RCM Health Consultancy
RCM Health Consultancy
MembershipCorporate Health

Privacy Policy

RCM HEALTH CONSULTANCY INC. (“we,” “our,” “us” or “RCM Health”) is committed to protecting the personal and health information of every patient and client we serve. This Privacy Policy explains what we collect, why, how we safeguard it, and the choices you have in relation to the services we provide to you, including services under your RCM Health membership (the “Services”).

The term “Personal Information” includes personal information you provide during the intake process and health related information provided to us by your physicians, hospitals, and our affiliated medical specialists or subspecialists in the course of providing the Services.

Your personally identifiable information and privacy generally are protected by the Personal Information Protection and Electronic Documents Act (“PIPEDA”). Where it applies to our work, your personal health information and your right to access health records are also protected by Ontario’s Personal Health Information Protection Act, 2004 (“PHIPA”).

We follow the ten fair information principles: accountability, identified purposes, consent, limited collection, limited use and retention, accuracy, safeguards, openness, individual access, and the right to challenge compliance.

Please read this Privacy Policy (“Privacy Policy”) before signing up for an RCM Health membership or other Services. If you do not wish to share your Personal Information, the Services will not be available to you. By indicating your acceptance of this Privacy Policy and the Services, you expressly consent to our collection, use and disclosure of Personal Information in accordance with this Privacy Policy.

This Privacy Policy applies to RCM Health as a health information custodian, an agent of a health information custodian, its agents (including employees, affiliated medical specialists and subspecialists, contractors, consultants, and other workers at RCM Health, including all personnel affiliated with third parties), and to all programs, procedures, and technologies at RCM Health that involve Personal Information.

1. What Personal Information and Data Do We Collect?

We collect only what we need to provide the Services and coordinate your care. This may include the following, collected during the intake process and as your case progresses:

  1. Identity and contact information: full name, date of birth, address, phone number, email address, and emergency contact;
  2. Health information: health and medical history, diagnoses, test results, imaging, medications and immunizations, information pertaining to current health issues (physical or mental), records from your physicians and hospitals, and the name of your substitute decision maker, if applicable;
  3. Insurance and payment information: your insurer, plan or policy details, and billing information;
  4. Communications: emails, intake forms, call notes, and recordings of calls to our phone line where you are told the call is recorded; and
  5. Answers you provide to our periodic surveys about the Services.

You can pay through PayPal or with a credit card. If using a credit card, we will encrypt the data collected.

Where we get your information. Where possible, we collect information directly from you. With your consent, we also obtain it from your physicians, hospitals, insurers, employer health programs, or an authorized representative.

2. How We Use Your Personal Information

We use your Personal Information to assess your needs, arrange second opinions and specialist care, manage your case, communicate with you, bill you for the Services, and meet our legal obligations. RCM Health, its partners and affiliated medical specialists and subspecialists will process your Personal Information only for these purposes and for no other purposes.

What we will not do. In particular, RCM Health will not:

  • sell your Personal Information to anyone;
  • share your Personal Information with any third party except as described in Section 3 of this Privacy Policy;
  • combine Personal Information with personal information from third parties (except as permitted by applicable data protection laws); or
  • retain, use or disclose Personal Information for any purpose other than to perform the Services pursuant to this Privacy Policy or as required by law.

Requests and legal enquiries. RCM Health will promptly assist and co-operate as necessary to:

  • take reasonable and appropriate steps to stop and remediate any unauthorized processing of Personal Information;
  • respond to any request for access to, correction or erasure of Personal Information, any objection to the processing of Personal Information, any withdrawal of consent, and any request relating to data portability received by RCM Health; and
  • respond to any request for access to or surveillance of Personal Information received by RCM Health from any government official (including any court, data protection agency or law enforcement agency).

Our other commitments.

