Last Updated: April 17, 2019
Layla Care Inc. (“Layla”, “we” or “us”) values the relationship it has with its clients and is committed to protecting their Personal Information (as defined below in Section III, “Definitions”) in accordance with applicable laws. When used herein, the term “client” means any individual who is receiving or has signed up or requested to receive the Layla Services (defined below).
Layla is not itself a healthcare provider. Included in the services that Layla provides is the provision of assistance to individuals to find, choose, and facilitate access to therapists based on individuals’:
• current situation and goals for therapy;
• Insurance coverage considerations;
• scheduling and logistical preferences; and
• therapist preferences
(the “Layla Services”).
• Personal Information provided by clients to a Therapist directly or indirectly through the Therapist’s employees or agents;
• any third party websites, including any websites linked from the Layla Website. Clients are responsible for reviewing the privacy policies (if any) of any such third parties. Layla has no control over, and disclaims any and all responsibility for, the content, privacy policies or practices of any such third-party websites.
“collect” means to gather, acquire, receive or obtain Personal Information by any means from any source, and “collection” has a corresponding meaning.
“consent” means voluntary agreement to the collection, use and/or disclosure of Personal Information for identified purposes. Consent can be either “express” or “implied” and can be provided directly by the individual or by an authorized representative. “Express” consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Layla. “Implied” consent is consent that can reasonably be inferred from an individual’s action or inaction.
“disclose” means to release or make available Personal Information that is in the custody or control of Layla to another person who is not using the Personal Information as an agent of Layla, and “disclosure” has a corresponding meaning.
“Personal Information” means information about a specific, identifiable individual, regardless of form, including, for example, name, date of birth, address, and medical history, but does not include, for example, information related to a person in their professional (work) capacity.
“use” means to handle or deal with Personal Information that is in the custody or control of Layla, and includes transferring the information to an agent acting on behalf of Layla.
IV. Collection of Personal Information by Layla
Layla may collect the following Personal Information from clients:
• name, contact information (including home address and email address), date of birth, medical history (including diagnoses and medication history), religious affiliation(s), gender, employment status, family physicians and other healthcare providers, and certain other Personal Information about the client
• credit card information and/or bank account information (where provided to us for the purposes of paying for the Layla Services); and
• other identifying information about the client that we did not request but that is provided by the client or any other person authorized to provide such information on the client’s behalf.
We will always collect Personal Information by fair and lawful means. We may collect Personal Information from clients directly and/or from third parties, where we (and/or those third parties) have obtained the client’s consent to do so, or as otherwise required or permitted by applicable law.
Generally, however, we collect Personal Information directly from clients when they voluntarily provide it in the course of accessing the Layla Services. For example, Personal Information will be collected when a client:
• completes a client profile / intake form; and
• communicates with representatives of the Layla, via telephone, email or mail.
Therapists will not disclose client’s Personal Information to Layla, and Layla will not collect Personal Information from Therapists.
V. How We Use Client’s Personal Information
We use client’s Personal Information for the following purposes:
• to plan and monitor the Layla Services;
• for quality control purposes;
• for billing purposes;
• to communicate with Therapists and their agents (as defined by applicable privacy legislation) about the client in order to determine whether the client will be matched with the Therapist and if so, to provide the Therapist with information to assist in their provision of services (e.g. psychotherapy, counselling) to the client; and
• to de-identify it (i.e. make it so that it is no longer identifies a client). Layla may use de-identified information (i.e. information that is no longer Personal Information) for any reason it determines appropriate.
From time to time and in addition to the Therapists, we may retain third party individuals or companies act as service providers to assist us in the provision of the Layla Services, or to perform certain tasks related to our business operations such as to provide audit, legal, consulting, operational or other services to us. Any such service providers will be subject to any restrictions and conditions that are necessary to enable Layla to continue to provide the Layla Services in accordance with applicable law.
VI. Access to Client’s Personal Information
VII. Disclosure of Personal Information
We identify to whom, and for what purposes, we may disclose Personal Information, at the time we collect such information from the client to whom it relates and obtain such client’s consent to such disclosure except as required or permitted by applicable law. For example, in accordance with section 7(2)(b) of PIPEDA, Layla may - without the knowledge or consent of the client - use the client’s Personal Information for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual. In the event that we are required by applicable law to disclose a client’s Personal Information without their consent, we will aim to disclose only the specific information that is required in the circumstances and unless prohibited by applicable law from doing so, will inform the client about the disclosure.
VIII. Security and Safeguards
Information that we collect is stored on servers located in Canada. Layla uses standard security procedures and practices and other reasonable means appropriate to the nature of the Personal Information to protect it from theft, loss or unauthorized access, use (including modification and copying), disclosure or destruction.
IX. Retention of Personal Information
We will use, disclose or retain Personal Information that clients provide to us for as long as necessary to fulfill the purposes for which that Personal Information was collected, and as permitted or required by applicable law.
XI. Access, Correction, or Other Requests
Our Chief Privacy Officer can be contacted as follows: Email: firstname.lastname@example.org, Telephone: 1.888.695.2952