Medigroup Health Services ("Medigroup," "we," "us," or "our") is committed to protecting the personal information of patients and users of the Medigroup Virtual Care Platform. This Privacy Policy describes how we collect, use, and share personal information in connection with your use of the Platform and any website or service that links to this policy (the "Services").
Information you provide in the course of using the Platform may also constitute "personal health information" ("PHI") as defined under the Personal Health Information Act (PHIA) of Manitoba, or equivalent provincial legislation where applicable. Where this Privacy Policy conflicts with PHIA or other applicable health privacy legislation with respect to PHI, the legislation prevails.
In connection with PHI, the physicians providing care through the Platform are the custodians or "trustees" of that information under applicable health privacy legislation. Medigroup processes personal health information on behalf of and under the direction of those physicians in order to operate the Platform and support the delivery of care.
I. Information We Collect
We collect information in the following ways:
Information you provide directly
When you register for and use the Services, we may collect:
- Contact information, including your name, email address, phone number, and mailing address
- Account credentials
- Payment information, where required for non-insured services
- For healthcare providers: professional information such as your specialty, license status, and employment details
- Personal health information, including medical history, current symptoms, diagnoses, insurance details, and other information you submit in connection with your care
- Any other information you choose to provide
Information collected through your use of the Platform
We may also collect technical information about how you access and use the Services, including your IP address, browser and device type, operating system, pages visited, and session timestamps. We may use cookies and similar technologies for this purpose. You can adjust cookie preferences through your browser settings, though doing so may affect certain Platform functionality.
Information from third parties and other providers
In connection with your care, we may receive relevant medical records and clinical information from other healthcare providers involved in your treatment, and from third-party services you choose to connect to the Platform, subject to their respective terms and your consent.
Recordings of virtual encounters
The Platform may record virtual healthcare encounters as part of the clinical record, subject to your prior consent and applicable law. Recordings may be reviewed by Medigroup for quality assurance, training, or clinical purposes where permitted, and will be handled in accordance with professional confidentiality obligations and this Privacy Policy.
II. How We Use Your Information
We use personal information to:
- Provide, maintain, and improve the Services
- Communicate with you about your account and your care
- Fulfill your requests for appointments, services, or information
- Meet our legal and regulatory obligations under PHIA, PIPEDA, and other applicable legislation
- Detect and prevent fraud, misuse, or unauthorized access to the Platform
- Conduct research or quality improvement activities, where permitted and with appropriate authorization
Where your information constitutes personal health information, it will be collected, used, and disclosed by the treating physician in accordance with applicable health privacy legislation, including PHIA, and with your consent or as otherwise permitted or required by law.
III. How We Share Your Information
We may share your personal information in the following circumstances:
- With healthcare providers, laboratories, insurers, and other parties directly involved in your care
- With third-party vendors and service providers who assist us in operating the Platform, who are contractually required to provide a level of protection for your personal information that is comparable to that required under applicable law
- With Medigroup affiliates that are bound by this Privacy Policy
- In connection with a merger, acquisition, or other corporate transaction involving Medigroup, as permitted by law
- In response to a valid legal process, court order, or regulatory requirement, or to protect the rights, safety, or security of individuals or the Platform
- With your explicit consent or at your direction
We do not sell your personal information to third parties.
IV. How We Retain Your Information
We retain personal information only as long as necessary to fulfill the purposes identified in this Policy and to comply with applicable legal and regulatory requirements. Personal health information forming part of a clinical record is retained in accordance with applicable professional and legal requirements. When information is no longer required, it is securely destroyed or anonymized.
V. Security
We take reasonable technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These include encryption in transit and at rest, role-based access controls, and audit logging. No system can be made entirely secure, and we cannot guarantee the absolute security of information transmitted over the internet. You are responsible for protecting your account credentials.
VI. Your Rights
Subject to applicable law and any clinical record retention obligations, you may request access to, correction of, or deletion of personal information we hold about you. To make a request, contact us through the information provided below under "Contact". Some requests may be subject to legal or regulatory limitations. You also have the right to challenge our compliance with applicable privacy laws by contacting us using the information below.
VII. Third-Party Links
The Services may contain links to third-party websites and services that Medigroup does not control. This Privacy Policy applies only to the Medigroup Platform. We encourage you to review the privacy practices of any third-party sites you visit.
VIII. Data Residency
Personal information collected through the Platform is stored and processed in Canada in accordance with Canadian privacy law. If you access the Platform from outside Canada, you acknowledge that your information may be transferred to and processed in Canada.
In some cases, we or our service providers may use systems or services that involve the transfer or access of personal information across provincial or national borders. In such cases, information may be subject to the laws of those jurisdictions.
IX. Changes to This Policy
We may update this Privacy Policy periodically. Changes will be reflected by an updated "Last updated" date at the top of this document. We encourage you to review this Policy when you use the Services.
X. Contact
Medigroup has designated a privacy officer responsible for overseeing compliance with applicable privacy laws. You may contact our privacy officer using the contact information below for any questions, requests, or complaints regarding your personal information.
- Name: Medigroup Privacy Officer
- Email: privacyofficer@medigroup.ca
- Phone: 204-942-0933
Regulatory Notice: College of Physicians and Surgeons of Manitoba
This virtual clinic operates in conjunction with Medigroup's physical medical facilities:
- Medigroup Portage Clinic, 100-330 Portage Avenue, Winnipeg, MB, R3C 0C4
- South Sherbrook Health Centre, 88 Sherbrook St, Winnipeg, MB, R3C 2B3
In-person follow-up care is available at both locations and may be required by your physician.