Privacy Policy

SECTION 1: PRIVACY COMMITMENT

Hospall Private Homecare Inc. (“Hospall”) is committed to ensuring that the
information it holds is protected and that confidentiality is maintained. Hospall’s duties include
collecting, using, disclosing, retaining, and destroying personal information as it relates to providing
health care services and otherwise caring for you.

Hospall’s Privacy Management Program is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Personal Health
Information Protection Act (PHIPA)
. Hospall may also be governed by additional applicable provincial
and professional standards.

SECTION 2: ACCOUNTABILITY

While all Hospall employees are accountable for maintaining the privacy of information
obtained in the course of their employment, Hospall’s Privacy Officer is responsible for overall compliance.
Hospall staff receive careful training on privacy practices and our own Privacy Management Program.

In order to provide you with good care and service, Hospall’s employees endeavor to ensure
that all personal information is accurate, complete, and up to date. We need your assistance in doing this.
Please let us know if any information relevant to your health care needs to be changed. However, we will not
continue updating your information once you have been discharged.

As required, Hospall will amend this document and its Privacy Management Program
when changes to privacy legislation or best practices are known.

SECTION 3: WHAT PERSONAL INFORMATION WE COLLECT AND WHY

Hospall staff will collect the personal information required to provide you with the care
and service requested and to respond to questions and inquiries you have. Such information may include your
name, address, contact information (on yourself and other designated persons), your health information
number, and the name of your family physician and any other health care providers. For all services that you
request, we may ask you specific questions to help us determine how you manage at home with your current
health status, including your ability to be independent in the residence.

When you request or require home support or personal support services, we will collect
information regarding your health and ability to perform activities of daily living. This allows us to
assess how best to support you. If you require nursing services, we will complete a more thorough assessment
of your health to determine the level of care that you will require.

If you make inquiries of Hospall online, we may ask for your name, email address and any
other information that we feel is reasonably necessary to answer your questions.

If at any time we require more or different information, or your information is
required for a purpose other than the care and service discussed with you, unless otherwise permitted or
restricted by law, you will be contacted.

SECTION 4: CONSENT

We will obtain your consent – either express or implied – before collecting your personal
information. Implied consent depends on what is reasonably anticipated in the circumstances. For example, if
you ask Hospall to attend at your house, it is implied that we will collect your address for purposes of
attending at your house.

When your case begins, we will request that you give us your express written consent for
the services that we will be providing you. This is typically done by way of a Client Consent and can
include your permission regarding the release of information that we require. Before you fill out this form,
our supervisor or nurse will discuss it with you and, at this point, you can advise us if there are certain
people with whom you do not want your information shared with.

Once your consent is given, it is deemed to be given throughout the entirety of our
service, however, you may withdraw your permission or consent in part or in whole, at any time during your
care and service. Changing your consent may restrict our ability to provide the requested services. Should
this occur, you will be informed about how your consent change will affect our services. In order to change
the terms of your consent, or to withdraw, simply contact the Hospall office.

For those individuals who are unable to provide consent, e.g. minors, those who are
seriously ill or mentally handicapped persons, consent will be obtained by an authorized authority, e.g. a
legal guardian, power of attorney or the executor of your estate.

SECTION 5: HOW WE USE YOUR PERSONAL INFORMATION

Your personal information will be used so that we can provide you with the health care
services you request and work with your other health care professionals. Using the Client Consent form, our
nurse will review the information and record your wishes.

Your information may be reviewed with respect to auditing and quality improvement
services, but this may be done without reference to specific people. The purpose of such a review is to
monitor our performance and improve our services.

SECTION 6: WHO WE SHARE YOUR PERSONAL INFORMATION WITH

When you start service with Hospall, and you sign the Client Consent, we discuss with you
who we may share your information with. We will typically share your information with those individuals that
we consider the members of your “multidisciplinary care team” or “circle of care”. We may also share your
information as otherwise permitted or required by law. Not all employees of Hospall have access to your
personal information, even though they are employees of Hospall, and you are a client of Hospall.

If there are people to whom you do not want us to share your information with, please let
us know.

In those rare circumstances where we are required by law to share your information,
Hospall will verify the lawful authority requesting the information and only provide what is reasonably
necessary for the stated purpose of such request.

SECTION 7: HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Hospall will continue to have access to your information even after your services have been
discontinued. We retain all discontinued client records for a minimum of 10 years, or longer if required by
provincial regulation. We retain children’s records until the child reaches the age of majority plus 10
years. These records whether at our offices or off site, are stored in a manner that are designed to ensure
ongoing security. Hospall uses off site storage facilities that cite privacy practices which are in
compliance with relevant privacy legislation and only after a Confidentiality Agreement has been signed with
the facility. Records are kept of the location of files retained, so that we may retrieve them as required.
At the end of the 10-year period, all information that we have, regardless of format, is destroyed in a
confidential manner.

In a circumstance where the records are created by Hospall and then retained by
other health care organizations, such organizations will maintain the information according to their own
retention schedule. Accordingly, access requests will be redirected to the relevant organization in
possession of the information.

SECTION 8: SAFEGUARDS

Hospall has many measures in place designed to ensure that your information remains
confidential, and to comply with requirements under PIPEDA, PHIPA and other applicable laws. Confidentiality
applies to all of your information, regardless of whether we store it electronically, in paper format or
simply within the knowledge of our staff.

Staff members complete privacy training at the commencement of their employment and
throughout the course of their employment. In addition, they sign a confidentiality agreement and are not
permitted to share any information beyond what is required to exercise their duties at Hospall.

Electronic information is password protected and firewalled. Unauthorized access is
restricted through the implementation of safeguards for the storage of information. We also limit access to
personal information to those individuals that require it to complete your services. In this regard, we
manage our employees and contractors strictly to ensure that information is treated with the utmost care.

Hospall protects hard copy files by storing them in our office where access is restricted
to staff with the necessary authority. Outside of working hours, the files are kept in a locked and secure
area.

In order to protect faxes from going astray, they are sent to pre-programmed numbers and
include a confidentiality sheet that outlines what to do if received in error. Similarly, our emails contain
a statement informing the receiver what to do if the message is received in error. Both faxes and emails
contain the number for Hospall’s Privacy Officer in case errors occur.

Hospall is not responsible for the privacy practices of organizations linked on our
website.

SECTION 9: ACCESS TO YOUR PERSONAL INFORMATION

Subject to certain limitations, you are able to view your personal information at any time.
This can be done by sending a written request to Hospall’s Privacy Officer. You may also request a copy of
your file by writing to your local Hospall branch. We invite you to view your records with one of our nurse
managers so that they may be available to answer any of your questions.

In order to maintain our privacy standards, we may need information to identify the person
who is making a request for the information. This is only used to make sure that the requesting person is
authorized to obtain the information.

When Hospall receives a request for information, we aim to respond to it within 30
days, subject to any limitations that may arise at law. If your access to information is refused for any
reason, we will provide you with the reasons for such refusal. A reasonable fee may be charged based on the
information that is being requested.

SECTION 10: YOUR RIGHT TO CORRECT YOUR PERSONAL INFORMATION

You may contact Hospall in writing to request a correction of any errors that may
be in your personal information. If the requested correction cannot be made, we will notify you of the
reasons for this.

SECTION 11: CONTACT INFORMATION – PRIVACY OFFICE

If You Need More Information about Hospall and its Privacy Practices

Anyone can contact Hospall, at the contact information below, with respect to a complaint,
question, concern or compliment relating to Hospall’s information handling practices. Any complaints made to
Hospall will be investigated thoroughly and action will be taken if the complaint is found to be justified.

If you have any questions or concerns about your personal information, or if you would like
more information about Hospall’s policies and practices for managing and handling personal information, you
are invited to contact Hospall’s Privacy Office by email at michelle@hospall.com, by calling 1-800-208-8480 ex 101 or in writing to Hospall Private Homecare
Inc., 28 Claudview St, King City, ON L7B 0C6, Attention: Privacy Officer.

You are also entitled to contact your provincial Privacy Commissioner’s Office if you feel
this is necessary. While we would appreciate the opportunity to do what we can to address your concerns, we
would also assist you in contacting your Privacy Commissioner’s Office if you believe this is warranted.

Latest Revision Date: May 22, 2019