TELUS Health MyCare Privacy Commitment

Effective as of October 30, 2024

Key updates: We've made some important updates to the TELUS Health MyCare Privacy Commitment to reflect the removal of the HealthCheck and Monitor features.

TELUS Health MyCare is a healthcare platform that enables individuals to access clinical healthcare services and tools to help manage their healthcare through a mobile app and our physical clinics.

We are passionate about the protection of your Personal Information and Personal Health Information and committed to respecting your privacy.

TELUS Health MyCare policy to protect your privacy

By accessing or using TELUS Health MyCare Services, you understand that your information will be treated in accordance with this TELUS Health MyCare Privacy Commitment (“Privacy Commitment”). 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.

If you do not want us to collect, use or disclose your Personal Information or Personal Health Information in the ways identified in this Privacy Commitment, you may choose not to use TELUS Health MyCare Services.‬‬‬‬‬‬‬‬‬‬‬‬‬‬

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Definitions

The following definitions apply to this Privacy Commitment.

You - An individual who uses, or registers to use, our Services.

Medical Record - A record of your Personal Health Information. This may include but is not limited to:

the name(s) of your Healthcare Practitioner(s) at each visit;
patient identification (i.e., name, address, phone number, personal health number, contact person in case of emergencies) and a medical history;
any photos you upload for use by your Healthcare Practitioner
records of examinations carried out by Healthcare Practitioners and clinical notes for each patient encounter;
requisitions for treatment or investigation;
consents to treatment obtained in writing;
records of treatment you receive from Healthcare Practitioners through our Services;
reports of investigative procedures and reports of the results of laboratory, pathology, consultations, diagnostic imaging examinations or tests;
diagnoses; and
a record of missed and/or cancelled appointments.

Your Medical Record excludes your TELUS Health MyCare account profile.

Healthcare Practitioners – Practitioners that provide or assist in the provision of healthcare through our Services, which may include physicians, nurse practitioners, registered nurses, psychologists, dietitians, and mental health therapists.

Personal Health Information - Any Personal Information regulated under applicable health privacy legislation in the provinces in which we operate, including 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 your Medical Record. Personal Health Information excludes data obtained through the use of TELUS Health MyCare Travel, unless specified.

Personal Information - Any information about an identifiable individual, other than business contact information used to contact the individual in their business or professional capacity. Personal Information includes your TELUS Health MyCare account profile and Personal Health Information.

Personal Information does not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.

Services - The TELUS Health MyCare app, our website

www.telus.com/mycare

, and our physical clinics.

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

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.

Accountability

In most provinces, TELUS Health MyCare has overall responsibility for protecting the privacy of your Medical Records and other Personal Information that we collect about you through your use of the Services, and we are directly accountable to you.

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Consent

When you access or use our Services, you consent to our collection, use, disclosure, and storage of your Personal Information as described in this Privacy Commitment.‬‬‬‬‬‬

You can withdraw your consent at any time, subject to limited restrictions.‬‬

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Collection and Use of Personal Information

We collect only the Personal Information required for us to establish and maintain a responsible healthcare and service relationship with you, to provide our Services, and 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 MyCare website and app.‬

We collect Personal Information to set up an account for you on the TELUS Health MyCare app so that you can access and use the TELUS Health MyCare health-related services, including:

Consultations with Healthcare Practitioners, virtually or in person

When you book a consultation with a Healthcare Practitioner, we collect your health card number and/or payment information.

We also collect other information from you as you use our TELUS Health MyCare website or app:

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 them at any time by following the unsubscribe instructions included in each of our marketing messages or contacting us as set out below.

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By creating an account with TELUS Health MyCare, you will have access to consultations with Healthcare Practitioners through video and audio conversations and related healthcare and administrative support services (i.e., prescription services, laboratory requisitions, etc.), as well as other tools to help you manage your healthcare through the app. Depending on your location, you may be able to access consultations with our Healthcare Practitioners in our physical clinics.

When using TELUS Health MyCare Travel in the United States you will have access to consultations with Healthcare Practitioners through telephone conversations.

We only collect and use Personal Information for the following purposes:

To establish and maintain our relationship with you

TELUS Health MyCare Account Creation: In order to use the Services that are available through the TELUS Health MyCare app, you will need to download the app and create an account by providing your first and last name, email address, province of residenceand a password that you select. If you are using the app as part of a benefit program provided by your employer, we also collect your date of birth and employer code at the time of registration in order to validate your eligibility to participate in your employer’s benefit program.

Once you have created an account, you will have access to all of the Services available through the app, including healthcare consultations. Creating an account is required to use the app as it enables TELUS Health MyCare to provide you with accurate and relevant information based on your Personal Information and records of your previous interactions with the app, such as your interactions with the health-related tools described below, healthcare consultation summary, and prescription history.

