Privacy Policy
EmergConnect Inc. Privacy Policy
EmergConnect Inc. (“EmergConnect”, “we”, “us”, or “our”) is pleased to present our mobile remote triage, intake, individualized emergency department wait-time prediction and clinical direction system (“System”).
We want you to understand our privacy practices, and so, we urge you to read this privacy policy (“Policy”) in order to gain a clear understanding of how we collect, use, transfer and disclose your personal information, including personal health information (“Personal Information”) when you register and input Personal Information into our Mobile Patient Portal (defined below), use our System, or otherwise interact with us.
To register for use of our System through our Mobile Patient Portal, you must provide your express consent to our collection, use, transfer, and disclosure of your Personal Information on behalf of the Hospital EMR as described in this Policy. Where applicable, EmergConnect may also use de-identified and/or aggregated information for research, analytics, system development, and improvement purposes as described in this Policy. When you provide us with your express consent and input Personal Information into our Mobile Patient Portal, use our System, or otherwise interact with us, you consent to EmergConnect’s collection, use, and disclosure of your Personal Information in accordance with the terms of and for the purposes set out in this Policy.
Please review this Policy each time you use our System, as we may update it from time to time.
The following is a short summary of the key elements of this Policy. You can read the full version of the Policy following the summary.
FULL VERSION OF PRIVACY POLICY
This Policy covers the following:
1. Overview of our System
2. Collection of Personal Information and Your Consent
3. Use of Your Personal Information
4. Sharing of Your Personal Information
5. Storage, Retention and Security of Your Personal Information
6. How to access and update your Personal Information
7. How we make updates to this Policy
8. How to contact us for more information
1. OVERVIEW OF OUR SYSTEM
Our mobile remote triage, intake, individualized emergency department wait-time prediction and clinical direction system (“System”) provides individuals with real-time emergency department (“ED”) wait time predictions. We use machine learning to predict individualized ED wait times, allowing patients to comfortably wait at home.
When you use Our System, you will access our mobile patient portal to self-navigate through the registration and triage processes, where we collect necessary data to triage your wait time. (“Mobile Patient Portal”).
In our secure backend System, we temporarily store and analyze your Personal Information in order to conduct remote triage and predict individualized ED wait times. We send information to your hospital’s emergency medical record (“EMR”) system to assist in clinical direct decisions.
Your Personal Information will be sent to the hospital’s EMR system for interaction with clinicians and all identifiable Personal Information will remain under the custody and control of your healthcare provider within the healthcare environment.
This Policy outlines how your Personal Information will be collected, used, transferred, and disclosed in furtherance of our triage System.
With your consent provided when you register to use our Mobile Patient Portal, EmergConnect uses your Personal Information with identifiers removed for research and analytic purposes, as outlined in detail within this Policy.
2. COLLECTION OF PERSONAL INFORMATION AND YOUR CONSENT
Personal Information means any information, recorded in any form, about an identifiable individual or an individual whose identity may be inferred or determined from such information, and includes personal health information, such as information concerning physical or mental health. Personal Information may or may not include business contact information, depending on the jurisdiction.
2.1. Mobile Patient Portal
We interact with Patients on behalf of hospitals via our Mobile Patient Portal. The Mobile Patient Portal is a self-guided triage System which asks you to respond to a series of questions to allow for evaluation of the severity of your condition and other factors that impact ER wait time. We will ask you to provide the following personal information:
a. Preliminary Information
Upon opening the Mobile Patient Portal, you will be provided with an overview of our System including what it does, how it should and should not be used, and what patients are best suited to use it (i.e. non-life-threatening conditions). You will be provided with an overview of the Personal Information you will need to have available and will need to provide in order to work through our triage System, and in what cases you should immediately go to the in-person ED.
Consent: At this preliminary information stage, and before you progress in our triage System or provide any Personal Information, we will seek your consent to use our Mobile Patient Portal and System. You will be required to agree to the terms of this Privacy Policy, our Terms of Use, and our disclaimers and liability waivers.