  • Personal Information collected or accessed by RCM Health in the performance of the Services will be limited to that which is necessary to perform such Services or to fulfill any legal requirements. RCM Health will make its best efforts to keep Personal Information accurate and current.
  • RCM Health will comply with all applicable privacy laws related to your Personal Information.
  • RCM Health will co-operate in responding to and contesting enquiries, complaints, and claims relating to the processing of Personal Information from any court or governmental official (including but not limited to any data protection agency or law enforcement agency).

3. Our Disclosure of Personal Information

We share only what is necessary, and only with your consent or as the law permits:

  • Your care team: physicians, specialists and subspecialists, hospitals, and Centres of Excellence in our network.
  • Payers you authorize: your insurer, benefits plan, or employer health program, limited to what they need to approve or pay for services.
  • Service providers: secure technology, hosting, and communications vendors bound by written confidentiality agreements.
  • Legal requirements: where disclosure is required by law, court order, or to prevent serious harm.

By providing us with your Personal Information, you give RCM Health your express consent to share your Personal Information with our affiliated medical specialists and subspecialists as needed for them to provide the Services. The sharing of such Personal Information will be done through a cloud-based portal operated by one of our service provider partners who are PHIPA compliant. Except as described above, we do not use your Personal Information for any other purpose or disclose it to any other third party without your explicit consent.

Care outside Canada. If you choose treatment or a second opinion abroad, we transfer the information that provider needs. Your information will then be subject to the laws of that country. We assess these transfers, use secure channels, and obtain your express consent before any cross-border disclosure.

4. Communication Preferences

By providing us with your Personal Information, you give RCM Health your express consent to contact you using the contact details that you provide.

5. Security, Retention and Breaches

We, our partners and our affiliated medical specialists and subspecialists are PHIPA compliant and protect your Personal Information with physical, administrative, and technical safeguards. These include encrypted storage and transmission, role-based access, regular privacy training, and other industry standard security technologies. Only staff who need your information to serve you can access it. We continuously use these measures to protect your Personal Information from unauthorized access and against loss, misuse or alteration. Despite our efforts, however, we cannot guarantee the security of any Personal Information.

Retention. We keep health and case records for at least 10 years after our last service to you, or 10 years after a minor patient’s 18th birthday, unless the law requires a longer period.

Breaches. If your Personal Information is lost, stolen, or accessed without authorization, we will notify you as soon as reasonably possible and take prompt action to rectify the cause. We will also report the breach to the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario as the law requires.

6. Your Rights and Choices

  • Access and correction: you may request a copy of your records or ask us to correct them. We respond within 30 days.
  • Withdraw consent: you may withdraw your consent at any time, subject to legal limits. We will explain how this affects the Services we can provide.
  • Limit sharing: you may ask us not to share specific information with a named person or organization.

To make any of these requests, contact our Privacy Officer using the details in Section 9.

7. Automated and AI-Assisted Tools

Our phone line and secure case-management platform may use automated and AI-assisted tools to answer questions and record intake details. These tools do not give medical advice or make decisions about your care. Our staff review all information.

8. Changes to This Privacy Policy and Jurisdiction

We review this Privacy Policy at least annually and may amend it from time to time. The use of Personal Information we collect is subject to this Privacy Policy. If we make any material changes in the way we use Personal Information, we will post a notice on our website, but in all respects, we will only use your Personal Information in accordance with PIPEDA, PHIPA and other relevant provincial privacy legislation that may be enacted in the future. You are bound by any changes to the Privacy Policy when you participate in the Services after such changes have been posted.

This Privacy Policy will be interpreted in accordance with the laws of the Province of Ontario and the Federal Laws of Canada.

9. Questions and Complaints

It is our goal to make our privacy practices easy to understand. If you have questions, concerns or would like more detailed information, please contact our Privacy Officer:

RCM Health Consultancy Inc., Toronto, Ontario
Email: info@rcmhealth.ca
Phone: 647-350-5500

If we cannot resolve your concern, you may contact the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario.