Privacy Policy

The Provincial Health Authority, operating as NL Health Services (“NL Health Services”) is committed to protecting the privacy of individuals and taking reasonable security measures to help safeguard an individual’s personal and personal health information when collecting, using or disclosing information in compliance  with the Access to Information and Protection of Privacy Act, 2015 (“ATIPPA”) and the Personal Health Information Act (“PHIA”).

This Privacy Policy (“Policy”) describes:

• How NL Health Services collects, uses, discloses and protects your personal information, personal health information and/or other information (collectively “Information”) as a user of this Website (“Site”);
• Describes the types of Information NL Health Services may collect from you or that you may provide when you visit the Site; and
• The practices of NL Health Services when collecting, using, maintaining, protecting and disclosing Information on or through the Site.

 

This Policy applies to Information NL Health Services collects, uses, or discloses about you:

• On or through this Site and/or former agencies and/or health authorities’ websites that are now controlled by NL Health Services (referred to as “Subsites”) that you access through the links on this Site, unless you access the Subsites directly. For greater certainty, references to “Site” throughout this Policy shall include Subsites accessed by you through the links on this Site; and
• In email, text, and other electronic messages or communications between you and this Site.

 

This Site may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies, and NL Health Services does not accept any responsibility or liability for these policies or the actions of these third parties. NL Health Services does not control these third-party websites, and NL Health Services strongly encourages you to read and consider the privacy policy of every website you visit.

Please read this Policy carefully to understand our policies and practices for collecting, using and disclosing your Information. BY ACCESSING OR USING THIS SITE, YOU INDICATE THAT YOU UNDERSTAND, ACCEPT, AND CONSENT TO THE PRACTICES DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH THESE POLICIES AND PRACTICES, DO NOT ACCESS OR USE THIS SITE. NL Health Services reserves the right to change this Policy at any time without notice. Please review this Policy regularly as your continued use of this Site now, and following the posting of any updated Policy, will constitute your acceptance and consent to any changes to the Policy. NL Health Services includes the date this Policy was last revised at the bottom of the page. You are responsible for periodically visiting the Site and this Policy to check for any changes.

 

What is Personal Information?
Personal Information is defined in ATIPPA as recorded information about an identifiable individual, including, among other things, the individual’s name, address or telephone number and the individual’s age, sex, sexual orientation, marital status or family status. Personal information is collected, used, disclosed and/or processed in accordance with ATIPPA for many reasons as authorized under that legislation.

What is Personal Health Information?
Personal health information is defined in PHIA as identifying information in oral or recorded form about an individual that relates to, among other things, an individual’s physical or mental health and the provision of healthcare. This includes, but is not limited to, name, date of birth, MCP number, medical services and symptoms. Personal health information is collected, used, disclosed and/or processed in accordance with PHIA for many reasons, including the provision of healthcare.

NL Health Services will not request or store your personal or personal health information except as authorized under applicable legislation, and this Information will only be used by authorized individuals to fulfil the limited purpose(s) for which it was collected. NL Health Services collects, uses and/or discloses the following personal health information and/or personal information in or through this Site:

• IP addresses to establish approximate user locations. IP addresses are multiple digit numbers that identify a specific computer connected to the Internet. NL Health Services uses a third-party service to refine location data and improve efficiency. NL Health Services only collects and stores the location data necessary to provide and improve its services. This includes retaining IP address and location pairings in a localized database to optimize future searches and minimize requests for third-party services.
• IP addresses, together with the following additional user Information, for the purpose of enhancing Site functionality, optimizing content, analyzing Site traffic patterns, ensuring the integrity of Site ratings to minimize fraud and/or security threats, and Site monitoring for Site management, investigating and troubleshooting incidents, adding Site functionality and making Site improvements, through Google Analytics or similar automated technologies:
  • Browsing behavior, such as which pages are visited, how long users visit a page, and the navigation paths taken;
  • Device information, such as the type of device (e.g., desktop, mobile), operating system, and browser version user to access the Site; and
  • Technical performance metrics, such as page load times, error logs, and other performance data that help us diagnose issues and optimize the site experience.

