TELUS Health Corporate Privacy Commitment

TELUS Health offers a variety of health, wellness and workplace management products and services that are designed to build and maintain healthy communities and workplaces. TELUS Health is committed to delivering remarkable experiences for the benefit of all customers and individuals we serve while also protecting Personal Information and respecting privacy.

TELUS Health commitment to protect your privacy

This Privacy Commitment explains the collection, use and disclosure of Personal Information and sets out the basis on which any Personal Information we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Commitment carefully to understand the ways in which we collect, use, disclose and protect your Personal Information.

As described in further detail below, TELUS Health collects, uses and discloses Personal Information to identify you, establish eligibility, and provide technology-enabled total health, wellbeing and human resources services (such as pensions and benefits, employee assistance programs, and health management programs), including through our websites and apps. We also use your information to analyze and improve our services and to communicate with you.

Our Privacy Commitment and practices are consistent with the 10 Fair Information Principles, and we strive to apply the principles of Privacy by Design in the development and review of our products and services.

Additional information about how TELUS Health collects, uses and discloses Personal Information in connection with certain products and services can be found here:

https://www.telus.com/en/health/about-telus-health/privacy

1. Definitions

The following definitions apply to this Privacy Commitment.

Healthcare Practitioners - Practitioners that provide or assist in the provision of healthcare in connection with the TELUS Health services, such as psychologists, social workers, and registered nurses.

Personal Health Information - Any Personal Information regulated under applicable health privacy legislation in the jurisdictions in which we operate, which may include information that relates to an individual’s physical or mental health and healthcare, including health history, the provision of healthcare to the individual, payments or eligibility for healthcare, healthcare provider, substitute decision-maker, health card number or other healthcare-related personal identification numbers, or any other information that is collected in the course of providing health services to the individual, including information contained in a medical record.

Personal Information - Any information about an identifiable individual, other than business contact information used to contact an individual in their business or professional capacity. Personal Information does not include anonymized or aggregated information that cannot reasonably be associated with a specific individual.

TELUS Health - In this Privacy Commitment, the words "we", "us", "our", or "TELUS Health" refer to TELUS Health Limited.

TELUS Family - In this Privacy Commitment, "TELUS Family" means TELUS Communications Inc. and its subsidiary companies and corporate affiliates, as they may exist from time to time.

You - An individual who uses the TELUS Health services or otherwise interacts with us.

2. About this Privacy Commitment

We created this Privacy Commitment to tell you:

What Personal Information we might collect about you;
What we might do with that Personal Information; and
Your choices about the Personal Information you provide.

This Privacy Commitment covers our websites, mobile apps, services provided through these platforms or otherwise accessed by a user (such as our counselling and well-being services) and any other interactions you may have with us (such as by telephone, email, or in person).

3. Accountability

With the exception of limited information related to your eligibility for TELUS Health services (in respect of which your employer, plan sponsor, or other provider is responsible), TELUS Health typically has overall responsibility for protecting the privacy of the Personal Information we collect about you through the TELUS Health services, and we are directly accountable to you with respect to the handling of that information. In circumstances in which TELUS Health is not the responsible organization (e.g., when processing Personal Information related to your eligibility for the services, as described above), we may redirect a query or request concerning TELUS Health’s handling of your Personal Information to the responsible organization (e.g., your employer, plan sponsor or other provider).

Canadian residents: Certain TELUS Health services may be delivered by Healthcare Practitioners. With the exception of Alberta, Northwest Territories, and Yukon, TELUS Health has overall responsibility for protecting your Personal Health Information and we are directly accountable to you. In Alberta, Northwest Territories, and Yukon, your Healthcare Practitioners who are designated as ‘health information custodians’ or ‘custodians’ under applicable legislation (Alberta’s Health Information Act, Northwest Territories’ Health Information Act, and Yukon’s Health Information Privacy and Management Act), have overall responsibility for the privacy of your Personal Health Information and TELUS Health collects, uses, and discloses Personal Health Information on their behalf and otherwise assists them with their responsibilities under the applicable legislation.

U.S. residents: When using certain TELUS Health services, your employer or other provider may be considered a “covered entity” under the Health Insurance Portability and Accountability Act and will be responsible for the Personal Health Information we collect, use and disclose when delivering the TELUS Health services.

If we refer you to a third party outside of TELUS Health to receive healthcare or other services, that party will be accountable for handling any Personal Information you provide to them in accordance with that party’s privacy policy.

4. Consent

When we rely on consent to collect, use and disclose your Personal Information (which may depend on the jurisdiction in which you are based), you can withdraw your consent to such collection, use and disclosure, subject to our legal, regulatory and contractual restrictions. However, if you refuse to provide certain information or withdraw your consent, this may limit our ability to provide you with the TELUS Health services. The withdrawal of your consent does not affect the lawfulness of our collection, use and disclosure of your Personal Information based on that consent prior to its withdrawal.

In some situations, we may rely on the consent you provide directly to your employer or benefits provider.

You can close your account associated with the TELUS Health services at any time. To close your account or request to delete your Personal Information, you may be able to make a request through your account or you can contact us as set out below. If your request relates to healthcare or other services received from a third party outside of TELUS Health to whom we have referred you, we will direct you to the appropriate third party who can assist you.

To collect, use or disclose Personal Information outside of the purposes contemplated in this Privacy Commitment, we will seek additional consent from you where required.

When you provide Personal Information on behalf of a third party, such as a beneficiary, you represent that you have obtained all requisite consents and authority for us to collect, use, disclose and otherwise process such Personal Information for the purposes communicated to you at the time of collection or as otherwise set out in this Privacy Commitment, and you agree to provide such third party with a copy of this Privacy Commitment.

5. Where we get your information

We collect Personal Information in the following ways:

Directly from you;
From your use of TELUS Health services, programs, websites and apps;
From your employer, association, insurer or benefits plan sponsor;
When you attend a TELUS Health site or event;
When you apply for a position at TELUS Health;
If you contact us with a complaint or query;
When you engage with us over social media; and/or
From legally authorized third parties.

6. Children’s information

We will not knowingly collect, use or disclose your Personal Information if you are under the age of majority in your area (or such other age as specified by applicable law in the jurisdiction in which you are based) without the permission of your parent or guardian. If you are underage and want to access our counselling and wellness services, your parent or guardian needs to contact TELUS Health on your behalf.

7. What information we collect and why

We collect the Personal Information required for us to establish and maintain a responsible service relationship with you, to provide the TELUS Health services, to develop, enhance or market our products and services (including to send you relevant information about products and services that may be of interest to you), and to maintain and improve the security and functionality of the TELUS Health services.

We may collect Personal Information to set up an account for you where required to access and use the TELUS Health services.

We also collect other information from you as you use the TELUS Health services, such as:

app usage information
website and device information
cookies

We may use Personal Information to send you relevant marketing messages. You can opt out of receiving marketing messages at any time by following the unsubscribe instructions included in each of our marketing messages or by contacting us as set out below.

Details

We may collect and use the following types of Personal Information for the following purposes: