TELUS Privacy Policy | Babylon Health

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Babylon by TELUS Health Privacy Policy

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 personal 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:                                   

  • Who we are;
  • What personal data we hold and how we get it;
  • What we use your personal data for;
  • Sharing your personal data;
  • Retention;
  • Data security and transfers; and
  • Your rights.

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

 

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.  

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.

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.

We get this information directly from you, when you register with us and when you use our healthcare services. Any correspondence we receive from you is uploaded electronically to your Babylon medical record.  We may also get this information from third parties, such as laboratories or other healthcare professionals.

We retain recordings of our consultations with you, in order to provide you with an easy way to re-watch your consultations where you wish to, and so that we can ensure high quality care is provided to you.  With your consent, we may also use the recordings to allow us to learn from them to improve our services. These recordings are held securely in accordance with our retention policy. You can access recordings of your consultations at any time through the App. You can always request that consultations not be recorded, or that recordings be deleted.

We may also hold information about you and your health from other apps, devices and services where you have given your consent to that data being shared with us. Examples include where you decide to share information collected from a smart watch or similar device with our App. 

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, we may automatically collect the following information where this is permitted by your device 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 type and version, browser or app version, time zone setting, operating system and platform, and your location (based on IP address); and

(b) information about your visit, including products and services you viewed or used, App response times, interaction information (such as button presses) and any phone number used to call our customer service number.

We work with service providers 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, providing our advertisements on the internet, and measuring performance of our services and our adverts. 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.

 

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.

  • We obtain and use your personal details and financial details in order to establish and deliver our contract with you.
  • We obtain and use your medical information because this is necessary for medical purposes, including medical diagnosis and the provision of healthcare or treatment. This includes the information collected through our consultations with you (such as notes and recordings) and your use of our digital services. 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.
  • Where you have provided your explicit consent, we will use your medical information (always having removed personal identifiers, such as your name, address and contact details) to improve our healthcare products and services, and our artificial intelligence system, so that we can deliver better healthcare to you and other Babylon users. This medical information (de-identified in the way described above) may include your medical record (both records received and created by us), transcripts and recordings of your consultations, and your interactions with our artificial intelligence services, such as our symptom checker. This does not involve making any decisions about 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.
  • We may obtain and use data about your precise location where you give your consent (through providing us access to your location), for example, to help direct you to the nearest pharmacy. We may also derive your approximate location from your IP address.
  • We use your email address and/or phone number to contact you with occasional updates and marketing messages where you have not opted out, based on our legitimate interest in marketing our services to you and subject to your right to opt out at any time.
  • 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, 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 - 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 use 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 and your interactions with our digital 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.

 

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.  With your consent, we will also share your personal data, such as name and contact details (but not medical or health data) with TELUS Health so that TELUS Health can tell you about their products or services that might be of interest to you.  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 data with members of our corporate group  to help us deliver our services to you. 
  • We share personal data (with identifiers removed) with members of our corporate group to help us develop, improve and maintain our software and artificial intelligence system (where you have explicitly consented to this use of your data).
  • We may share your personal data 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 need to let your insurance company know your name, email address, policy number, location (based on IP address), 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.  
  • 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. 

Our sharing of personal data with TELUS Health will always be in accordance with data protection laws and subject to strict safeguards.

Except as described above, we will never share your personal information with any other party without your consent. 

 

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.

Data storage, security and transfers

We do not store your personal health data on your mobile device. We store all your personal health data - including your primary care information, medication information and diagnostic information - on secure servers.

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. 

Your data may be processed, stored or accessed by Babylon or our service providers from inside or outside of Canada, including in the European Union. In either case, personal data will be protected in accordance with data protection law and subject to strict safeguards. For example, when we do transfer personal data outside of Canada, we strive to minimize the amount of personal data that we transfer.  Notwithstanding these safeguards, while outside of Canada, personal data may be accessible by foreign government agencies under applicable law. 

 

Your rights

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; and 
  • Ask for your data to be provided on a portable basis.

Contact us For any questions or concerns, you can contact us by sending an email to DPO@babylonhealth.com