The website https://platform.mindbeacon.io is owned by MindBeacon Software Inc., and the MindBeacon application is licensed to and operated by MindBeacon Health Inc. (MindBeacon Health Inc. and MindBeacon Software Inc. collectively referred to as “MindBeacon”).
You must be at least sixteen (16) years old to use the MindBeacon Platform or any MindBeacon service. By using the MindBeacon Platform, you represent and warrant to MindBeacon that you are at least sixteen (16) years old. Parental consent may be required in some provinces if you are under the age of eighteen (18).
What is “Personal Information”?
For purposes of this Policy, the term “Personal Information” means information about an identifiable individual that is provided through the MindBeacon Platform such as contact information, name, address, phone number or email address, gender, date of birth, and personal health information, including information relating to physical or mental health, health history, medical records, prescriptions, payment for health care provided, and health card number.
Any data that has been collected in which personal identifiers have been removed, such that the information could not reasonably be used to identify the individual, is not considered Personal Information.
MindBeacon will collect, use and disclose your Personal Information without your consent only in limited circumstances and as permitted or required by law or regulatory requirement. For example, Personal Information may be used or disclosed without consent for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual. In certain limited circumstances, we may be called upon to release your Personal Information in response to a court order, subpoena, search warrant, law or regulation. We will cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information that they may receive, and that disclosure is necessary to comply with applicable law.
In certain cases, you may choose not to provide us with some or all of your Personal Information. However, should you choose not to provide necessary Personal Information to us, that decision may impact your ability to interact with us or for us to provide you with certain services. For example, we require that you provide us with current emergency contact information, and we cannot provide any services without emergency contact information.
You may withdraw your consent at any time by notice to us in writing. Please contact our Privacy Officer listed below to find out how.
What Personal Information does MindBeacon Collect?
We may collect Personal Information about you for the purpose of administration and providing services through the MindBeacon Platform, including, without limitation, information such as:
- Your name;
- Your contact information, emergency contact information, date of birth;
- Demographic information (gender, ethnicity, place of birth, education, health, family and lifestyle information, etc.);
- The services you will and have received through the MindBeacon Platform, dates, etc.;
- Responses to your screening and/or online assessment;
- Your assessment report;
- Secure messaging or email communications between you and a regulated healthcare professional involved in your care;
- Any information that you send to us through email or the MindBeacon Platform;
- Notes and records of assessment and information relating to your assessment for suitability for services through the MindBeacon Platform, and notes and records relating to your progress through the MindBeacon Therapist Guided Program and/or MindBeacon’s Live Therapy;
- Outcome data from self-report measures; and
- Your responses to requests for information and/or treatment questions at follow-up intervals three (3) and six (6) months after you have completed the course.
How is this Personal Information Used?
We will use your Personal Information for the purposes for which it was collected as outlined above, and as required or permitted by applicable law. Specifically, we will use your Personal Information to:
- Deliver and administer services to you through the MindBeacon Platform, including assessments, the Therapist Guided Program, and Live Therapy;
- Communicate with you, including setting up an assessment phone call, enabling communications with your therapist, to provide you with information about possible services and treatments, and to provide other reminders, prompts and feedback about your progress through the Therapist Guided Program and/or Live Therapy; and/or
- Provide you with ongoing service and support and to help us better understand your needs.
Your Personal Information may be de-identified and/or aggregated, and thereafter used for the purposes of improving and developing new assessment processes or other related product or service offerings, research, including academic and non-academic research, AI and other types of analytics, quality assurance, performance reporting, customer reports, promotion and advertisement, and business development.
What Personal Information does MindBeacon Share?
We may share your Personal Information with third parties as follows:
MindBeacon Therapists: Your Personal Information may be shared with another MindBeacon therapist and/or any one or more clinical supervisors or clinical consultant of any MindBeacon therapist, if sharing such information is necessary to provide you with services through the MindBeacon Platform.