Authentication: Once your account is created, you may use biometric authentication or device password to access the app. The app will retrieve tokens saved in your device’s secure storage to authenticate your access.

Identity Verification and Confirmation: At the time of booking your first appointment with a Healthcare Practitioner in Canada, you will be required to verify your identity and provide details such as your address, phone number, date of birth, and sex assigned at birth.

We verify your identity in order to prevent someone from creating an account in your name and to help prevent fraud, including public healthcare fraud. In British Columbia, Ontario, and Quebec, you can verify your identity in the app by providing a photo of your government-issued identification (either driver's license, passport, or government-issued photo identification card) and a real-time selfie photo.

We use a third-party service provider who matches the photo on your identification card to the selfie you upload and validates the authenticity of the selfie and identification card provided. We do not use this information for any other purpose. In Alberta, you will be required to show your government-issued photo identification manually during your first consultation with a Healthcare Practitioner.

When you visit a physical clinic in person, you may be required to verify your identity by presenting your government-issued identification (either provincial health card, driver’s license, passport, or government-issued photo identification card).

Before each consultation with a Healthcare Practitioner, you will be asked questions to confirm your identity using information from your TELUS Health MyCare account profile. For example, you may be asked to confirm your phone number, date of birth, and first and last name, and to show your health card when you attend a physical clinic.

When using TELUS Health MyCare Travel, at the time of booking your consultation with a Healthcare Practitioner in the United States, you will be required to provide Personal Information to our third-party Healthcare Practitioner. For example, you may need to provide your address while in the United States. This service is exclusive for TELUS and Koodo customers with Easy Roam and Can-US plans. The Care Coordinator who answers your call may ask who your wireless carrier is for eligibility reasons.

To provide health-related services and tools to you

Healthcare Consultations in Canada: You will need to provide information about your current health condition and health history when booking a consultation appointment in the app and directly to Healthcare Practitioners, including any relevant photos you choose to provide on an optional basis, in order to enable TELUS Health MyCare to provide you with healthcare. This information will also be used to complete and update your Medical Record. The TELUS Health Chief Medical Officer and Medical Directors of our TELUS Health MyCare clinics may review Healthcare Practitioners’ work to ensure they are meeting the high standard and quality of care expected of them.

Real-Time Video and Audio Conversations in Canada: Where you wish to have a virtual consultation with a Healthcare Practitioner, we connect you through a real-time video or audio call. All video and audio calls conducted through the TELUS Health MyCare app are confidential and end-to-end encrypted. Recordings are never made.

Healthcare Consultations in the United States: You will need to provide information about your current health condition and health history to Healthcare Practitioners, in order to enable our third-party provider in the United States to provide you with healthcare. Our third-party provider may review Healthcare Practitioners’ work to ensure they are meeting the high standard and quality of care expected of them.The Personal Information provided to our third-party provider in the United States is not entered in or considered part of your Medical Record in Canada. Canadian Healthcare Practitioners do not have access to the information provided to our third-party provider in the United States; however, we may receive a copy to facilitate your request for access. Please review the ‘Access, Corrections, and Accuracy of your Personal Information’ section below for more information.

Real-Time Telephone Conversations in the United States: Where you wish to have a telephone conversation with a Healthcare Practitioner, you phone our toll free number from the United States. All telephone calls conducted through TELUS Health MyCare Travel may be recorded for training and quality purposes and will remain confidential.

Payments and Health Card Information: Prior to consulting with a physician, you will be required to provide a valid provincial health card number if the consultation is to be covered under your provincial health care insurance plan. Your health card number will be maintained on file for future visits (unless you choose to remove it from your account profile). If you choose to purchase any Services from us that are not covered under a provincial health plan, we collect your payment information, such as your payment method, payment card number, CVV code and signature (physical clinics only). This information is used to process your payments. We use a third-party service provider who is Payment Card Industry Data Security Standard (PCI DSS) compliant to facilitate secure payment processing.

Service Messages: We may contact you by SMS, email or push notification to provide you with helpful information related to our Services, such as how to prepare for your appointment, reminders, and other important information or updates. You can turn off push notifications at any time in your device settings. To adjust your communication preferences for SMS and email service messages, contact us using the contact information set out under ‘Questions, Complaints, and Contact’ below.

Location-based Services: Certain features of the TELUS Health MyCare app request your permission to use GPS technology to collect real-time information about the location of your device so that TELUS Health MyCare can help you locate a pharmacy or another healthcare service in your area. This service is provided for your convenience only, and your permission for this use is voluntary. This location data is not retained or used for any other purpose.

TELUS Health MyCare Technical Support: In certain circumstances, Personal Information may be required by or accessible to technical support staff in order to resolve technical issues. Where possible, our support team will resolve issues without viewing Personal Information. If you speak to TELUS Health MyCare support, all audio conversations are recorded to ensure quality of service to you and for training purposes.

