Privacy Policy

We collect only the Personal Information necessary to fulfill the specific purpose for which it is collected, based on the nature of your interaction with us. We may collect Personal Information through our Websites, in the course of providing our Services, or through our interaction with you. We collect, use, and disclose your Personal Information with your express or implied consent, unless otherwise permitted or required by applicable law.

• Collection of Personal Information. We collect, use, and disclose your Personal Information with your express or implied consent, unless otherwise permitted or required by applicable law
• Personal Information you Share. When you choose to share your Personal Information with us through our Websites or Services, it may include your full name, contact information, and any other information you voluntarily submit. We use Personal Information you share with us to facilitate your use of our Services.
• Services. We may collect and process your Personal Information in connection with clinical trials, health programs, and related services. This information may be provided directly by you or collected through testing, samples, external health care services (for example, laboratories) or institutions without direct involvement from you, provided appropriate authorizations have been obtained. If you choose to participate in a clinical trial, you will receive an informed consent form outlining the types of information collected, the purpose for which it is being collected, and the parties with whom it may be shared. We use this information to conduct and support the clinical trial, monitor participant safety, evaluate the effectiveness of the investigational treatment, comply with legal and regulatory obligations, and improve the quality and delivery of health services.
• SMS Communication. If you choose to provide us with your mobile phone number, we may communicate with you via SMS in connection with your participation in clinical research or your use of our Services. These communications may include appointment reminders, study-related updates, or follow-up communications designed to support your experience or address any questions or concerns. For individuals residing in Quebec, SMS communications may be provided in French or in your language of preference. We use this information to facilitate timely and effective communication, enhance your engagement in the research process, ensure you have access to relevant information, and help you stay informed and supported throughout your participation. You may withdraw from SMS Communication.
• Personal Information Collected Automatically. When you visit our Websites, certain information may be collected automatically through your browser or device, such as your IP address, browser type, and how you interact with the site.
  • Website Usage. When you visit our Websites, certain information may be collected automatically from your browser or device that may include your Internet Protocol (IP) address, browser type and version, the pages you visit, the time and duration of your visit, and other technical or usage details. We use this information to maintain the security and performance of our Websites, to better understand how visitors engage with our content, and to improve the accessibility and effectiveness of our digital Services.
  • Cookies and Tracking Technologies. We use cookies and similar tracking technologies to enhance the user experience, provide you with more relevant content, monitor website functionality, and assess and improve the effectiveness of our Services. A cookie is a small text file sent to your device when you visit a website, allowing the site to recognize your browser on return visits. Cookies may store your preferences and other information. If you prefer not to use cookies when you interact with our Websites or the Services, you may decline to provide consent when prompted.
  • Third-Party Analytics. We may use trusted third-party service providers to assist with website analytics to support the optimization of our Websites and Services. These providers may use cookies or other tracking tools to collect aggregated, non-identifying data. If you prefer not to have your website usage tracked by third parties, you can install a browser opt-out tool or adjust your cookie preferences.
• Recruitment and Hiring. For more information about Care Access’s recruitment and hiring activities as they relate to your Personal Information, please refer to Section 4.

We collect only the Personal Information necessary to fulfill the specific purpose for which it is collected, based on the nature of your interaction with us. We may collect Personal Information through our Websites, in the course of providing our Services, or through our interaction with you. We collect, use, and disclose your Personal Information with your express or implied consent, unless otherwise permitted or required by applicable law.

