Babylon by TELUS Health Privacy Policy

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At Babylon our mission is to put an accessible and affordable health service in the hands of every person on earth. We are passionate about high-quality and convenient healthcare. We are also passionate about privacy. We strive to be market leaders when it comes to healthcare and privacy, and always to comply with applicable privacy laws.

This policy explains how we collect, use, disclose and otherwise process your personal data when you use our healthcare services and products in Canada, or visit or use the App or any of our websites that link to this policy (collectively, our “App”).

We want to help you understand how we work with your data, so that you can make informed choices and be in control of your information. We invite you to spend a few moments understanding this policy. We may update this policy from time to time and we will notify you when we do so.

This policy covers:

  1. Who we are;
  2. What personal information we hold and how we get it;
  3. What we use your personal information for;
  4. Sharing your personal information;
  5. Retention;
  6. Data security and transfers; and
  7. Your rights.

If you have any questions about how we process your information, please don't hesitate to get in touch by contacting our Privacy Officer at privacyofficer@babylonhealth.com


1. Who we are

Your relationship is with Babylon Health Canada Limited. When this policy talks about 'Babylon', 'us', 'we' or ‘our’, it means Babylon Health Canada Limited.

Our website and App provide information services and digital healthcare software services through our digital healthcare tools (such as Healthcheck and our symptom checker).

In certain provinces, we also provide clinical services via our video and audio consultations with qualified medical professionals. As health information custodians, physicians may also be subject to legislative and professional requirements that govern their management of your information. Babylon provides physicians with the technology, maintenance and support to enable these clinical services.


2. What personal data we hold and how we get it

We use the following categories of personal data:


Personal details

When you register with us, you complete forms and provide us with basic information about yourself, such as your name, date of birth, physical address and email address. You will also provide us with a copy of identification documentation for ID checks to be carried out on our behalf by one of our service providers, and health card number/provincial health insurance number for the purposes of us billing the public health system. You are responsible for the accuracy of the information that you provide to us.


Health and medical information

The main type of information we hold about you is health and medical information: information about your health, symptoms, treatments, test results, consultations and sessions, medications and procedures. This includes details of your consultations with our doctors, and interactions with our digital services, including interactions with our symptom checker, Healthcheck, Digital Twin services, health monitoring, or other health and condition management services.

We get some of this information directly from you, when you register with us and when you use our healthcare services. We may also get this information from third parties, such as laboratories or other healthcare professionals.

We retain recordings of our consultations (where you have consented to the recording) and records of interactions with you. This can include your use of our digital tools (such as chatbot, Healthcheck and monitoring services), and audio consultation recordings. With your consent, consultation recordings may be viewed by our clinical management team for quality assurance and audit purposes. To monitor our service quality, we may retain records of when you contact our support teams via email or phone. Recordings are held securely in accordance with our retention policy.

We may also hold information about you and your health from other apps, devices and services where you have given your explicit consent to that data being shared with us (Babylon). Examples include where you decide to share information collected from a smart watch or similar device with our App (for example through our monitoring services). Our App name may appear on your device as ‘TELUS Health’, but your information is only shared with us (Babylon).


Financial information

If you make any payments on the App, your credit/debit card details are processed directly by a third party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers and we will not retain your credit or debit card information.


Technical information and analytics

When you use our App or visit our website, we may automatically collect the following information where this is permitted by your device or browser settings:

(a) technical information, including the address used to connect your mobile phone or other device to the Internet, your login information, system and operating system platform type and version, device model, browser or app version, time zone setting, language and location preferences, wireless carrier and your location (based on IP address); and

(b) information about your visit (such as when you first used the App and when you last used it, and the total number of sessions you have had on that App), including products and services you viewed or used, App response times and updates, interaction information (such as button presses or the times and frequency of your interactions with the communications we deliver to you in the App or otherwise) and any phone number used to call our customer service number.

