skip to main content

Privacy Policy

Effective Date: 05/26/2017
Last Amended: 08/14/2024

Contents of the Privacy Policy

  1. WHAT SERVICES DOES ONTARIOMD PROVIDE? 
  2. WHAT PERSONAL INFORMATION DOES ONTARIOMD COLLECT? 
  3. HOW IS PERSONAL INFORMATION USED AND DISCLOSED? 
  4. SECURITY 
  5. WEBSITE 
  6. ONTARIOMD PORTAL 
  7. AI MARKETPLACE 
  8. CHANGES TO THIS PRIVACY POLICY 
  9. ACCESSING YOUR PERSONAL INFORMATION 
  10. SAFEGUARDS 
  11. OPENNESS 
  12. HOW TO CONTACT US OR MAKE A COMPLAINT 

1. WHAT SERVICES DOES ONTARIOMD PROVIDE? 

This Privacy Policy applies to personal information collected and used by OntarioMD.  The purpose of this Privacy Policy is to outline the type of personal information we collect, how we use that information in compliance with applicable laws and ethical business practices, and the safeguards we have in place to protect that information. OntarioMD's privacy policies and guidelines are guided by Ontario's Personal Health Information Protection Act ("PHIPA") and the federal Personal Information Protection and Electronic Documents Act ("PIPEDA").

OntarioMD supports clinicians in the selection, adoption, sustained and enhanced use of certified Electronic Medical Records ("EMRs") and related technologies.  Protecting personal information is a key value at OntarioMD.

OntarioMD has also developed products and services that allow primary care practitioners, hospitals, medical clinics and other health care organizations to select and optimize their use of digital delivery mechanisms and EMRs.  OntarioMD has developed solutions that enable and promote the exchange of patient health information between and among clinicians and health facilities.  We have developed and delivered electronic health initiatives that align and respond to provincial government priorities and many programs are funded by the Ontario Ministry of Health ("MOH").  Due to the nature of our work, OntarioMD will have access to personal information.

The OntarioMD Privacy and Security Modules are online education tools and collect users' name, licence number (e.g. CPSO number) and successful completion status. OntarioMD also collaborates with other stakeholders to research, evaluate and deliver other services. 

With respect to health information custodians ("HICs"), OntarioMD acts as a service provider; we support health care providers in the use and adoption of technology and digital health delivery tools; this may include either OntarioMD-led, or collaborative research and publications related to the progress and effectiveness of use and adoption of technology, artificial intelligence-enabled and digital health delivery tools. Although from time to time, our representatives may access or view personal health information ("PHI") in order to perform our services, OntarioMD itself, does not collect or store PHI in the course of providing these services. With respect to its provision of Health Report Manager (HRM®) (which enables the disclosure of personal health information to two or more HICs), OntarioMD acts as a "health information network provider" within the meaning of the regulations under PHIPA. 

2.    WHAT PERSONAL INFORMATION DOES ONTARIOMD COLLECT? 

Personal information includes information about an identifiable individual. Personal information does not include name, business address or business contact information, such as business title, or phone number, that are provided for business purposes. Types of personal information that we collect include personal address, and, in some cases, CPSO or other applicable licence numbers and practice information. OntarioMD generally collects personal information that is voluntarily provided, but we may collect information from third parties where you have registered for a program that requires this data, or otherwise where you consent, or as permitted or required by law. Third parties may include certified EMR vendors who are required as part of OntarioMD's EMR Certification Program, to provide monthly updates on EMR users, to enable health system planning and delivery and inform aggregate EMR user penetration and saturation in the province. Unless otherwise stated, certified EMR vendors will be deemed as having client consent to disclose clinician practice EMR information with OntarioMD to deliver on provincial digital health priorities. We may also collect information through our website (OntarioMD.ca) and our microsites such as, but not limited to, OMDEducates.com, OntarioMD.Live, OntarioMD.News, OntarioMD.VC, OntarioMD.Report, OMDai.ca, OMDMarketplace.com, OntarioMD.blog, and OntarioMD.Marketing. These websites may collect your email address where you provide it. OntarioMD does not collect or store personal health information of patients for its own purposes.

3.    HOW IS PERSONAL INFORMATION USED AND DISCLOSED?

OntarioMD collects, uses and discloses personal information in order to deliver programs, products and services that work with, and on behalf of, HICs to leverage information technology ("IT") and to facilitate the adoption of new IT  {including artificial intelligence tools ("AI" tools). OntarioMD may deliver these products and services either on its own or in conjunction with third parties. OntarioMD has also developed tools and services that facilitate the delivery of health information between stakeholders. As discussed above, OntarioMD does not require access to personal health information in order to fulfill its mandate other than converting it to secure file formats for transmission to HICs in the provision of HRM. 

OntarioMD uses personal information for the following purposes: 

  • Providing information about OntarioMD products and services, and about developments in health IT policy of interest to primary care practitioners.