• Service Providers. We may engage third-party service providers to perform functions on our behalf in connection with the delivery, maintenance, or improvement of our Websites and Services. These functions may include the processing, storage, or management of Personal Information. All service providers are contractually obligated to handle Personal Information in a manner that is consistent with this Privacy Policy and/or applicable law and solely in accordance with our documented instructions. Service providers are strictly prohibited from using Personal Information for any purpose other than the one for which it was provided, and must securely delete or return all Personal Information upon completion of the purpose. For a list our current service providers, please visit careaccess.com/sub-processors.
• Partners. At times, we may collaborate with trusted third-party partners to deliver or support certain aspects of our Services. For example, we may work with community organizations, healthcare institutions, or academic partners to facilitate clinical research, recruit participants, or deliver health-related programs. Any partner involved in handling Personal Information is required to do so in a manner consistent with this Privacy Policy and applicable privacy obligations.
• Compelled Disclosure. We may disclose your Personal Information if we are required to do so by law or pursuant to valid legal processes, such as a subpoena, court order, or warrant. We may also disclose your Personal Information where we believe such disclosure is necessary to comply with legal or regulatory obligations, to protect or defend our legal rights, to prevent fraud or abuse, or to protect the safety of individuals. Any such disclosure will be limited to the extent necessary to comply with the applicable obligation or request.
• Change of Ownership or Control. In the event of a merger, acquisition, restructuring, or other corporate transaction, your Personal Information may be transferred as part of the transaction, subject to appropriate confidentiality and data protection obligations. Where required by applicable law, we will provide notice and, if necessary, obtain your consent prior to any such transfer. Any recipient of Personal Information will be required to handle such information in a manner consistent with this Privacy Policy and applicable privacy obligations.
• No Sale or Unauthorized Disclosures. We do not sell your Personal Information. We also do not share your Personal Information with unaffiliated third parties for their marketing or promotional purposes without your explicit consent. Any use or disclosure of your Personal Information for such purposes will only occur where you have been clearly informed and have provided affirmative authorization.

We retain Personal Information only for as long as necessary to fulfill the purpose for which it was collected, including to meet legal, regulatory, or operational requirements. The duration of retention may vary depending on the type of information, the nature of our relationship with you, and applicable legal or contractual obligations.

We take reasonable steps to ensure that your Personal Information in our custody or control is accurate, complete, and current. When your Personal Information is no longer required for the purposes for which it was collected or to satisfy legal or regulatory obligations, it is securely destroyed or de-identified using safeguards appropriate to its sensitivity and format to help ensure its continued protection.

This section applies only to the processing of your Personal Information collected in connection with your candidacy for employment or engagement as a contractor with Care Access Canada (“Employment Information”).

• Collection and Use of your Personal Information. We may collect, use, and process your Employment Information to evaluate your suitability for employment or contractual engagement. Your Employment Information may be collected directly from you, through recruitment platforms, professional recruitment firms, or from publicly available sources, and may include:
  • Identity Verification. We may process your name, home address, email address, phone number, date of birth, gender, and emergency contact details to confirm your identity using government-issued identification or similar documentation.
  • National Identifiers and Work Eligibility. We may process your Social Insurance Number (SIN), passport details, immigration documentation, citizenship and residency status, work permit, and visa information to confirm your legal eligibility to work in Canada.
  • Educational and Professional Background. We may process your academic qualifications, professional certifications, résumé or curriculum vitae, reference letters, and publicly available professional information to verify your credentials and assess your suitability for the position, including validation of academic achievements, employment history, licensure, and other relevant qualifications.
  • Sensitive Information. We may process health-related information, including information about disabilities, to identify and implement reasonable workplace accommodations.
  • Criminal Background and Vulnerable Sector Checks. We may conduct criminal background checks to assess your suitability for specific roles and to help ensure a safe, secure, and compliant working environment. For positions that involve direct interaction with vulnerable individuals, such as children, seniors, or persons with disabilities, we may conduct vulnerable sector checks as required or authorized under applicable laws and regulations.
  • Automated-Decision Making. We may use pre-screening tools and other assessment methods, including, where permitted by law, automated decision-making tools, to evaluate qualifications, assess job fit, and support a fair, transparent, and consistent recruitment process. Where applicable, individuals will be informed of the use of such tools and may request additional information.
  • Future Opportunities. With your consent, we may retain your Employment Information to consider you for future opportunities.
• Sharing of your Personal Information. We may share your Employment Information with (a) internal personnel involved in the hiring process, such as human resources staff and hiring managers, (b) authorized third-party service providers who support our recruitment, screenings, or talent acquisitions, (c) affiliates and subsidiaries of Care Access Canada for internal business operations, recruitment coordination, and lawful processing activities, (d) regulatory bodies, licensing authorities, or government agencies to ensure compliance with applicable laws and regulations, (e) third parties in connection with a corporate transaction, such as a merger, acquisition, restructuring, or other corporate reorganization, and (f) other parties, with your consent. All such disclosures are subject to appropriate, contractually binding data protection obligations designed to ensure the confidentiality, integrity, and security of your Employment Information. These obligations require third parties to handle your Employment Information solely for the purposes for which it was shared, implement adequate technical and organizational safeguards, and comply with all applicable laws and this Privacy Policy.
• Retention. We retain your Employment Information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws, regulations, and internal records management policies. If your application is unsuccessful, your Employment Information will be securely deleted or de-identified, unless you have provided explicit consent for us to retain it for consideration in future opportunities. If you are hired, your Employment Information will become part of your personnel file and will be managed in accordance with our employee privacy policies and applicable retention practices.

• 4.1 INTERPRETATION – EMPLOYMENT INFORMATION. For purposes of Sections 5 through 9 of this Privacy Policy, references to “Personal Information” includes “Employment Information.”

Your Personal Information may be transferred to, stored in, and processed outside of Canada in connection with your use of our Websites and Services. We implement appropriate contractual, technical, and organizational safeguards to ensure that your Personal Information remains protected and is handled in a manner consistent with Canadian privacy principles.

We implement reasonable and appropriate administrative, physical, and technical safeguards to protect your Personal Information against loss, theft, unauthorized access, disclosure, alteration, or destruction. These safeguards are designed with consideration for the sensitivity of the information, the nature of the processing activities, and the potential risks involved. While no system can guarantee absolute security, we continuously assess and update our safeguards to align with evolving industry standards and applicable data protection laws, helping to ensure the integrity and confidentiality of the Personal Information collected through our Websites and Services.

• Access to your Personal Information. You have the right to request access to the Personal Information we hold about you. Upon receiving such a request, we will confirm whether we hold any Personal Information about you and, where feasible, disclose the source of that information. We will also provide details regarding the purposes for which the information has been used and the third parties to whom it has been disclosed.
  • Exceptions to Access. In certain circumstances, we may not be able to provide access to all of your Personal Information. These exceptions are limited and specific, and may include situations where the information: (a) references other individuals; (b) is subject to legal or litigation privilege; (c) contains confidential commercial information; (d) cannot be disclosed for legal or security reasons; and (e) is prohibitively costly to retrieve, If we must deny access, we will provide you with an explanation, unless prohibited by law.
  • Identity Verification. In order to locate your information and safeguard your privacy, we may require additional details to verify your identity. Any information you provide for this purpose will be used solely to process your request.
• Right to Request Corrections. If you believe that any Personal Information we hold about you is inaccurate or incomplete, you have the right to request an amendment. Where appropriate, we will also notify any third parties to whom the original information was disclosed of the amendment.
  • Unresolved Challenges. If you challenge the accuracy of your information and the issue is not resolved to your satisfaction, we will make a note of the unresolved challenge in our records. Where appropriate, we will also notify any third parties who have accessed the contested information.
• Withdrawal of Consent. We rely on your knowledge and consent to collect, use, and disclose your Personal Information, except where otherwise permitted or required by law. Consent may be express or implied, depending on the nature and sensitivity of the information and the context in which it is collected. We make reasonable efforts to ensure that you are informed of the purposes for which your Personal Information is collected, used, or disclosed at the time of collection, or before any new use not previously identified.
• You have the right to withdraw your consent to the collection, use, or disclosure of your Personal Information at any time, subject to legal or contractual restrictions and the provision of reasonable notice. Upon receiving your withdrawal request, we will inform you of any potential implications, such as impacts on your ability to access certain services, and take appropriate steps to cease the applicable processing activities.
• Please note that in certain limited circumstances, we may collect, use, or disclose your Personal Information without your knowledge or consent, including for legal, medical, or security reasons, or where obtaining consent would be impractical or inappropriate.
• Response Time and Cost. We strive to respond to access requests within a reasonable timeframe and at minimal or no cost to you. When applicable, we will ensure the information is provided in a clear and comprehensible format, including explanations of any codes or abbreviations.

We are committed to upholding the highest standards of data protection and ensuring that your privacy rights are respected through clear, responsible, and lawful handling of your Personal Information. If you have concerns about how your Personal Information is being handled, you have the right to challenge our compliance with this Privacy Policy or applicable privacy laws.

You may direct any questions, concerns, or complaints regarding our privacy practices to our Data Protection Officer at privacyofficer@careaccess.com.

Individuals who submit a complaint or inquiry will be informed of the existence of our complaint-handling procedures and any applicable external mechanisms for review. All complaints will be addressed in a timely and impartial manner. If a complaint is found to be valid, we will take appropriate corrective action, which may include modifying our privacy policies or practices to ensure continued compliance.

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable laws. The “Effective Date” at the top of this Privacy Policy indicates the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed on how we handle and protect your Personal Information.