Foundry BC Platform – Privacy, Collection & Consent

Foundry, a part of Providence Healthcare collects Personal Information from patients and clients under the authority of s. 26 (c) of the Freedom of Information and Protection of Privacy Act. For privacy questions, please contact privacy@providencehealth.bc.ca. For all other questions, please contact info@foundry.bc.ca.

Curious about privacy and confidentiality? You’ve come to the right place! This page will take you through our privacy policy and how we adhere to these guidelines. We acknowledge that much of the language used on this page may be hard to understand. To learn more and understand each section better, click the “+” button.

As a provincial organization that supports you on your mental health & wellness journey, we are committed to maintaining confidentiality and privacy. In order to best support you, we have to collect certain information that lets us know who you are so that we can separate you from others who access our services.

This page will help explain why we collect your information, how long we hold onto it, how we are keeping it safe and confidential, how you can request access to it, and more.

Keep reading!

Foundry (which we may refer to as “we”) is a program within the Providence Health Care Society that provides young people ages 12-24 with access to mental health care, substance use services, primary care, social services and youth and family peer supports. Foundry provides these services through a province-wide network of integrated health and social service centres, and through Foundry Virtual. 

This Privacy Statement, Collection Notice & Service Consent (which we will call the “Privacy Statement” throughout the rest of this document) tells you about the types of personal information we collect, use and disclose when we provide services to you on the Foundry Virtual App.  

This Privacy Statement will also explain: 

• For how long we keep your personal information and why, 

• How we make sure your personal information stays secure and confidential while we have it in our records, 

• How you can access or correct your personal information in our records, 

• How we will destroy your personal information from our records once we no longer need to keep it, and 

• How you can ask questions or make a complaint about anything Foundry does with your personal information.  

When we talk about your “personal information”, what we mean is information that identifies you as an individual that we collect from you, and sometimes from other sources, when you access our services using the Foundry Virtual App  

Certain laws, including British Columbia’s Freedom of Information and Protection of Privacy Act (FIPPA) and Personal Information Protection Act (PIPA), set out the rules for the collection, use, disclosure, security, retention and destruction of your personal information. We strive to follow all of these rules. This Privacy Statement tells you how we do that. So please read this entire Privacy Statement carefully and ask questions if there is anything you don’t understand. You can ask your Foundry Service Provider, or you can contact us using the contact information we have provided at the end of thisPrivacy Statement. 

From time to time, we might make changes to this Privacy Statement. If we do that, we will provide you with a copy of the updated Privacy Statement through the Foundry Virtual App. We will also describe the changes we have made to the old version of the Privacy Statement in a way that is easy for you to understand. We will also ask you to consent to the new version of the Privacy Statement before you can access our services again using the Foundry Virtual App. If you don’t want to give us your consent to the new version, that’s okay, but it does mean that you won’t be able to use the Foundry Virtual App any more. This is because the Privacy Statement is part of the Terms of Use for the Foundry Virtual App. 

What Personal Information do We Collect from You and Why

When you create an account on the Foundry Virtual App or use the Services or Features on the Foundry Virtual App, you are doing so for the purpose of accessing a health service. As a result, we will need to collect your full legal name, date of birth, postal code and Personal Health Number (PHN) in order to create your account to protect your identity and to ensure that no one else is impersonating you. If you don’t know your PHN, we can use your name and other information to locate your PHN using the BC Ministry of Health’s HealthNet database.   

Once your Foundry Virtual App account is established and you begin to receive our services, we collect personal information, including your personal health information, in and use that information for a number of purposes: 

• Your Foundry Service Provider will collect the information you provide during your service appointments in order to provide the services that you have requested from Foundry. Your Foundry Service Provider will document information relating to your service appointments in the Foundry electronic medical record (EMR) system. Your information on the EMR will remain there indefinitely. 

• There may be cases where your Foundry Service Provider may copy the chat transcript from your session with them into the EMR. For example, the chat transcript may be copied to the EMR when the session is conducted by “chat only”, and does not include video or audio contact between you and the Foundry Service Provider. In addition, no matter how the session is conducted, your Foundry Service Provider may copy all or a portion of the chat transcript to the EMR if the chat transcript contains important information that could be used to better or more appropriately support you in future sessions. The chat transcript will only be accessed if and when needed to support you better, or if we must access it in order to comply with a legal obligation to disclose information (for example, where we believe you might harm yourself or others, or where a court order requires us to disclose your information). 

• Information about how you use the Foundry Virtual App (for example, which features you use and how) will be collected in two ways: (a) automatically through the use of an audit log and ananalytics tool, and (b) directly by asking you to fill in information and surveys/questionnaires.  

On registration on the app, your information will be automatically transferred to and saved in Foundry’s data collection platform called Toolbox. Your information will remain on Toolbox indefinitely, even after your account is deleted for if and when you access a Foundry service again.  

Your information may also be used to evaluate and improve Foundry Services or for approved research projects that have been properly vetted by a research ethics committee. Wherever possible, your information will be de-identified before it is used for these purposes. Where, however, the program evaluation or research cannot be carried out using de-identified information, we will still ensure that the results of any such program evaluation or research project cannot be used to identify you before we share those results with anyone. 

On deletion of your account, you can withdraw consent from your information being stored on Toolbox by contacting datamanager@foundrybc.ca. When emailing this address, please insert “Consent Withdrawal” in the subject line of the email, and please provide your first name , last name and DOB in the body of the email. On receiving this we will scrub all identifying or personal information that we have on you but we will continue to keep deidentified information. 

