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GOVERNANCE POLICY REGARDING PERSONAL INFORMATION (PI) HELD BY THE LACROIX MEDICAL GROUP AND PRIVACY POLICY

PREAMBLE:

Clinique Médicale Lacroix Inc., Lacroix Chirurgie Privée Montréal Inc., Lacroix Chirurgie Privée Québec Inc. and Lacroix Labo Privé Inc. are related corporations that collectively form the Groupe Médical Lacroix, hereinafter referred to as the “Lacroix Medical Group.”

In connection with its activities, the Lacroix Medical Group collects and uses personal information about patients and users who require its services.

The Lacroix Medical Group is subject to the Act respecting the Protection of Personal Information in the Private Sector (the "Act"). Therefore, the Lacroix Medical Group is responsible for protecting the personal information that it holds and for complying with the Act.

This Policy aims to ensure the protection of personal information and provide guidelines on how the Lacroix Medical Group collects, uses, discloses, keeps and destroys this information. It also aims to provide information to interested parties on how the Lacroix Medical Group handles their personal information.

Although automatically collected information may not generally be considered personal information, because it is not collected in such a way that makes it possible to identify you personally, Appendix "B" of this Policy also provides information to interested parties on the Lacroix Medical Group's practices with respect to automatically collected information.

DEFINITIONS:

Personal information (hereinafter “PI”) is information that relates to a natural person and allows that person to be identified either directly or indirectly. For example, here are the types of PI that the Lacroix Medical Group may collect about certain individuals:

  • name and contact information;

  • home and email addresses;

  • telephone number;

  • first and last names of the parents;

  • demographic data (gender, date of birth);

  • billing information;

  • membership status.

Sensitive personal information (hereinafter "Sensitive PI") is information that raises a high degree of reasonable expectation of privacy due to its specifically medical, biometric or otherwise private nature. For example, these are the types of Sensitive PR that the Lacroix Medical Group may collect about certain individuals:

  • medical record and notes;

  • health insurance number;

  • criminal background information;

  • health status;

  • medical examination results;

  • list of medications

  • social insurance number (for employees only).

APPLICATION

This Policy applies to senior management, employees, consultants, suppliers and all other subcontractors who represent or work for the Lacroix Medical Group.

It targets all types of PI and Sensitive PI that the Lacroix Medical Group collects, manages and uses, including the PI and Sensitive PI of its patients, employees, subcontractors and consultants, as described in Appendix “A” of this Policy.