    We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, which in-app notifications to send you, providing Babylon by TELUS Health product advertisements on the internet, measuring performance of our services and our advertisements, and de-identified reporting that helps us understand how users interact with our services. Cookies and similar technologies may be used to collect this information, such as your interactions with our services. You can change your device settings to block cookies, or to notify you before a cookie is set. If you block cookies, you may not be able to use all the features of our App. You can prevent the setting of cookies by adjusting the settings on your browser or your mobile phone. This technical information is not linked to your medical record. Your health information is not analyzed to target you with advertising services.

    Information obtained from third party services

    We may also hold information about you and your health from other apps, devices, and services where you have given your explicit consent to that data being shared with us. Examples include where you decide to share information collected from a smart watch or similar connected health device with our App. For example, in our ‘Monitor’ feature you can choose to sync your data from the Apple Health app via HealthKit. We would use your synced health and activity data from HealthKit to present you with a dashboard of your metrics to help you manage and improve your overall health. This data won’t form a part of a physician’s clinical record or be used or disclosed for marketing, advertising or use-based data mining purposes.

    Provided we are acting in accordance with data protection laws, we may also process information from other sources, such as specialist companies that supply information, our commercial partners and public registers. This information can for example, help us to improve and measure the effectiveness of our services. For example, we may receive epidemiological statistics about trends relating to healthcare from public reports, or anonymised statistical data relating to healthcare from research entities.

    3. What we use your personal data for

    The purposes for which we use your personal data and the grounds on which we do so are set out below. We generally use personal data with your consent, except where the use of personal data without consent is permitted by law.


      Providing you a service
      • We obtain and use your personal details and financial details in order to verify your identity and eligibility for our services, establish and deliver our contract with you including to provide the services you request, seek reimbursement for our health services from insurers (private and public) and (if applicable) charge you correctly.
      • We collect, use and retain medical information in order to provide effective diagnosis, treatment and care. This includes the information collected through our consultations with you (such as notes and recordings), our digital services, and medical history from your previous GP. It may also include sharing information with other healthcare professionals as necessary for the provision of care to you, such as your GP, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, and diagnosis centres chosen by you for the purpose of imaging request forms. It may also include Babylon physicians and their designates accessing your medical and / or prescription history contained within provincial databases (including but not limited to, PharmaNet, NetCare, Drug Profile Viewer) for the purpose of providing care or for the purpose of monitoring medication use.

      Making healthcare accessible
      • When you provide your optional explicit consent, we use data to build a better Babylon for all users- to make our services faster, smarter and more useful to you- so we can deliver better healthcare. Data improves the performance of our artificial intelligence, which in turn will provide you and our users with a better service. When we use data to learn from, we always remove personal identifiers (such as your name, contact details and address) to ensure that your privacy is protected. This data (with your personal identifiers removed in the way described above) may include your medical record (both records received and created by us), and your interactions with our artificial intelligence services, such as our symptom checker and other digital tools. This does not involve making any decisions which would have a significant effect on you – it is only about improving our products, services and software so that we can deliver a better experience to you and other Babylon users, and help achieve our aim of making healthcare affordable and accessible to everyone. Strict confidentiality and data security provisions apply at all times.

      Keeping you up to date
      • As part of providing you with high quality preventative health care services, we may contact you by SMS, email and/or other means to provide appointment reminders, offer you helpful information or invite you to make appointments, for example for free healthcare screening programmes (such as cervical cancer screening).
      • We may also use your email address, postal address, phone number and/or name to contact you or present you with occasional updates and marketing messages where you have not opted out.
      • You can opt out receiving these communications at any time by following the instructions contained within the marketing communication or visiting the ‘Privacy Settings’ in the app.

      Other uses
      • Based on our legitimate interest in managing and planning our business, we may analyse data about your use of our products and services to, for example, troubleshoot bugs within the App or our website, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you that would have a significant legal effect on you – it is only about improving our App so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
      • Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
      • We also store your medical information, such as notes from consultations, recordings of our consultations with you as well as your interactions with our digital services including interactions with our chatbot (including symptom checker, Healthcheck and Digital Twin services), health monitoring, or other health and condition management services, for safety, regulatory, and compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with lawful requests by regulatory bodies or as otherwise required by law or regulation.
      • Where necessary for safety, regulatory and/or compliance purposes, we may audit consultations and your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.
      • We may obtain and use data about your precise location where you give your consent (through providing us access to your location through your App or browser settings or your address), for example, to help direct you to the nearest pharmacy.