To develop, enhance or market our products and services

Developing and enhancing our services: We analyze Personal Information in your TELUS Health MyCare account profile and actions you take on the TELUS Health MyCare app and your ratings or responses to surveys, to better understand how we can improve and what care programs or services to provide. For example, we may use your postal code and aggregate it with all other TELUS Health MyCare user postal codes to determine the best location to open a new physical clinic. We do not use information from your Medical Record for this purpose.

Satisfaction and experience surveys and questionnaires: Your name and email address may be used by us to contact you regarding your experience when using our Services. We may ask for additional information to follow-up. We may share this information with a third-party provider to address an issue or concern and to improve our service offerings.

Sending newsletters and marketing communications: Your TELUS Health MyCare contact details, including your name, email address and home address, may be used so that TELUS Health MyCare can provide you with news and offers by SMS, email or mail about TELUS Health MyCare, the TELUS Family, and third-party partners. These communications may be tailored based on data in your account profile and app activity, but not information contained in your Medical Record. We may send you offers for a TELUS service you may not currently subscribe to, or send you offers for a TELUS third-party partner that may be of interest to you. For example, a company that offers fitness or lifestyle services.

We may use your email address or phone number (where available) to digitally deliver ads about our services and offers on third-party websites and apps where we purchase advertising from our partners. We only share anonymized and aggregated information with our third-party partners and will not use information contained in your Medical Record.

You can opt out of receiving newsletters and marketing messages from us at any time by following the unsubscribe instructions included in each of our marketing messages or by contacting us as set out under ‘Questions, Complaints and Contact’ below.

To maintain and improve the security, performance and functionality of the TELUS Health MyCare Website and App

Visiting the TELUS Health MyCare Website: In general, you can visit our website without telling us who you are or submitting any Personal Information. However, we collect the Internet protocol (IP) addresses of all visitors to our website and other related information, such as device type, page requests, browser type, operating system and average time spent on our website. We use this information to help us understand our website activity and to monitor and improve our website. We also use your IP address and device type to help ensure a secure experience and detect anomalous behaviour.

Device Information: As with many applications, certain limited technical data is required for the TELUS Health MyCare app to function on your device. The information we collect includes information about your device and operating system, such as the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the app accesses our servers. This information is used to deliver content appropriate for your device’s capabilities, to deliver push notifications and to help ensure a secure experience and detect anomalous behaviour in order to protect Personal Information from unauthorized access. In addition, in the event the TELUS Health MyCare app crashes on your mobile device, we may receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of the TELUS Health MyCare app.

App Usage Information: We may collect and analyze information about the actions you take on the TELUS Health MyCare app to better understand what care programs or services to provide.

Cookies: Please see our

FAQs

and

Cookies Notice

for information on our use of Cookies.

De-Identification and Aggregation

De-Identifying and Aggregating Information: We may de-identify or aggregate your Personal Information, including information in your Medical Record, such that it cannot reasonably be associated with you, for the following purposes:

To protect your privacy and the security of your Personal Information;
To conduct analytics and/or research in a privacy protective manner to:

better understand and improve our Services;
operate and expand our business opportunities; and
improve health outcomes.

We may share such de-identified information or insights with our partners to assist in research, planning, or product and service development. This may include participation in provincial health initiatives that require the disclosure of de-identified information to inform government health strategy, policy and initiatives.

Our electronic medical record provider may de-identify and use data to assist in health care research, planning, or product and service development. For example, our electronic medical record provider may de-identify Personal Information so that it may be used to support clinic data quality, improve the platform or to analyze and recommend clinical outcomes for treatment.

Sharing and Disclosure of Personal Information

For continuity of care purposes, we may share Personal Information among your Healthcare Practitioners and others who assist in the provision of healthcare to you.

We will not disclose your Personal Information for any purpose other than what has been outlined in this Privacy Commitment or as permitted under applicable law, unless we obtain your consent. We disclose only the limited amount of Personal Information necessary to meet these purposes.

We do not sell your Personal Information to any third parties.

We may share your Personal Information with our service providers who are contracted to perform services or functions on our behalf where they require the information to assist us in serving you. We use contractual controls to protect this information and limit its use to what is necessary for the service provider to perform the service.

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We may share or disclose Personal Information for the following purposes:

Provision of Healthcare: If you receive healthcare through our Services, we may disclose your Personal Information to and among your Healthcare Practitioners for the purpose of providing or assisting in the provision of healthcare to you. We may also disclose your Personal Information to third parties, such as other health professionals, specialists, pharmacists, pharmacies and laboratories for the purpose of providing or assisting in the provision of healthcare to you – this includes, but is not limited to, providing medically appropriate referrals, prescriptions, or lab and imaging requisitions to you. Information will only be shared with your family doctor, hospital, lab or specialist with your consent (unless we are required to do so under applicable laws).