Research studies: From time to time, a hospital may conduct a research study involving the System at its site. Where a study is being conducted at the hospital you have selected, and where that study has been approved by the hospital’s Research Ethics Board, you will be presented with a separate study consent form describing the study, its purposes, and your rights as a participant. Participation in any such study is entirely voluntary and is not a condition of using the System. You may decline to participate and continue to use the Mobile Patient Portal and System as normal, and you may withdraw your consent to study participation at any time in accordance with the terms of that consent form.
Children: Note that the use of our System is restricted to persons age 16 or older. Patients under the age of 16 may only use this System with the consent of their legal parent or guardian(s).
Please note that it is always your choice whether you provide us with your Personal Information, however, if the Personal Information requested is necessary in order for us to provide our System to you, we will be unable to provide our System without your Personal Information.
b. Risk Rule-Out (i.e. Initial Assessment)
You will be asked a series of questions in an effort to rule out complaints that warrant calling EMS. You will be asked whether you are experiencing any serious complaints, including unconsciousness, serious chest pain or discomfort, severe pain, shortness of breath or dizziness, choking, sever bleeding, trouble seeing or speaking or sudden weakness or numbness; or any high risk and ambiguous complaints, such as chest pain, breathing problems, or an altered level of consciousness. Based on your answers, you may be redirected to either seek help from EMS or register remotely and seek triage in the in-person ED environment.
c. Registration
The following Personal Information will be collected upon registration with the Mobile Patient Portal: first name, last name, date of birth, phone number, mailing address, email address, emergency contact (optional), emergency contact phone number (optional), emergency contact relationship (optional), and family physician (optional).
You (as patient, or parents/guardians, as applicable) are then asked to enter your Ontario health card number. This information is validated through a vendor of record connected to the Ministry of Health database to ensure information provided during registration matches the health card provided. Note that this is done on a voluntary basis.
None of these personal identifiers are stored either within the Mobile Patient Portal or communicated to any server outside of the hospital in which the patient aims to seek care.
d. Triage Questionnaire
The triage process in our remote triage System starts with a triage questionnaire where you are asked clinically relevant yes/no questions. You will be asked to select your sex assigned at birth, your identified gender, and your current age.
You will then be prompted to enter any vital sign metrics that you are able to measure remotely. Specific vital sign metrics include: blood pressure, pulse, respiratory rate, O2 saturation and temperature. If you are unable to measure any or all vital sign metrics using at home vitals metrics devices or smart wearable devices, our Mobile Patient Portal includes qualitative self-assessments related to such unmeasurable vitals.
You will also be asked:
• a series of questions gauging for severe, or uncontrollable bleeding, any pre-existing conditions, recent ED visits or surgery and infectious disease screening; and
• common, clinically relevant questions such as recent ED visits, recent surgery, any medication allergies, and regularly taken medication.
e. Complaint Selection
Our System uses digital technology and artificial intelligence to identify and assess a chief presenting compliant (i.e. the reason for your visit). You will be asked to enter “what complaints are bothering you the most”, or “what brought you into the ED today”. Our natural language search system analyzes what you input, parses the data, and presents all relevant complaints in a categoric fashion. You will then be prompted to select all relevant complaints. A first or second modifier question may be presented to you at such time, which helps to identify and assign the appropriate CTAS score.
Each complaint and modifier combination identified is assigned a triage score using both our stored process lookup table and our pattern directed machine learning triage score prediction system. The triage scores are then compared and the most relevant complaint is selected based on the most severe triage score.
f. Subjective Assessment
Our System captures data around all four categories of inquiry commonly assessed in the in-person triage environment, specifically: (1) your own account of why you are coming into the ED; (2) the symptoms you are experiencing; (3) pain severity, injury history (mechanism of injury) (i.e. you are asked about the type of pain and to rate your pain); and (4) any other concerns you may have (via a free-text option).
g. Clinical Direction
Once triage is complete, low severity patients with lower risk complaints may be offered the option to seek care at a virtual ED or urgent care centre in the same network they selected during registration.
h. Reassessment
Triage reassessment is an automated process within our System that you cannot bypass.
No cookies or tracking technologies are used in the Mobile Patient Portal for purposes other than those necessary to operate and secure the System.
