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Privacy Policy

 

1. Our Role as a Custodian

Under the HIA, Holistic Harmony TCM acts as the Custodian of your health information. We are responsible for all patient records in our possession and have established rigid policies and procedures to ensure your privacy is maintained. Any staff members, practitioners or contractors working under our clinic operate as Affiliates and are legally bound by these same strict privacy standards.

2. Information We Collect

We limit the amount and type of health information we collect to only what is essential for providing your care. This includes:

  • Registration information: Your name, date of birth, address, phone number, email address, and emergency contact details.

  • Diagnostic, Treatment and Care information: Health History, symptoms, acupuncture treatment plans, clinical charts, and progress notes collected during your intake or appointments.

  • Technical Website Data: Standard internet log information automatically collected when you browse our website (e.g. your IP address and browser type)

3. How we Use and Disclose Your Information

We will only collect, use, and disclose your health information for the primary purpose of providing you with health services, or as otherwise permitted or required by the HIA.

  • Appointment & Care Management: We use your data to schedule appointments, send text/email reminders, and manage your treatment plans via Jane App.

  • Third Party Disclosures: We will no disclose your health information to thirst parties (such as insurance companies or legal counsel) without your explicit, written consent, unless legally mandated to do so under Alberta law. You may withdraw your consent at any time.

4. Our Relationship with Jane App (Information Manager)

We utilize Jane App as our secure Electronic Medical Record (EMR) and online booking platform. Under HIA terminology, Jane App acts as our Information Manager.

  • Jane App processes and stores your patient data strictly on our instructions; they do not own, sell, or trade your data

  • Patient data is stored securely within Canadian Data Centers.

  • Financial transactions via the booking portal are processed using a secure, PCI-compliant payment partner (Jane Payments/Stripe). Your full credit card data is never stored directly on our or Jane App’s servers.

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5. Safeguards and Security

In accordance with HIA Section 60, we maintain administrative, technical and physical safeguards to protect your health information from unauthorized access, use, modification, or destruction.

  • Technical: All data transmitted between your browser and Jane App is fully encrypted using bank-grade SSL/TLS security protocols. Access to our systems requires unique authenticated user credentials and involves activity logging/auditing.

  • Mandatory Breach Notification: In the highly unlikely even of a data breach onvoloving risk of harm to you, we are legally required under the HIA to notify you, the Minister of Health, and the Office of Information and Privacy Commissioner (OIPC) of Alberta as soon as practicable.

6. Retention and Destruction of Records

We retain your health information and clinical charts in accordance with provincial regulations and the professional standards set out by our regulatory college (e.g. the College of Acupuncturists of Alberta). Health records are securely maintained for the legally required duration (typically 10 years past the date of the last treatment or longer for minors) and are securely destroyed thereafter.

7. Your Rights: Access and Correction

Under the HIA, you have the right to request access to your health information record or request a correction if you believe there is an error.

  • To request a copy of your records, you must submit a request in writing to our clinic.

  • We will respond to your request within 30 days, as required by law. A standard administrative fee may apply for producing copies of your records.

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