Notice of Privacy Practices

Field Trip Health and Wellness Ltd. (“Field Trip”)

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This Notice applies to all Field Trip Health and Wellness Ltd., centres and contractors working in such locations.

I. Field Trip’s Legal Obligations

Field Trip is required by law to maintain the privacy of your personal health information and to provide individuals with notice of our legal duties and privacy practices with regard to personal health information, and to receive consent for collection, use, and disclosure of your personal health information.

We are also required by law to maintain the privacy and security of your personal health information. We will let you know promptly if a breach of your unsecured personal health information occurs that may have compromised the privacy or security of your personal health information.

We will follow the duties and privacy practices set forth in this notice and provide you with a copy of it.

We will not share your personal heath information other than described herein unless you tell us that we can do so in writing. If you tell us, you may change your mind at any time by letting us know in writing.

We must follow these privacy practices that are described in this Notice while it is in effect. This Notice takes effect July 2021 and supersedes all prior Notices of its kind and will remain in effect until we replace it.

As permitted by law, we reserve the right to amend or modify our privacy policies and practices. These changes in our policies and practices may be required by changes in federal, provincial and/or territorial laws and regulations. We will provide you with the most recently revised Notice during regular business hours when you visit the office, or we may fax or email it to you if you have agreed to receive electronic communications of this kind. Any changes to our privacy practices will apply to all information we have about you.

II. Uses and Disclosures of Health Information

We typically use or share your health information in the following ways:

Treatment

Your health information may be used by our workforce members and/or disclosed to other health care professionals for the purpose of evaluating your health, diagnosing medical conditions, and providing treatment. For example, results of laboratory tests and procedures will be available in your medical record to all health professionals who may provide treatment or who may be consulted by workforce members.

For those participating in the And Beyond Program, your health information is shared with contract therapists who provide such services and are providing care to you.

For those participating in the Cooperative Ketamine Program, your health information is shared with your therapist.

Bill And Receive Payment For Services

Your health information may be used to seek or obtain payment from your health plan, from other sources of insurance coverage such as your provincial insurer, benefits insurer, or from credit card companies that you may use to pay for services. For example, your health plan may request and receive information regarding dates of service, the services provided, and the medical condition being treated.

Health Care Operations

Your health information may be used as necessary to support the day-to-day activities and management of Field Trip. This would include but is not limited to running our practice, improving your care, and for contacting you when necessary. For example, information on the services you received may be used to support quality assessment and improvement activities, reviewing the competence or qualifications of healthcare professionals, evaluating practitioner and provider performance, conducting training programs, accreditation, certification, licensing, credentialing activities, budgeting and financial reporting, and other activities to evaluate and promote quality.

We are also allowed or required to share your information in other ways, usually which promote the public good such as public health and research. We may have to meet certain conditions in the law before we can share your information for these purposes which include:

To You, Your Family and Friends

We must disclose your health information to you as described in this Notice. We may also disclose your health information to a family member, friend, or other person to the extent it is necessary to do so to assist with your healthcare needs or with payment for your healthcare, but only if you agree that we may do so. If there are individuals to whom you want to give us permission to share such health information with, please let us know by requesting and filling out the necessary form (available upon request).

Appointment Reminders

We may use or disclose your health information to provide you with appointment reminders (such as voice mail messages, text messages, emails, postcards, or letters) unless you direct us not to do so.

To Avert a Serious Threat to Health or Safety

We may use or disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or other person. Any disclosure, however, would only be to someone able to help prevent the threat.

Comply with the Law

We will share information about you if federal, provincial, or territorial laws require it.

Military Personnel

If you are a member of the armed forces, active or reserve, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.

Law Enforcement

Your health information may be disclosed to law enforcement agencies to support government audits and inspections, to facilitate law-enforcement investigations, and to comply with government mandated reporting. For example, we may release medical information if asked to do so by a law enforcement official:

In response to a court order, search warrant, production order, or similar process;
To identify or locate a suspect, fugitive, material witness, or missing person;
About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;
About a death we believe may be the result of criminal conduct;
About criminal conduct at the facility;
In emergency circumstances to report a crime, the location of the crime; and
In compelling circumstances affecting the health or safety of an individual.

Public Health Risks

We may disclose medical information about you for public health activities. These activities generally include the following:

To prevent or control disease, injury, or disability;
To report child abuse or neglect;
To report reactions to medications or problems with products;
To notify people of recalls of products they may be using and to provide your health card number and/or other required information to medical device companies and similar organizations regulated by Health Canada (for example, biologic supply companies and donor banks) so that such organizations may locate you should there be a need to do so;
To notify a person who may have been exposed to a disease, or who may be a risk for contracting or spreading a disease or condition; and
To notify the appropriate government or law enforcement authority if we believe a patient has been the victim of abuse, neglect, or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.