3. USE OF YOUR PERSONAL INFORMATION
The Personal Information we collect will be used for the following purposes:
3.1. To Create a Medical Record in EMR System
As part of the registration process, you will need to provide identifiable information in order for us to create a medical record in the hospital’s EMR. As indicated above, identifiable data collected by us on behalf of the hospital will include your first and last name, date of birth, address, postal code, health card number (optionally), email address and phone number.
This data will be sent through a secure API gateway to the hospital’s local EMR system. Backend data will be linked using participant ID numbers (specifically, randomly generated visitor and patient ID numbers). All identifiable data and linkers will be destroyed 24 hours following patient registration. Following this, all data is irreversibly anonymized and identified through randomized numbers given to each record.
3.2. De-Identification and Use for Study Purpose
By using our System, you expressly consent to the use of your Personal Information to generate de-identified and/or aggregated data that cannot be linked to you or used to identify you. EmergConnect may use de-identified and/or aggregated data for research, analytics, system development, testing, quality improvement, and other purposes described in this Policy.
All patient data is automatically anonymized and used only for further development and testing purposes.
Hard data analysis will be done through the collection and analysis of de-identified patient triage data and analysis system performance. This includes triage, wait-time predictions, and clinical redirections. Triage score (CTAS) consistency, accuracy and distribution (when compared to historic data sets) will be analyzed to make an assessment as to the accuracy of the triage scores assigned. Data surrounding the number of patients with high-risk complaints will also be collected. Demographic information will also be analyzed to look at the populations using the system most often.
• De-identified patient information includes: aggregate data of number of visits, chief complaint(s), patient demographics (age, sex, identified gender, history, medication, etc.), choice of hospitals.
• De-identified individual-level data will be retained for machine learning and accuracy testing purposes including chief complaint(s), patient age, sex, identified gender, self-report pain scale (1-10), vital sign metrics (blood pressure, heart rate, O2 sat, resp. rate, temperature, CTAS score, date of presentation, time of registration, and physician initial assessment (PIA) time (when IAP or first MD signs up for the patient’s chart).
Soft metrics will include user surveys involving feedback as to how the System could be improved for future use. Metrics around provider system improvement will also be collected and analyzed to look at predicted cost savings, time saved for clinicians and improvement to operation efficiency.
Clinicians will also be asked to complete surveys to subjectively assess their perspectives on the accuracy and efficacy of the System. This data will be used to collect key metrics and improvements on both the clinician and patient end of the System. Collecting these key metrics will result in an effective overview of how the System is performing with the general public and internally in the site to gauge efficacy, efficiency, safety, and plan future improvements.
3.3. Communicating With You
We collect your contact information as part of the registration process in order to contact you related to your scheduled arrival time at the ED.
Should you be scheduled to arrive and not arrive within an hour after the predicted physician initial assessment time, the registration clerks or administrative personnel will get in contact with you. First, the Mobile Patient Portal will notify you several times, an automated email will be sent, then up to two phone call attempts will be made, a text message attempt will be made, and finally, clerks will reach out to any outlined emergency contact.
If all contact proves unsuccessful, you will be de-registered from the System.
We will also use the contact information you provide in order to respond to your inquiries, emails or questions.
3.4. Surveys
With your consent, we will use your contact information to send you surveys and seek your input on your experience with our Mobile Patient Portal.
3.5. General
We will use the Personal Information we collect on behalf of the hospital in order to:
• Provide you with our System;
• To investigate, prevent or act on any illegal activities;
• To comply with any applicable law and assist law enforcement agencies as required.
We will use de-identified/aggregated data to:
• To improve the quality and functionality of our System;
• To ensure that our Mobile Patient Portal and System remain functioning and secure.
4. SHARING OF YOUR PERSONAL INFORMATION
4.1. Providers
We only share your Personal Information with:
• the hospital / EMR system you select on whose behalf we are collecting your Personal Information; and
• any other service providers, including individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading of our computer systems.