Consulting Professionals: Your Personal Information may be shared by your MindBeacon therapist with a MindBeacon consulting regulated healthcare professional for the purpose of quality assurance and otherwise in accordance with applicable laws.
Insurance Providers: In circumstances where you are completing therapy as part of a return to work plan established by an insurance company, we may share your Personal Information with those involved in your care, including the insurance company. This disclosure may include information regarding your assessment results, progress and discharge from the MindBeacon Therapist Guided Program or Live Therapy.
Payors: If your use of services through the MindBeacon Platform is paid for by your employer or a third-party insurance provider, we may disclose certain information in order to assist us with arranging payment for your enrollment. This information includes your name and insurance plan information. We will not disclose to your employer or a third-party insurance provider, any correspondence between you and your MindBeacon therapist, any of your assessment information, progress or discharge reports, or any summaries of such information.
Hospitals: In circumstances in which you have been referred to us through a hospital or other health care provider that remains involved in your care on an ongoing basis, or if you are referred to such provider after concluding the MindBeacon Therapist Guided Program or Live Therapy, we may share your Personal Information with such provider. This disclosure may include information regarding your assessment results, progress and discharge from the MindBeacon Therapist Guided Program or Live Therapy.
Employees and Agents: We may provide your Personal Information to our employees and those of our affiliates and our respective agents and those third parties that require such information in order to help us provide services to our clients and administer our business.
Service Providers: We have relationships with agents and third-party service providers that help us provide services to you including, but not limited to, administering our business, and designing, maintaining and improving the MindBeacon Platform and our systems and computer security.
We use payment processing service providers that are hosted and operated in the United States, and laws in the United States and other jurisdictions may differ from the laws where you reside.
Legal Disclosure: We and our service providers may disclose your Personal Information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.
The Personal Information you provide to us through the MindBeacon Platform will not be otherwise disclosed to a third party without your consent, except as required or permitted by applicable law.
Please note that we have the following legal obligations to release confidential information:
- Harm to self: If a regulated healthcare professional involved in your care has reason to believe that you are in danger of physically harming yourself in ways that may be life-threatening, s/he will have to make a referral to a hospital and/or contact a family member, close other, or another person such as a police officer who may be able to help protect you. There may be other emergency health care related circumstances where disclosure is reasonably necessary for the protection of your health, in which case your regulated healthcare professional will disclose Personal Information to other healthcare professionals as long as you have not expressly prohibited him/her from doing so.
- Harm to others: If a regulated healthcare professional involved in your care has reason to believe that you are seriously threatening physical violence against another person, or if you have a history of physically violent behaviour, and if s/he believes that you are an actual threat to the safety of another person, s/he is required to take some action (such as contacting the police, notifying the other person, seeking hospitalization, or some combination of these actions) to ensure that the other person is protected.
- If a regulated healthcare professional involved in your care has reason to believe that a child under the age of sixteen (16) is being abused or neglected, s/he is legally obligated to report this situation to the appropriate child protection authority (e.g., the Children’s Aid Society).
- If a regulated healthcare professional involved in your care suspects or is informed of unlawful conduct that resulted in harm or risk of harm to a resident of a Long Term Care Facility or Retirement Home, or that a resident is being harmed or is at risk of being harmed in any way (e.g., sexual or physical abuse, neglect, misappropriation of resident’s funds), s/he may be required to contact the applicable Ministry or Regulatory Authority and report all relevant information.
4. Sexual Abuse: If you have been sexually abused by a member of a regulated health profession, this information must be reported to the appropriate regulatory body if you share the information with a regulated healthcare professional involved in your care.
- 5. Court Order: A regulated healthcare professional involved in your care and your clinical record can be subpoenaed by a court order. Your regulated healthcare professional can be required to testify and give information obtained during sessions. Without a court order, this information would never be provided voluntarily without your direct request or consent.
