to Third Party Websites
The Services and the resources section of our website provide may provide links to websites or content that we do not own or operate. This policy does not apply to such sites or content, and we are not responsible for the content or privacy practices applicable to the sites. We provide the links solely for convenience. Our provision of the links does not constitute an endorsement of or referral to the linked websites or content. We strongly encourage you to review the privacy policies and terms of use applicable to any website you choose to access through the links.
Amendments to this Policy
Oncology Simplified last updated this Privacy Policy (“Policy”) on the date posted at the top of the policy. We reserve the right to amend the Policy at any time to account for changes in applicable law, our practices and the Services. Please check to see if we have amended the policy since you last used the Services as by continuing to use the Services, we will understand that you have agreed to the amended policy.
Contact Us
If you have any questions or concerns about our privacy practices, please contact our Compliance Officer through one of the means indicated below. Please include your name and contact information if you would like us to respond to you.
By post to: Oncology Simplified Inc., ATTN: Haya Sarras — Compliance Officer, 151 Charles St. West Suite 100, Kitchener, ON N2G 1H6
By email to: privacy@oncologysimplified.com
By telephone: 1(437)-500-5000
Appendix 1 - Links and system integrations
Telus CHR Connect: CHR Connect App | TELUS Health
SRFax Integration: https://help.inputhealth.com/en/articles/5180974-srfax-integration
Stripe Integration: https://help.inputhealth.com/en/articles/5192642-overview-of-collecting-private-bill-payments-using-stripe
OLIS integration: https://help.inputhealth.com/en/articles/5721823-getting-connected-to-olis