Under certain circumstances, EmergConnect will be obliged or permitted to disclose your information without your consent:
4.2. Law Enforcement
EmergConnect may disclose Personal Information to third parties without your consent for any of the following reasons: (i) to comply with any law, regulation or order of a court, administrative agency or government tribunal; (ii) to cooperate with Government investigations; (iii) to help prevent fraud or to enforce or protect the rights of EmergConnect or its subsidiaries and to pursue available remedies or limit any damages that we may sustain; or (iv) where it is necessary to protect the rights, privacy, safety or property of an identifiable person or group.
4.3. Other Third Parties
EmergConnect may disclose Personal Information to other third parties without your consent where required or permitted by law, including where: (i) the information is public as permitted by law; (ii) it is necessary to proceed with or complete a “business transaction”, such as purchase and sale of an organization or assets, a merger or amalgamation, making of a loan, charge, lease or licensing, or other prescribed business activity; (iii) it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or (iv) it is necessary to identify an individual who is injured, ill or deceased, or (v) due to an emergency that threatens the life, health or security of an individual.
Where obliged or permitted to disclose information without consent, EmergConnect will not disclose more information than is required. EmergConnect does not disclose your Personal Information to any third party to enable them to market their products or services.
5. STORAGE, RETENTION AND SECURITY OF YOUR PERSONAL INFORMATION
5.1. Storage and Retention:
All patient Personal Information collected via our Mobile Patient Portal is sent through a secure API gateway using a certificate to a database on a secure Amazon Web Services (“AWS”) server located in Canada and to the hospital’s native EMR.
Some of our service providers may be located outside of Canada. Where applicable, your Personal Information may be processed or stored in a foreign jurisdiction and may therefore be subject to the laws of that jurisdiction, including lawful access by government authorities. You may contact EmergConnect for information regarding the jurisdictions in which your Personal Information may be processed or stored.
No patient identifiable Personal Information is stored in the database for more than 24 hours. Where Personal Information is no longer needed, it will be securely destroyed or permanently anonymized or de-identified.
All data will be owned by the care provider at which the patient elects to receive care.
5.2. Security:
We have implemented stringent security protocols in an effort to keep information safe from loss, unauthorized access, modification or disclosure, including, but not limited to managing/restricting access to cloud services, implementing infrastructure security, protecting against DoS and DDoS attacks, firewalls, security monitoring and alerts, secure operating systems, data security (i.e. network isolation, application-level threat protection, server-side encryption), and application/API security.
While EmergConnect endeavours to safeguard all Personal Information we hold, you should be aware that no form of internet transmission or network security is guaranteed to be secure against all forms of threat actors or instruction, and your use of our website, Mobile Patient Portal, System and networks is at your own risk.
6. HOW TO ACCESS AND UPDATE YOUR PERSONAL INFORMATION
Subject to certain exceptions in Canadian privacy legislation, you may have the right to access or correct your Personal Information. Again, all identifiable Personal Information, whether stored by us in transitory form for 24 hours or not, is collected by EmergConnect on behalf of the hospital, and is under the custody or control of the hospital. Accordingly, any requests for access or correction should be directed to the hospital in accordance with their policies.
7. HOW WE MAKE UPDATES TO THIS POLICY
Since EmergConnect regularly reviews all of its policies and procedures, we may change this Policy from time to time. Any changes will be effective upon the amended Policy being posted on the Mobile Patient Portal. We will reflect any such changes or modifications to this Policy on the Mobile Patient Portal and will indicate on the first page of this Policy the date this Policy was last amended. Your continued access to and/or use of our System after any such changes constitute your acceptance of, and agreement to be legally bound by this Policy, as revised. We encourage you to review this Policy each time you use our System.
8. HOW TO CONTACT US FOR MORE INFORMATION
If you have any inquiries or concerns regarding this Privacy Policy or our privacy practices, or to exercise your rights, please contact our Privacy Officer by emailing us at info@emergconnect.ca
RESOLVING PRIVACY CONCERNS
EmergConnect will work with you to resolve any concerns you may have about this Policy or our privacy practices.
If we are unable to resolve your privacy concerns, you have the right to make a complaint to the relevant Information and Privacy Commissioner in your jurisdiction of residence (in Ontario, the Information and Privacy Commissioner of Ontario).
