01 Jul 2021
Alberta Health Services (“AHS”) has retained the services of Innowell to collect, use and disclose patient health information between patient, patient’s health services providers (including AHS providers) and the patient’s support persons authorized to access the Innowell platform by the patient, in order to produce better quality health outcomes in relation to addictions and mental health. AHS’ service providers, including Innowell, must comply with AHS’ legislated privacy obligations in addition to their own.
AHS is required by law to maintain the confidentiality and privacy of individuals’ personal and health information in compliance with the Freedom of Information and Protection of Privacy Act (“FOIP”) and the Health Information Act (“HIA”). AHS will not collect, use, or disclose personal or health information in any manner that is not in accordance with FOIP or HIA. AHS maintains administrative, technical and physical safeguards, including monitoring and auditing access to and activities engaged in on the Innowell platform, to protect against any reasonably anticipated threat or hazard to the security or integrity of identifying information or theft, loss, or unauthorized access, use, or disclosure of identifying information stored in the Innowell platform.
Identifying personal information is collected under the authority of section 33(c) of FOIP. Identifying information is collected directly from you FOIP and from your personal and AHS health services providers, support persons or others who are authorized by you to access your profile to add to, or access, use or disclose identifying information from your profile, in accordance with section 34 of FOIP. Identifying personal information in the Innowell platform will only be used and disclosed by AHS as is necessary for the purposes for which it was collected, and otherwise in accordance with sections 39 and 40 of FOIP.
Identifying health information is collected from you, your health services providers, and any support persons or others you authorize to provide identifying information to your profile, pursuant to sections 20(b), 21 and 22 of HIA. Identifying health information in your profile will only be used or disclosed by AHS as is essential for the purposes for which sections 27 and 35 of HIA permit identifying health information to be used or disclosed by AHS. Collection, use and disclosure of your health information by AHS will also comply with the requirements in sections 57 and 58 of HIA, and protected in accordance with section 60 of HIA. Health information collected by AHS in the Innowell platform may be disclosed to researchers to conduct research that is authorized by an approved research ethics board, in accordance with section 27(1)(d) and Division 3 of Part 5 of HIA.
If you have any questions about the collection, use or disclosure of your identifying information by AHS via the Innowell platform, you may contact the Manager, Addiction and Mental Health Strategic Clinical Network at 10301 Southport Lane, SW. Calgary, AB T2W 1S7, +1(780)394-4635 or eMH@albertahealthservices.ca
At Innowell, we care about your data and we want you to be able to know and understand how we collect, use and disclose your personal information when you use and interact with our Platform.
This Privacy Policy applies to any users who use or access our Platform in or from Canada as part of the Alberta Health Services
We’ve provided the essential information that you need to know in each of the items below. If you would like to dive into the issues that matter to you in more detail, click the heading to jump around this policy.
The policy sets out how we collect, use and disclose your personal information.
We own and operate the Innowell Platform – which is comprised of our online platform and our website. Our digital platform helps you to manage mental health and general wellbeing.
We collect your personal information when you share it with us through the platform or our website. We may also collect your personal information from our partners, your support persons, and third parties that integrate into the platform (like FitBit).
We collect your name and email address as well as health and wellbeing information that you provide to us. We also collect technical and behavioural information from you when you use the platform.
We mainly use your information to provide the platform and our associated services to you. We may also use your information to develop and improve the platform and to provide technical support.
We may disclose your information to our partners or where we are required by law. We will not share information with any other third parties without your express consent.
So that we can continue to provide the best service to you, we ask that you keep your personal information updated through the functionality provided on the platform.
We implement strict technical and procedural controls to protect your data from unauthorised access or disclosure.
You can manage your personal information directly through the functionality provided on the platform or by contacting us at privacy@innowell.org.
We delete your data when it is no longer required for the purpose it was collected.
We will notify you and the Alberta Information and Privacy Commissioner of any unauthorised use or disclosure of data (as required by law) and will take steps to remedy any data breach.
You can contact privacy@innowell.org if you have any questions, complaints or feedback about your personal information or how we manage personal information.
This privacy policy sets out the way in which we collect and handle personal information as part of delivering Innowell’s services to Alberta Health Services (“AHS”). In addition to this Privacy Policy, and the agreements governing our provision of Innowell services to AHS, we also comply with other privacy legislation where it applies to us, including:
This Privacy Policy applies to our customers, guests, visitors, subscribers to any of our services and our Platform, and any individual who interacts with us.
By using or purchasing our services, accessing our website as a visitor or providing any personal information to us, you consent to us collecting, using, holding and sharing your personal information (including your health and sensitive information) in accordance with this Privacy Policy.
There is no obligation for you to provide us with any of your personal information. However, if you request services from us, we may ask you to provide us with certain personal information to allow us to provide you with our services. If you choose not to provide us with your personal information, we may not be able to provide you with our services.
We may amend or update this policy from time to time. If this happens, we will publish any updates on our website and (if the changes are significant) notify you by email or by posting a notice of the changes in the platform. If you do not agree with the changes, you must cease accessing the platform. If you continue to access or use the platform after the changes come into effect, we will assume that you have agreed to them.
Innowell delivers digital health solutions to promote mental health and wellness and help people receive the right care at the right time. Innowell is the owner of the Innowell platform and services provided through the platform. More information about Innowell can be found here. References in this policy to ‘we,’ ‘our’ or ‘us’ means Innowell.
The Innowell platform is a customisable digital platform that is designed to assist in assessing, monitoring and managing mental health issues and the maintenance of general wellbeing. It does this by collecting and processing your personal information (including sensitive and health information).