Work With a Medical Examiner or Funeral Director

We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medical information about you as a patient of the facility to funeral directors as necessary to carry out their duties.

Workers’ Compensation

We can use or share health information about you for workers’ compensation claims.

Respond to Lawsuits and Legal Actions

We can share health information about you in response to a court order or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

Marketing Health-Related Services

With your consent, we may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you with your express consent.

Research

We can use or share your information for health research, with consent or when province/territorial-specific conditions are met. Any such report will be anonymized.

Other Uses and Disclosures Require Your Prior Written Authorization

Any other disclosure of your health information or its use for any purposes other than those listed above requires your specific written authorization in most cases. If you change your mind after authorizing a use or disclosure of your information, you may submit a written revocation of the authorization. However, your decision to revoke the authorization will not affect or undo any use or disclosure of information that occurred before you notified us of your decision to revoke your authorization. If you revoke your authorization, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required by state law to retain our records of the care that we provide to you.

Without your authorization, we are expressly prohibited to use or disclose your protected health information for marketing purposes when financial remuneration is involved or for marketing other than face-to-face communication or provision of promotional gifts of nominal value. We may not sell your protected health information without your authorization. We may not use or disclose most psychotherapy notes contained in your protected health information without an authorization. We will not use or disclose any of your protected health information that contains genetic information that will be used for underwriting purposes.

III. Individual Rights

You have certain rights under the federal privacy legislation, Personal Information and Electronic Documents Act, and provincial or territorial laws that have substantially similar legislation, or specific legislation that deals with personal health information. These include rights to:

Request Access to Your Information

You can request to view your medical records under our control, with limited exceptions.

Request a Copy of Your Information

You can ask to get a copy of your medical record and other health information we have about you, with limited exceptions. Usually, this includes medical and billing records, but does not include psychotherapy notes. All such requests must be in writing. You may obtain a form to request access by using the contact information listed on this Notice.

You may request that we provide copies in a format other than photocopies. We will use the format you request unless we cannot practicably do so.

Where a copy of your medical records is requested, we may impose a reasonable fee that covers the cost of providing access to the documents.

Ask Us to Correct Your Information

You can ask us to correct health information about you that you think is incorrect or incomplete. This request must be in writing, and it must explain why the information should be amended. We may deny your request under certain circumstances, in which case we will provide a written explanation typically within 30 days (20 in Quebec) of your request, unless an extension has been granted.

Get a Copy of this Privacy Notice

You can ask for a paper copy of this Notice of Privacy Practices at any time, even if you have agreed to receive this notice electronically. Upon request we will provide you with a paper copy promptly.

Choose Someone to Act For You

If you have given someone medical power of attorney or if someone is your legal guardian, substitute decision maker, or otherwise able to act on your behalf, that person can exercise your rights and make choices about your health information. We will verify that this person has this authority and can act for you before we take any action.

File a Complaint if You Believe Your Rights Have Been Violated

You can complain if you feel we have violated your rights by contacting us as indicated below. You can also file a complaint with the Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3, Toll free: 1-800-282-1376 or (819) 994-5444, or the applicable Provincial/Territorial Privacy Commissioner. We will not retaliate against you for filing a complaint.

IV. Provincial or Territorial Law

Some provinces have enacted substantially similar legislation dealing with personal health information that takes precedence over some of the terms contained here. To the extent that the substantially similar privacy law imposes requirements that are more restrictive than federal privacy law, the provincial law will pre-empt the federal law.

The following is a summary of circumstances where your health information may be shared under provincial laws:

V. British Columbia

Get a List of Those with Whom We Have Shared Information

You can ask us for a list of individuals and / or organizations we have shared your information with. Except in limited circumstances is an organization able to not disclose the information, including if the disclosure could threaten the safety, physical, or mental health of the person who made the request.

VI. Notice for Records

We keep a record of the health care services we provide you. You may ask us to see and copy that record. You may also ask us to correct that record. We will not disclose your record to others unless you direct us to do so or unless the law authorizes or compels us to do so. You may see your record or get more information about it under the heading “Complaints” below.

VI. Complaints

If you would like to submit a comment or complaint about our privacy practices, or request further information regarding our privacy practices, you can do so by sending a letter outlining your concerns to: the Field Trip Health and Wellness Privacy Office at

Field Trip Health Canada Privacy Office

30 Duncan Street, Suite 401

Toronto, ON

M5V 2C3

If you believe that your privacy rights have been violated, you should contact us immediately. You will not be penalized or otherwise retaliated against for filing a complaint.

VII. Effective Date

This notice is effective as of July 1, 2021.