Privacy Policy
Clinique THVR – Compliance with Bill 25
Last update : July 2025
Clinique THVR takes the confidentiality and security of your personal information very seriously. The purpose of this privacy policy (hereinafter referred to as “the Policy”) is to clearly explain how we collect, use, communicate, protect and store your personal information as part of our primary care services, including teleconsultation, while complying with the legal obligations set out in the Act to modernize legislative provisions respecting the protection of personal information (Bill 25).
1. Scope of the policy
The purpose of this document is to inform you :
- The types of information collected
- How this information is used and protected
- What rights you have to your personal information
- How to exercise these rights
This policy applies to all personal data collected by Clinique THVR, whether :
-
In the clinic, by telephone or teleconsultation
- Through our website
- Through partner platforms used to manage appointments or medical records
By submitting your information to us, you acknowledge that you have read this policy and consent to your information being processed as described.
Clinique THVR acts in accordance with applicable Quebec and Canadian laws, in particular:
-
Act respecting the protection of personal information in the private sector (LPRPSP) (P-39.1)
- Act respecting health services and social services (RLRQ, chapter S-4.2)
- Act to modernize legislative provisions respecting the protection of personal information (Bill 25)
Your consent is required prior to any collection or use of your information. Your consent must be free, informed and specific.
- Minors under 14 : consent required from parent or guardian
- Young people aged 14 and over can give their consent themselves, unless otherwise stipulated by law.
You may withdraw your consent at any time, except in the case of legal or security obligations.
In certain situations, we may provide you with specific information at the time of data collection. Your explicit consent may then be required for certain uses, communications or storage of your information.
4.A. We collect the information necessary to provide our services. This information may include:
HOW DO WE HANDLE YOUR PERSONAL INFORMATION?
| PATIENT | EMPLOYEE | WEBSITE VISITOR | |
|---|---|---|---|
| How do we collect your personal information? | When you contact us for an appointment or register for our services, by person, through telephone or via our digital platforms. | When you transmit your application, directly or through our partners. | When you use our website and agree to the use of certain tracers. |
| What personal information do we collect? | RAMQ number, name, address, telephone number, e-mail address, date of birth, gender, medical and pharmaceutical information, financial information, photograph. | Name, address, telephone number, e-mail address, date of birth, gender, academic and professional background, social insurance number. | – |
| From whom do we collect your personal information? | From you, the Quebec Health Record (QHR) or a third-party platform when you book an appointment. | – | – |
| Why do we collect your personal information? | – To confirm your identity. – To provide you with medical care tailored to your situation. – To keep track of your appointments and your file. – To respond to your consultation requests. – To manage and improve our clinical and digital services. – To comply with our professional and legal obligations. |
– | – |
| What happens if I refuse to provide your personal information? | In the absence of essential information, we may be unable to provide you with our medical services. | You may not be hired or become part of our team. | – |
| Who has access to your personal information? | Our medical and administrative staff in the course of their duties. Researchers or collaborators in the context of projects for which you have been informed and consented to. |
Administration, human resources and our employment management partners. | – |
| How do we share your personal information with third parties? | Through electronic communications or by secure fax, in compliance with applicable laws, to ensure continuity of your care. | – | – |
| How long do we keep your personal information? | As long as the therapeutic relationship is active, in accordance with professional and legal rules. | As long as the employment relationship is maintained and in accordance with legal obligations. | – |
| What are the risks associated with processing your personal information? | Risk of a privacy incident as defined above. | Risk of a privacy incident as defined above. | Risk of a privacy incident as defined above. |
| Where is your personal information stored? | In a Medesync and Pomelo electronic medical record, a secure digital platform developed by Telus Santé, designed to facilitate the management of communications between clinics and their patients. All in compliance with the requirements of the Ministère de la Santé et des Services Sociaux du Québec. | In our human resources management systems and with payroll providers, with physical and electronic safeguards. | – |
SOFTWARE USED
| SOFTWARE | SUPPLIER | UTILITIES | UPDATE SCHEDULE |
|---|---|---|---|
| WordPress | Automattic | Website | According to publisher |
| Medesync | Telus | Medical Record | By supplier |
| Pomelo | Telus | Secure digital platform designed to facilitate the management of communications between clinics and their patients | By supplier |
| Windows | Microsoft | Operating system | – |
4.B. Although automatically collected information is generally not considered personal information, in the sense that it is not collected in a way that would allow us to identify you personally, this policy is also intended to inform you about Clinique THVR’s practices with respect to automatically collected information.