      4. Sharing your personal data with others

      We have partnered with TELUS Health to provide certain services on our behalf, including technical and customer support and communications. Your personal data will be shared with TELUS Health as necessary to allow TELUS Health to provide these services to you and to us. We also share with TELUS Health de-identified data that is no longer capable of identifying you, as well as aggregated data that does not personally identify you, but which shows general trends, for example, the number of users of our service. If you are a user of the Babylon by TELUS Health Enterprise App provided by your employer, we and / or TELUS Health may share this de-identified, aggregated data with third parties, such as your employer.

      • We may share your personal information with members of our corporate group, Babylon Partners Limited, to help us deliver our services to you, specifically hosting, managing and troubleshooting the App platform and its digital tools and providing technical support to our physicians and clinical support staff. Personal information is not shared with our investors.
      • We share personal information (with identifiers removed) with members of our corporate group, Babylon Partners Limited to help us develop, improve and maintain our software and artificial intelligence system (where you have optionally explicitly consented to this use of your information).
      • We may share your personal information with companies we have hired to provide services on our behalf, such as data hosting and processing, technical support, billing and payment processing, marketing and communications. These service providers are bound by strict confidentiality and data security provisions, and they can only use your data in the ways specified by us.
      • Where you access our services through public or private health insurance, and where you have given your consent, we will provide your insurance company with the personal information required to allow them to process your claim. This may include your name, email address, policy number, location, demographic information, that you had an appointment with us, the date of the appointment, details of your diagnosis, prescription, pharmacy location, whether or not you had a referral made and other similar information about your appointment with us. Personal information provided will be limited to only what is required.

      Information sharing with other healthcare providers
      • We will, where necessary for your treatment or care, share your information with your other health and social care providers. For example, your GP, specialist referral services, therapists, pharmacists, hospitals, accident and emergency services, pathology service providers, diagnosis centers chosen by you for the purpose of imaging requests, and other health and care bodies. This may include sharing information with such services for safeguarding purposes in accordance with our legal or professional obligations.
      • We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.

      5. Retention

      We retain your personal data and medical records for as long as necessary to provide the services you have requested and otherwise in accordance with legal, regulatory and self-regulatory requirements.


      6. Data storage, security and transfers

      We do not store your medical information on your mobile device.

      Where you have chosen a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

      We do not store any credit or debit card information. Payments are processed via a third-party payment provider that is fully compliant with Level 1 Payment Card Industry (PCI) data security standards. Any payment transactions are encrypted using SSL technology.

      We encrypt data transmitted to and from the App. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

      While some of your personal information may be processed outside of Canada, we store all of your medical information on secure servers in Canada.

      Some of your personal information may be processed or accessed outside of Canada by Babylon or our service providers. Regardless of location, personal information will be protected in accordance with the applicable data protection law and subject to strict safeguards. For example, when we do transfer personal information outside of Canada, we strive to minimize the amount of personal information to what is absolutely necessary to achieve the specified purpose. Notwithstanding these safeguards, while outside of Canada, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access personal information in certain circumstances. We will only provide, and our service providers are only permitted to provide, personal information in these circumstances if we or they are compelled to do so under applicable laws.


      7. Your rights

      As indicated above, whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by accessing the privacy settings in the App.

      You may also have the right to:

      • Request access to the personal data we hold about you. Recordings of your appointments with us and other medical notes can be accessed via the App. For other information, you can make a request by email;
      • Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
      • Ask us to restrict our processing of your personal data or object to our processing.


      Contact us

      For any questions or concerns, or if you’d like information about how to lodge a complaint with us or an applicable privacy commissioner’s office, you can contact us by sending an email to privacyofficer@babylonhealth.com.