As a Canadian user, you will be using and accessing a customised version of the platform that we have developed and implemented with AHS. Our Canadian platform is only available to users who reside in Alberta.
We hope that this privacy policy is straightforward and clear; however, if you have any questions about it, please e-mail us at privacy@innowell.org.
Information shared by you. The main way we collect personal information about you is when you provide it to us. For example, when you create an account in the platform, you will be asked to complete an assessment that includes questions about you generally, and about your health and wellbeing in particular. We may also collect personal information from you when you communicate with us in person, by phone or through correspondence, but will not solicit health information from you.
Information shared by AHS and support persons. We may collect personal and health information about you from AHS, health services providers or your support persons when they use or interact with you through the platform.
Information shared by third parties. We may, from time to time and only with your express prior consent, integrate third party services into the platform and your account. For example, we may integrate with FitBit to allow you to share information collected by your FitBit device and app with the platform. This information will be incorporated in to the dashboard and will be accessible to you.
We may also collect information from you about someone else. You agree that prior to providing any personal or health information about another person to us that you are authorized by that other person to provide their personal information and/or health and sensitive information to AHS and Innowell, or otherwise authorized to disclose that information to the Platform in accordance with applicable privacy laws.
The Innowell platform also collects other categories of data in order to provide services to you. These include:
AHS will also collect some personal information from you (including your name and email address) and provide this information to us so that we can send an email to you that contains a link that enables you to create an account in the platform.
The platform is designed to provide services to you that are suitable for your individual needs. Because of this, the exact nature of the personal information that the platform collects and handles will differ from person to person.
The main purpose for which we use your personal information (including health information) is to provide you with the platform services.
Your personal information and the information we create about you through processing is made available to you through the platform to support your mental health.
We also use personal information for several other related purposes, including:
In addition, from time to time, we may contact you to request feedback on our platform – this will help us improve the platform and provide better services to you. Answering feedback questions is voluntary and does not affect your access to the platform.
We may also disclose your personal information:
Innowell is an Australian company and we may send your information to, or store your information in, Australia from time to time as necessary to provide you with the platform and our support services.
We may also send information to third parties, such as related parties or businesses that provide services to us. Our use and disclosure of your information will be in accordance with the requirements of this Privacy Policy and our agreements with AHS. These third parties may be located or use infrastructure located overseas, including in the United States of America, although this list may change from time to time. Disclosure is made to the extent that it is necessary to perform our functions or activities. If you would like any information about our policies regarding the processing of your personal information outside of Canada, please contact our Innowell Privacy Officer (see contact information below).
AHS may also wish to understand the outcomes for its users of using the Platform to ensure that the benefits and services that it offers to its users are as useful and effective as possible, and AHS may access and use the information in the platform for those purposes. AHS may also direct Innowell to disclose your personal information for research purposes in accordance with HIA requirements. If Innowell provides your personal information and/or health information to AHS, AHS will handle it in accordance with its applicable laws and policies. To be clear, we will only share your personal information or health information with AHS.
Some of your personal information that is collected by the platform is entered directly into the platform by you and is always accessible to you when you log in to the platform. If your contact details change, we ask that you update this information promptly.
If you wish to correct or amend any of the personal and health information entered into the platform by you, and are unable to do so, please read the information we have provided about access and correction below. If you wish to correct personal and/or health information entered into the platform by your health services provider, AHS or a support person, please contact AHS at the contact information provided above.
We take implemented physical, organizational and technological safeguards in an effort to protect your personal information from misuse, interference and loss as well as from unauthorised access, modification and disclosure. As part of those safeguards, we:
Although we take appropriate measures to safeguard the security of your personal information, we cannot guarantee its security. To assist in preventing unauthorised use or disclosure of your personal information, you must keep confidential any sign-in information and passwords related to the platform. Further, you can protect the data in the platform on your smart device (phone, tablet or computer) by use of a PIN code to restrict unauthorised access to your smart device. Whenever you have finished using the platform, you should log out. You should not leave your device unattended while you access the platform.
Note however, that your use of an Internet Service Provider (ISP) will be subject to the separately-provided terms of use of such services. In particular, note that any data processing and/or transmission of data by the ISP are outside the scope of this policy and not the responsibility of Innowell.
You can access, view, manage and update your personal and health information details, research data sharing consent status, health domains and care options at any time. Simply sign in to the platform to view and update your information via the dashboard or settings menu.
If you think that your personal or health information is inaccurate in the platform and you are unable to update your details through the platform, please get in touch by emailing privacy@innowell.org and we will assist you to correct information entered into the platform by you, and notify AHS and/or the health services provider who provided the inaccurate information. We will respond to any requests regarding the correction of your personal information as soon as practicable. In order to protect your personal information, we may require identification from you before changing or releasing any requested information.
Innowell will only keep your personal information and health information for as long as is required under Innowell’s agreements with AHS as necessary for the purposes of the AHS project or as required by law. When your personal information is no longer needed for the purpose for which it was collected, we will return it to AHS or permanently destroy it or render it non-identifying, as directed by AHS. Information provided to the platform will be stored in client files which will be retained for a period that is necessary and required by law.
If you have any queries or complaints about our Privacy Policy or Innowell’s privacy practices, please contact AHS using the contact information above and us at:
Innowell Privacy Officer
Call: +61 2 5500 9355
Email: privacy@innowell.org
Write:
Innowell Pty Ltd
Suite 301, 309 George St, Sydney NSW 2000, Australia
We will quickly acknowledge access or correction requests, or complaints, and use our best endeavours to respond fully within 30 days of receipt of your request.
If you think that we have failed to resolve a complaint satisfactorily or you still have a concern, you may contact AHS or the Information and Privacy Commissioner of Alberta.
Last updated: July 2021