The following types of information are collected automatically and are generally not considered personal information. Information collected through cookies may include, but is not limited to:
- Browser information
- Operating system
- Visited pages and requests
- Time and day of connection
- Frequency and duration of visits
- Geography and language preference
The information collected by cookies mainly enables us to :
- Process statistics and traffic information.
- Create audience lists for retargeting purposes.
- Facilitate navigation and improve service for your convenience.
Only authorized persons (healthcare professionals and duly trained administrative staff) have access to your information, within the limits of their duties.
Your data may also be transmitted to service providers (e.g. technology platforms, data hosting) under strict confidentiality agreements.
Within our organization we have assigned the following roles and responsibilities : Privacy Officer
- Develops and implements internal privacy policies.
- Trains team on their legal responsibilities and has employees sign confidentiality agreements.
- Maintains a log of security incidents.
- Evaluates incidents and reports high-risk ones to the authorities.
- Oversees confidentiality risks.
- Manages access to systems according to roles
- Ensures that external suppliers meet rigorous confidentiality standards
- Carries out a Privacy Impact Assessment for any project involving new technologies or the disclosure of sensitive information to third parties.
Administrative and/or clinical staff
- Collects and records patient consents.
- Digitizes documents and integrates them into the file.
- Respect signed confidentiality commitments.
- Report unusual events related to confidentiality.
- Follows ethical guidelines and internal confidentiality policies.
- Remains vigilant to potential risks and incidents.
We train and raise awareness among our staff and professionals through the following activities:
- Hiring policy
- Annual reminder of the importance of protecting personal data
- Encouragement to report any security or confidentiality incident
Risks to safety or life
We may need to disclose information to third parties (relatives, authorities, interveners) if we believe a person is in serious and imminent danger.
Judicial and police cooperation
In the event of a warrant or as part of criminal investigations, we may be legally obliged to pass on certain information to law enforcement or other competent legal authorities.
We retain your information for as long as necessary to provide our services, or as required by law. Once this period has elapsed, the data is securely destroyed to prevent any leakage.
Our systems are protected by robust physical, technological and organizational security measures. Despite these safeguards, no technology is infallible. You are invited to use our services from secure networks and to be vigilant against phishing attempts. If you believe your personal information may have been compromised, please contact us immediately.
Your information is stored and processed exclusively in Canada. No international transfers are made without your explicit consent.
In accordance with Law 25, you have the following rights:
- Access to your data
- Correction of inaccurate information
- Withdrawal of consent, within permitted limits
- Restrict access to certain parties
- Portability of your data to another organization
- Complain to our manager or to the Commission d’accès à l’information :
All requests can be addressed to our Privacy Officer:
- info@cliniquethvr.com
- 438-892-5974
You will be given a maximum of 30 days from receipt of your request to process it.
We ensure that the information we hold is up-to-date, accurate and complete, according to the information you provide.
Clinique THVR remains responsible for the protection of all information collected, including that transmitted to trusted partners. Any information provided intentionally or unintentionally by patients (e.g. uploaded photos) outside authorized channels is not treated as clinical data and will not be used without consent.
When you first visit our site, a consent banner informs you of the use of cookies and offers you the possibility of accepting or refusing them, according to your preferences.
Our site uses different types of cookies to enhance your experience:
- Essential cookies : necessary for the proper operation of the site (e.g. secure
browsing, access to protected areas of the site). - Analytical cookies : used to analyze site traffic and usage (e.g. Google Analytics).
- Advertising cookies : used to offer you relevant advertising based on your interests (e.g. Google Ads).
You can adjust your preferences at any time :
- By using the cookie management banner on our site.
- Or by configuring your browser settings to refuse or delete cookies.
This policy does not cover the practices of external websites to which our site may link. We invite you to consult their respective policies before providing them with your data.
Your personal information may be transferred outside Quebec in certain cases.
Clinique THVR does not use any profiling, biometric identification or automated decision-making technologies based on personal information.
This policy may be revised to reflect changes in legislation or our internal practices. The most recent version will be available at all times on our website.