Please read and understand each statement. In these statements, please note that “I”, “my” and “me” refers to you as the individual who is being asked to read and understand:  

• My privacy will be respected. I understand that Foundry may connect with those health-care providers actively participating in my care to receive or share limited information to ensure I receive safe and excellent care. Information will be shared wisely and within legal and ethical bounds to ensure I receive the best support possible at Foundry.  

• I understand that notes regarding my service will be kept on an electronic medical record on a secure web-based system. If at any point I would like to retrieve my medical records, I will inform my service provider or I will submit a request to Foundry using the contact information at the end of this Privacy Statement. 

• There are a few legal exceptions to confidentiality, such as if my Foundry Service Provider is concerned about my safety or the safety of someone else. In these instances, I understand that my Foundry Service Provider will try to talk to me first about what needs to happen and additional supports I may need to help me be safe. If necessary, my Foundry Service Provider may need to pass on my contact information to authorities who can help protect me and/or others, such as a crisis service or the police. I understand that, where possible, my Foundry Service Provider will let meknow if his or her concerns reach the point where he or she needs to involve other services. 

• If a legal authority (e.g., a court order, or a law that gives someone the right to demand disclosure) requires Foundry to release my records to someone other than me, Foundry is obligated to comply with this requirement. 

• I understand that, except where Foundry has a legal obligation to share my information whether I consent to such sharing or not, I can withdraw my consent for Foundry to share information at any time by informing my Foundry Service Provider involved in my care that I wish to do so.

Security and Confidentiality 

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information you submit to us. We use strict internal procedures and technical security features to try to prevent unauthorized access, use or disclosure of your personal information.  If you have any questions about the security of your personal information, you can contact us using the contact information at the end of this Privacy Statement. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted using the Foundry Virtual App and any such transmission is at your own risk. 

In addition, ensuring the security and confidentiality of your personal information is a responsibility that we share with you. Your use of the Foundry Virtual App should take place in an appropriatelyprivate space to ensure that you cannot be overseen or overheard.

Please also note the following: 

• You are responsible for the security of your own computer/tablet/mobile/device, email service and WiFi.  

• Although security measures, such as encryption, may be used to safeguard communications, PHC cannot guarantee the security of the information you share over the internet.  

• Like other mobile applications, the Foundry Virtual App will require permissions to access content on your phone or computer to function. For example, permission to access the camera and microphone enables users to have the video appointment. These applications may also collect personal information such as your first name, last name, email address as well as your device and internet connection (e.g., IP address) in order to provide their services.

Accuracy of and Access to Your Personal Information 

We make reasonable efforts to ensure that your personal information that we collect, use and disclose in accordance with this Privacy Statement is accurate and complete. We need your help to accomplish this. Given that in the vast majority of cases we will collect your personal information directly from you, we rely on you to provide us with accurate information, and to update that information as and when needed. 

Whether or not we have collected your personal information directly from you, you have the right to request access to that information and to request that we correct any errors in or omissions from that information. If your request for correction is reasonable, and subject to any legal obligations we might have that require us not to correct the information (e.g., we cannot correct a healthcare professional’s clinical opinions), we will correct the information. If your request for correction is not reasonable, or cannot be granted for any other reason, we will in any event include a note in the file where the information is held to show that a request for correction was made, but not implemented. 

Email 

Information sent to our email address over the Internet is not secure. This means that if the visitor uses the e-mail address published on the app, to send an email, the information provided may be intercepted as it travels to us. We will not be responsible for any damages suffered by individuals as a result of the transmission and information that is sent to us or for any errors or changes made to transmitted information. 

Contact us 

For questions, or to make a complaint, about our collection, use or disclosure or your personal information, or the content of this policy, or to request access to or correction of your personal information in our records, please contact online@foundrybc.ca  

Contact the OIPC 

If you feel that we have not answered your questions, or dealt with your complaint, in an appropriate manner, you may contact the Office of the Information and Privacy Commissioner for British Columbia (“OIPC”) for further assistance. The OIPC is responsible for ensuring that we comply with FIPPA and PIPA.  

Address: PO Box 9038 Stn. Prov. Govt. 

Victoria, BC V8W 9A4 

Telephone: 250-387-5629 (or call Enquiry BC at 604-660-2421 or 1-800-663-7867 and request a transfer to the OIPC) 

Fax: 250-387-1696 

Email: info@oipc.bc.ca 

Version date: 15 Jan 2020 

Definitions

1. Personal Information: This will be a link on click of which the following should populate: personal information would include, but is not limited to, things such as  an individual’s name, address, birth date, e-mail address, phone number and care card number.
2. Analytic Tool: the app uses an analytics tool called Elk stack that collects information around  

• •  what features of the tool you have accessed 

• •  how long you have spent using a feature, etc. 

• • What actions you have performed on each page 

This helps us understand what features young people are finding useful and how that may be changing with time. This allows us to continue to change/improve our services to meet the changing needs of our young people. Elk Stack would also collect your IP address as this would help us understand locations from where the app is being accessed. This information becomes important for us to be able to measure app reach as one of the goals of this app is to meet the needs of rural and remote communities. 

1. Contact us at online@foundrybc.ca 
2. healthnetBC: The healthnetBC is an interface enables access to the Ministry’s databases that contains some of your personal information such as PHN, DOB, legal name, etc. by external agencies, either via the Internet or an integrated software system.
3. De-identified: which means the removal from a record of any information that identifies you, such as your name, address, phone number, PHN, etc., so that you cannot be identified from the record, either alone or when linked with other records or information.