Your Medical Record will be stored in the TELUS Health MyCare infrastructure and will be accessible to Healthcare Practitioners who provide or assist in the provision of healthcare services to you from our physical clinics or virtual care app. A record of all Canadian appointments will be stored in the TELUS Health MyCare app.

Employers/Benefits Providers: If your access to our Services is facilitated through your employer or benefits provider, we may provide general information about the non-medical status of your account to them. We will not disclose any Personal Health Information to your employer or benefits provider. De-identified information may be shared with your employer at an aggregated level. For example, we may provide your employer with de-identified information about trending diagnoses such as an increase in mental health consultations overall, or the overall number of referrals to specialists made over a particular reporting period.

Service Providers: We may share Personal Information with the TELUS Family, our suppliers, agents or other organizations or individuals who are contracted to perform services or functions on our behalf, where they require the information to assist us in serving you. For example, we may use service providers to verify identification, process payments, power the app, host our website and store and dispose of information on our behalf. We strive to minimize the amount of Personal Information that we share with our service providers and partners and require that it not be used for any other purpose.

Disclosing Personal Information to our software provider, with your express consent: If you give us your express consent, TELUS Health MyCare will share with our software provider, eMed Healthcare UK, Limited, your Personal Information, including your Medical Record, in order to allow eMed Healthcare UK, Limited to improve the performance of the eMed Healthcare UK software technology, which powers the TELUS Health MyCare app. Pursuant to their privacy policy, which can be found

here

, eMed Healthcare UK, Limited will remove personal identifiers (such as your name, address and date of birth) prior to using or storing the information we disclose. Personal Information you agree to disclose will be treated in accordance with the eMed Healthcare UK, Limited privacy policy.

Within the TELUS Family: Your name, email address and home address may be shared within the TELUS Family and matched to your existing TELUS customer profile (if applicable) to identify other services that you have with the TELUS Family. This information may be used to:

Perform aggregated reporting and demographic analysis;
Ask for your feedback on our Services through surveys or other means; and
Help us and the TELUS Family provide better recommendations of TELUS products and services that may be of interest to you and exclude those that are not relevant. For example, we and the TELUS Family will try not to contact you to register for the TELUS Health MyCare app if you have already downloaded the TELUS Health MyCare app and registered for our Services.

Provincial Billing: If a Service is to be covered under your provincial health care insurance plan, we share Personal Information with the jurisdictional organization or agency for billing purposes for provincially-covered services.

Participating in Provincial Health Initiatives: We may participate in provincial health initiatives that require the disclosure of de-identified information to inform government health strategy, policy and initiatives.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of TELUS Health MyCare, or as part of a corporate reorganization or other change in corporate control.

Disclosures required or permitted by law or regulation: We may disclose Personal Information to the extent necessary where we are required or permitted under applicable law, such as in the event of an emergency that threatens the life, health or security of an individual. We or our service providers will also share Personal Information with law enforcement, courts, other government agencies or other parties if we are required to do so to meet our legal and regulatory requirements in the jurisdictions in which we or our service providers operate; for example, we are required to provide records to law enforcement in response to a valid court order.

Third Party Links: The TELUS Health MyCare app and website may contain links to other websites or platforms that TELUS Health MyCare does not own or operate. Also, links to our Services may be featured on third party websites or platforms as advertisements. Except as provided in this Privacy Commitment, we will not provide Information to these third parties without your consent. We provide links to third party websites or platforms as a convenience to our users. These links are not intended as an endorsement of, or referral to, the linked websites or platforms. The linked websites or platforms have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites or platforms, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites or platforms may collect, use, disclose, secure and otherwise handle Personal Information. You should read their privacy policies and make an informed decision about whether you want to use those websites or their services.‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬‬

Access, Corrections, and Accuracy of your Personal Information

You can request access to or correction of your Personal Information by contacting us at

[email protected]

We rely on you to keep your Personal Information up-to-date and accurate so that we can serve you.

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Storage and Location of your Personal Information

Your Personal Information, including your Medical Record for consultations conducted in Canada, is stored in Canada and cannot be accessed from outside Canada, with only a few limited exceptions.

Your Personal Information, including your Medical Record for consultations conducted in the United States, is stored in the United States and cannot be accessed from outside the United States, with only a few limited exceptions.

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Retention

We retain Personal Information only for as long as necessary to fulfil the purposes described in this Privacy Commitment or as required to meet legal or regulatory requirements.

Personal Information that forms part of your Medical Record must be retained for a period of time mandated by law.

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Safeguards

We have implemented a comprehensive information security program.

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Changes to this Privacy Commitment

We may make changes to this notice, and we will notify you of the changes to our information practices.

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Questions, Complaints, and Contact

You can always reach us at

[email protected]

if you have privacy questions, concerns or complaints.

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