Privacy Policy
Orthopaedic Access — Patient Navigation and Coordination Services
1 Who We Are
Orthopaedic Access Inc., operating as Orthopaedic Access (“we”, “us”, “our”), is a private patient navigation and coordination service based in Toronto, Ontario. We are neither a healthcare provider nor a health information custodian under Ontario’s Personal Health Information Protection Act, 2004. Our collection, use, and disclosure of personal information, including personal health information (“PHI”), are governed by the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”).
2 Information We Collect
- Identity and contact information: name, date of birth, address, phone, email.
- Ontario health number, collected only for identity verification and record-linking (see Section 3).
- Health information you provide: symptom history, injury details, functional impact, treatments tried, medications, and relevant conditions.
- Health records you provide or direct others to provide: imaging and reports, physician and specialist notes, discharge summaries, referral correspondence.
- Booking and administrative information collected through our website (name, email, phone, selected service, general body region, and, where you choose to add it, a general description of your inquiry).
3 Why We Collect It
We collect and use your information to: assess your situation for navigation purposes; identify orthopaedic surgeons and clinics appropriate to your stated condition; prepare a referral brief for your physician; coordinate imaging and appointments and follow up with provider offices; support our Orthopaedic Liaison’s review of your file, as described in your signed Consent; and administer our services and meet our legal obligations. We do not use your information for marketing, do not sell it, and do not use it for any purpose beyond those described here and in your signed Consent without your further express consent.
4 Who We Share It With
Your family physician or telehealth physician; orthopaedic surgeons, their offices, and fracture clinics identified through our services; imaging facilities for scheduling and report routing; our Orthopaedic Liaison; and service providers who store or transmit data on our behalf (Section 6). We disclose only what is necessary for the purpose at hand, and we will tell you before sharing your file with any category of recipient not listed here.
5 Your Ontario Health Number
We collect your health number only to verify your identity and link records across your providers. We do not use it for billing and do not submit claims to OHIP. You may decline to provide it, though some record transfers may be slower without it.
6 Where Your Information Is Stored, Including Outside Canada
Your health records and PHI are stored and exchanged through TitanFile, which is hosted in Canada. Some supporting tools are hosted in the United States: Docusign (electronic signatures) and Squarespace (our website and booking form). Our booking form does not collect PHI; it collects only contact information, your selected service, and a general body region. Information stored or transmitted through a service hosted in another country may be accessed by that country’s courts, law enforcement, or national security authorities under its laws. We use Doxy.me for client video calls; this is a secure platform used for the call itself and does not store your PHI on our behalf beyond the call.
7 Your Rights
- Withdrawal: you may withdraw your consent to our collection, use, or disclosure of your information at any time, in whole or in part, by written notice to us. Withdrawal does not affect handling that occurred before withdrawal, and if you withdraw consent needed for our services, we may be unable to continue them.
- Access and correction: you may request access to the personal information we hold about you and request corrections. We respond within thirty (30) days.
- Complaints: our Privacy Officer is Brendan Gillmore, reachable at brendan@orthopaedicaccess.ca. You may also complain to the Office of the Privacy Commissioner of Canada.
8 Retention and Destruction
We retain your information only as long as necessary for the purposes described in this Policy and to meet our legal obligations, and then securely destroy or anonymize it.
9 Safeguards
We use physical, technical, and organizational safeguards proportionate to the sensitivity of the information we hold, including restricting access to personal information to personnel who need it to perform their role and using platforms selected for their security practices for the storage, transmission, and signing of documents containing PHI.
10 Changes to This Policy
We may update this Policy from time to time. The version in effect at the time of your engagement with us governs how we handle your information during that engagement, and we will notify you of any material change that affects how your information is handled.