  • Registering primary care practitioners and other health care clinicians or their administrators so that they can use the OntarioMD Portal (OntarioMD.ca) and other IT tools. We exchange information with the Ontario Medical Association (OMA) member services in order to have up-to-date records, including registration information for service and Portal access and provide services to OMA members.

  • Developing education programs , information services and product platforms about developments in health IT, AI and digital health policy of interest to primary care practitioners. This includes marketing services and products tailored to the needs and interests of OntarioMD stakeholders.

  • Engaging stakeholders including physicians and other clinicians, in order to assess their views on OntarioMD services and benefits, and on the technology adoption. This information is then de-identified for use in economic and policy analysis, research and future planning.

  • OntarioMD-led, or collaborative research and publications related to the progress and effectiveness of use and adoption of technology and digital health delivery tools.

  • Delivering personal information on behalf of health information custodians with respect to HRM or related services.

  • Supporting clinicians with any technical issues related to OntarioMD-supported products (e.g., HRM).

  • Updating stakeholders about the direction of OntarioMD to ensure they are well informed.

  • Distributing financial reports to the MOH or Ontario Health for physicians receiving EMR funding if a funding program is in place.

Except as expressly set out in this Privacy Policy, or otherwise as required by law, or agreed by you, OntarioMD will not disclose personal information to any third party without prior consent. In order to fulfill its role and reporting obligations to its funding partner and carry out its role as a certifying body for EMRs in Ontario, OntarioMD must disclose some information it collects with stakeholders.

Stakeholders:  OntarioMD is required to provide reporting information on its activities to its funding agent, Ontario Health.  In almost all other situations, OntarioMD only provides anonymized or aggregated information to Ontario Health and other stakeholders.

In order for OntarioMD and the OMA to administer their respective member programs, they may disclose practice information for purposes of registering in or accessing such programs. Similarly, in order to register and onboard clinicians for products such as eConsult, provincial EHR assets and viewers, ONE® ID (or other products as they are introduced), practice information including CPSO numbers and Billing Numbers may be disclosed to provincial agencies such as Ontario Health-Digital Services) for purposes of enrollment.

Where you consent, OntarioMD will disclose the status of your successful completion of the OntarioMD Privacy and Security Training Module (including required identification numbers) with provincial digital health partners in order to facilitate your access to their assets. We may also disclose such status with CME accreditation bodies for the purpose of granting CME credits.

Service Providers: From time to time, we may transfer personal information to third-party agents and service providers who provide services on our behalf. For example, we may use a service provider to help us conduct a study or verify information, to authorize and process payments, provide call centre support, host our website and operate some of its features. These third parties are required to safeguard the personal information transferred to them and not to use or disclose personal information transferred to them for any purpose other than the provision of services to OntarioMD. Examples of our service and infrastructure providers include Ontario Health and its data centres and networks. Some service providers may process data on servers outside of Canada. In the event our service provider is located in a foreign jurisdiction, they are bound by the laws of the jurisdiction in which they are located and may disclose personal information in accordance with those laws.

Sale of Business: OntarioMD may transfer any information we have about individuals as an asset in connection with a merger or sale involving all or part of OntarioMD or the OMA or as part of a corporate reorganization or other change in corporate control. OntarioMD may also transfer personal information to the professional advisors of the successor entity under an obligation of confidentiality for due diligence purposes and ultimately to the successor entity upon completion of the transfer of ownership.

4.   SECURITY

Your personal information is treated as private and confidential information by OntarioMD.  We strive to ensure that your personal information, regardless of format, is protected and kept secure by providing security safeguards that are appropriate to the sensitivity of the information. OntarioMD only keeps personal information for as long as it is required for legal or business purposes. Although we make every reasonable effort to protect your personal information from unauthorized access, release, use, loss and theft, disclosure, alteration by third parties, copying or modification by physical and logical security procedures, confidentiality policies, and authorization requirements, you should be aware there is always some risk involved in transmitting information over the Internet. As a result, OntarioMD does not represent, warrant or guarantee that personal information will be protected against loss, misuse or alteration and does not accept any liability for personal information submitted by you, nor for your or third parties' use or misuse of personal information.

5.    WEBSITE

OntarioMD maintains a website and a Portal that provides information to registered users.   

All Website Users:

Individuals may visit the public portion of our website (OntarioMD.ca), and associated microsites, without providing any personal information. However, we may automatically collect some information regarding your use on our website and the pages you visit on the website. Our servers may automatically collect information about the type of browser you use and the name of your Internet Service Provider. In addition, we may collect "cookie" information from your browser to identify your computer and provide us with a record of your visits to our website (collectively, the foregoing is referred to as "Usage Data"). The technology used to gather "cookie" information is provided by the Internet browser you use and is stored on your computer. You may set your browser to disable or refuse to accept cookies, although doing so may affect your viewing of certain portions of the website. The website collects Internet Protocol (IP) addresses for system administration, to report aggregate information and to audit the use of the website. Our website contains links to other websites which may collect your personal information. OntarioMD assumes no responsibility for the privacy policies of these websites. You should read the privacy policies of these websites and make an informed decision whether or not to provide your personal information to the websites' operators.