- 6. Quality Control:
- On occasion, a regulated healthcare professional involved in your care may be randomly selected to participate in a Peer Assisted Review by his/her regulatory college (for example, the College of Psychologists of Ontario). As part of this process, your file may be potentially reviewed by a member of the regulatory college. Regulatory colleges have confidentiality policies in place to protect your information.
- A regulated healthcare professional involved in your care may be supervised in his/her clinical work by a more senior professional. You will be informed of any such supervisory arrangement. That supervisor may access your clinical file for the purposes of quality control.
We may collect and use information about how you interact with the MindBeacon Platform, including Internet Protocol addresses, Internet domain names and operating system used to access the MindBeacon Platform, the time spent on each page and the time and date of each visit. This information is used for, among other things, auditing and tracking purposes, to improve the content of the MindBeacon Platform, and to create a better experience for users of the MindBeacon Platform.
Sale of Business
We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of MindBeacon or as part of a corporate reorganization or other change in corporate control.
Links and Referrals to Third Parties
Our Security Measures
We are committed to protecting the security of your Personal Information. We have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to your Personal Information. We apply security safeguards appropriate to the sensitivity of the Personal Information, such as retaining information in secure facilities and making Personal Information accessible only to authorized employees on a need-to-know basis. We have clearly defined internal policies and practices.
Although we will make commercially reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems. This risk is heightened if you are using unsecured/public Wi-Fi.
We retain your Personal Information only for as long as is necessary for the purpose for which it was collected in accordance with the laws, ethics and standards applicable to members of the College of Psychologists of Ontario or such other applicable regulatory body in jurisdictions in which we operate. When your Personal Information is no longer required or required to be maintained, it will be destroyed or de-identified in accordance with applicable laws.
If you create an account for the MindBeacon Therapist Guided Program but do not submit your answers to the screening or the online assessment questionnaire within seven (7) days from the date upon which you create your account, then we will automatically delete your answers. The information you provide to create a MindBeacon account will be deleted if you do not use the MindBeacon Platform within thirty (30) days of creating an account.
Your record will be maintained, as required, in accordance with the laws and standards set out by the College of Psychologists of Ontario or any other applicable regulatory body governing the provision of services as a clinician.
Except in the limited circumstances established by law, individuals may obtain access to their Personal Information. Individuals may also request us to correct their Personal Information where they believe it to be out of date or otherwise inaccurate. Requests for access or correction must be made in writing and should be addressed to our Privacy Officer (please see the contact details set forth below). We may decide to share your Personal Information with you through a healthcare provider, where appropriate.
We will assist you if you inform us that you need assistance in preparing a request concerning Personal Information. Administrative charges may apply.
You can update your account through the MindBeacon website, or by contacting our Privacy Officer.
MindBeacon Health Inc.
175 Bloor St East, Suite 801 North Tower
Toronto, ON, M4W 3R8
If you have any concerns about MindBeacon’s privacy practices or for more information on your privacy rights, you can contact:
Ontario - Office of the Information and Privacy Commissioner 1-800-387-0073
Alberta - Office of the Information and Privacy Commissioner 1-888-878-4044
British Columbia - Office of the Information and Privacy Commissioner 250-387-5629
Manitoba - Ombudsman 1-800-665-0531
New Brunswick - Office of the Integrity Commissioner 1-877-755-2811
Newfoundland and Labrador - Office of the Information and Privacy Commissioner 1-877-729-6309
Northwest Territories - Information and Privacy Commissioner 1-888-270-3318
Nova Scotia - Office of the Information and Privacy Commissioner 1-866-243-1564
Nunavut - Information and Privacy Commissioner 1-888-521-7088
Prince Edward Island - Office of the Information and Privacy Commissioner 902-368-4099
Quebec - Commission d’accès à l’information 418-528-7741
Saskatchewan - Office of the Information and Privacy Commissioner 1-877-748-2298
Yukon - Information and Privacy Commissioner 1-800-661-0408
Federal - Office of the Privacy Commissioner 1-800-282-1376