• Site/page rating information and feedback provided by users to evaluate and improve the information and performance of the Site, helping NL Health Services manage and improve Site content and deliver a better website experience by enabling NL Health Services to monitor which pages users find useful and which ones they do not.
• Patient feedback provided by users using the Site’s online form for the purposes of managing and resolving patient compliments, concerns or suggestions, as per NL Health Services’ Patient Feedback practices.

NL Health Services uses different methods to collect your Information through this Site, including:

• Direct interactions with you when you provide it to us, for example, by filling in forms or otherwise;
• User contributions. You may also provide Information for us to publish or display on the Site; and
• Automated technologies or interactions, as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and Information collected through cookies.

NL Health Services use cookies, which are small data files that are saved to your device when you visit this Site. Cookies can allow a server to recall previous requests or registration and/or IP addresses to analyze website use patterns. The cookies used on this Site help analyze Site traffic and help us provide you with a better Site experience, by enabling us to monitor which pages you find useful and which you do not and to enable Site management and improvements.

A notice is provided to inform you that NL Health Services uses cookies to enhance your browsing experience, serve geolocation-based information and analyze website traffic. You will have the option to use a “Find Precise Location” button, which uses browser-based geolocation for more accurate results when enabled. You can choose to accept or decline cookies. You can also set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies. If you decline cookies, however, some areas of the Site may not function as intended or at all.

Some content or applications on the Site are served by third-parties, including content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies, to collect Information about you when you use the Site. The Information they collect may be associated with your personal information or they may collect Information, including personal information, about your online activities over time and across different websites and other online services. They may use this information for service improvement as outlined in their privacy policies. You can access these websites to learn more about these collections and uses and/or how to stop websites from placing cookies on your device.

NL Health Services does not control any tracking technologies associated with third-party websites or how they are used. If you have any questions about tracking technology used by such third-parties, you should contact the responsible third-party directly.

The collection, use and/or disclosure of personal information for the purposes as described above is permitted under sections 62(1)(a), 66(1)(b) and 68(1)(b) of ATIPPA. The collection, use and/or disclosure of personal health information for the purposes as described above is permitted under sections 30, 33(1) and 34(a), (c) and (d) of PHIA.

Additional collections, uses, and disclosures of personal and personal health information may be carried out in accordance with your consent or ATIPPA and PHIA. Additional uses and disclosures as required or permitted by law may also occur. Where possible, identifying Information will be removed prior to any such use or disclosure.

All public bodies are required to protect personal and personal health information as set out in ATIPPA and PHIA by applying security controls to protect against risks of unauthorized access, use, or disposal of personal information or personal health information. NL Health Services’ security practices are continually evolving to ensure that the integrity and confidentiality of Information and systems are maintained. NL Health Services use up-to-date security safeguards to protect its networks and websites from misuse, alteration, copying, disclosure, destruction, monitoring or unauthorized sharing of Information and damage. The safeguards deployed include the use of security software and encryption protocols and involve physical, technical and procedural controls to protect Information.

The Internet is not a secure medium and privacy cannot be ensured.  Communication by email over the Internet and other publicly accessible networks is not secure. Any Information that you send by email may be lost, intercepted or altered while it is being transmitted and is at your own risk. NL Health Services also recommends the use of appropriate security, antivirus and other protective software to help reduce internet security risks.

NL Health Services  may transfer the Information collected as described in this Policy to contractors, service providers, and other third parties used to support its operations (such as analytics and search engine providers that assist with Site improvement and optimization) and who are contractually obligated to keep this Information confidential, use it only for the purposes for which it was disclosed to them, and to process the Information with the same standards set out in this Policy.

NL Health Services may process, store, and transfer your Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Information through the laws of the foreign country. However, the privacy and security standards of such service providers shall be required to adhere to applicable Canadian privacy legislation, such as ATIPPA and PHIA.

Questions, concerns, or complaints relating to this Policy or the treatment of your personal information and/or personal health information as described herein should be directed to the NL Health Services Privacy and Access to Information Program by Mail at: 70 O’Leary Avenue, St. John’s, NL, A1B 2C7, or by Email at: privacy@nlhealthservices.ca.

Last Update: March 31, 2025

Originally Published: March 28, 2024