6.    ONTARIOMD PORTAL

OntarioMD collects personally identifiable information when you register for an OntarioMD Portal account. When you register for the Portal, we require your name, email address, and other contact information. Once you have registered with the Portal and sign in, you are not anonymous to us. OntarioMD automatically receives and records information on our server logs from your browser which could include when you login, duration of Portal visits, IP addresses, portlets used and the pages requested. OntarioMD uses this information for the following purposes:

  • Authentication and provisioning access to certain Portal resources
  • Audit logging for security purposes
  • Monitoring and improving site performance issues

Except as provided in this Privacy Policy, or with your agreement, OntarioMD will not disclose the information to third parties. The handling of all personal information collected from you by OntarioMD is governed by applicable law, including Ontario's Personal Health Information and Protection Act (PHIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA) as applicable.

7.    AI MARKETPLACE

OntarioMD collects personally identifiable information from interested clinicians and AI scribe service providers to participate in or make use of the AI Marketplace. During registration or expressions of interests, we require your name, email address, and other contact information, as applicable. Once you have registered with the AI Marketplace , you are not anonymous to us. OntarioMD automatically receives and records information on our server logs from your browser which could include when you login, duration of AI Marketplace visits, IP addresses, portlets used, and the pages requested. OntarioMD uses this information for the following purposes:

  • Operating the AI Marketplace and reviewing, editing and removing vendors and content submissions;
  • Authentication and provisioning access to certain AI Marketplace resources;
  • Disclosing the information and service requests you provide to participating AI scribe service providers or other technology vendors, as applicable, to connect you with services that may be of interest to you;
  • Audit logging for security purposes;
  • Monitoring and improving site performance issues; and
  • Communicating with you and provide you with updated information.

Except as provided in this Privacy Policy, other OntarioMD Terms of Use, or otherwise with your agreement , OntarioMD will not disclose the information to third parties. The handling of all personal information collected from you by OntarioMD is governed by applicable law, including Ontario's Personal Health Information and Protection Act (PHIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA) as applicable.

8.    CHANGES TO THIS PRIVACY POLICY

OntarioMD reserves the right to modify or amend this Privacy Policy from time to time and we encourage you to refer to this policy regularly. The date of the most recent version is posted at the top of the Privacy Policy. If any material modifications are made to how we intend to use or disclose personal information, we will contact you accordingly to notify you, or where necessary, obtain your consent.

9.    ACCESSING YOUR PERSONAL INFORMATION 

You have the right to verify and amend your personal information collected by us. You are also free to withdraw your consent to such collection, use and disclosure of your personal information. On written request, and in a reasonable timeframe, you have the right to access your personal information, identify the uses to which that information is put, and identify any third party to whom it may have been disclosed, and for what purpose. These rights are not absolute; however, if we deny your request for access, we will provide reasons for doing so.

If an individual identifies incorrect personal information in OntarioMD's possession, OntarioMD will correct or delete that information in accordance with the individual's direction.

10.  SAFEGUARDS

OntarioMD maintains reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. OntarioMD maintains strict confidentiality of all personal information collected and will only disclose such information to authorized persons who require such information for the purposes set out above. OntarioMD will keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law.

11.  OPENNESS

OntarioMD makes its policies for protecting personal information readily available to those individuals from whom personal information has been collected. Reasonable access to such information can be provided where it does not interfere with the legal rights or requirements of OntarioMD or other third parties. The following policies are readily available on the OntarioMD website:

  • OntarioMD Privacy Complaints and Inquiry Policy and Procedures
  • OntarioMD Privacy Breach Management Policy
  • FAQ - Privacy for Physicians and Staff

12.  HOW TO CONTACT US OR MAKE A COMPLAINT

If you have any questions or concerns about how OntarioMD manages your personal information and protects your privacy, please contact our General Counsel and Chief Privacy Officer at:

  • Address: 150 Bloor Street West, Suite 900, Toronto, ON M5S 3C1
  • Phone:1-866-744-8668
  • Email: support@ontariomd.com

You have the right to complain to the Information and Privacy Commissioner of Ontario or the Office of the Privacy Commissioner of Canada if you are concerned that OntarioMD has violated privacy obligations regarding personal health information or personal information.


Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400
Toronto, ON
M4W 1A8

Telephone: 416-326-3333 or 1-800-387-0073

416-325-9195

Web: www.ipc.on.ca

Office of the Privacy Commissioner of Canada

30 Victoria Street
Gatineau, Quebec
K1A 1H3

Telephone: 819-994-5444 1-800-282-1376

Fax: 819-994-5424

Web: www.priv.gc.ca/