Privacy – Wagon
EHN Outpatient Services Inc. Privacy Policy
Effective: February 7th, 2017
Last Modified Date: Dec. 15, 2022
Click here to view the December 2023 EHN Outpatient Services Privacy Impact Assessment Summary
EHN Outpatient Services Inc.’s system consists of two services: the Wagon app and online treatment programs. The Wagon app and online treatment programs are provided to you through EHN Outpatient Services Inc. This Privacy Policy governs how EHN Outpatient Services Inc. and the Wagon app collect, use, disclose, and otherwise manage your personal information, including personal health information, when applicable.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING THE WAGON APP OR ENROLLING IN AN ONLINE TREATMENT PROGRAM, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND THE TERMS OF SERVICE.
EHN Outpatient Services Inc. does collect information from you.
EHN Outpatient Services Inc. collects different information from you depending on whether you use the Wagon app, enroll in one or more treatment programs provided by EHN Outpatient Services Inc., or both.
The Wagon app collects your name, address, and email address when you set up your online profile and recovery plan. The Wagon app also collects information when you log your goal completions, emotions, triggers and behaviours using the app. Wagon securely transmits and stores this data, leveraging Microsoft’s Azure Cloud Computing Platform. The Wagon app may also collect and compile progress statistics on your goal completions, emotions, triggers, and other behaviour.
The Wagon app transmits your data to EHN Outpatient Services Inc., allowing said company to provide counselling and guidance based on this data.
If you enroll in the online treatment programs offered and delivered by EHN Outpatient Services Inc. (online Aftercare, Group Therapy, Coaching, Individual Counselling, or an Intensive Outpatient Program), your counsellor may also collect personal information provided by you during enrollment or shared by you during your therapy sessions. This personal information may include your home address, phone number, employer, gender, credit card information for payment; information or records regarding your medical or health history; previous treatment and counselling services; health status and laboratory testing results; current and previous medications; and other identifying and health related information. Your personal information may be contained in medical records, treatment and examination notes, and other health related records maintained by your counsellor. All personal information collected during your enrollment or therapy sessions is stored and maintained in a secure storage system.
EHN Outpatient Services Inc. stores your information only for as long as it is necessary to provide services to you and for legal protections or as required by applicable laws and regulations.
What EHN Outpatient Services Inc. doesn’t do
The Wagon app does not collect health or medical data such as diagnosis, age, weight, medications, etc.
EHN Outpatient Services Inc. collects personal health and medical information from you only if you enroll in an online treatment program offered through EHN Outpatient Services Inc.
EHN Outpatient Services Inc. does not predict health outcomes such as sobriety or relapse.
The Wagon app does not act as a crisis line, and cannot be relied upon in an emergency situation.
The Wagon app does not store geographical data or send geographical data to the company or institution providing the Wagon app to the user.
EHN Outpatient Services Inc. uses information as disclosed and described below:
Neither EHN Outpatient Services Inc. nor EHN Canada counsellors uses or discloses personal information for any other purpose than to help you achieve long-term recovery.
We use information to respond to your needs, requests, or questions. We may use your information to respond to your feedback also.
We may disclose your information among counsellors and support staff for the purposes of improving our services to you.
We also use your information to improve the Wagon app and the services we provide. We may use your information to customize your experience with us, in an effort to provide better support for your goals.
We use information to communicate with you. We may communicate with you about your account or in response to your progress or behaviour. We may use push notifications in the Wagon app. These may include tips and strategies to help you reach your goals and identify triggers and behaviours. Your counsellor may also use the app to communicate with you.
We may use the email address or phone number you provided during enrollment to periodically response to and support your recovery progress. Your email address is not used for any other purpose and is not shared with outside parties.
We will use information as otherwise permitted by law, or as we may notify you.
EHN Outpatient Services Inc. shares some information with third parties.
We will share information with third parties who may perform services on our behalf. For example, we may use service providers to process payments, host our website, and store information on our behalf.
As the provider of your treatment, EHN Outpatient Services Inc. will not willingly release any information concerning you outside EHN Canada’s facilities and clinics, without your written consent.
We will share information if we are required to comply with the law or to protect our company. We will supply information if requested by court subpoena or court order; if a government or investigatory agency requests. We may share info if we are investigating a potential fraud.
We will share information for other reasons that we may inform you about.
You have a say in how EHN Outpatient Services Inc. uses some of your information.
You can turn off push notifications for the Wagon app on your phone. You can also decide to opt out of emails that you don’t want to receive.
EHN Outpatient Services Inc. uses standard security measures to protect data.
We understand that data security is a critical issue for you and we are committed to safeguarding your personal information in our custody and under our control.
EHN Outpatient Services Inc. has implemented a comprehensive information security program that includes written policies and procedures, and security controls. We have implemented reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control.
EHN Outpatient Services Inc. adheres to the regulations and privacy practises of the province or territory in which clients resides when collecting, using, and disclosing their PI and PHI.
Our privacy practices are intended to comply with applicable privacy laws, including, without limitation, the Personal Health Information Protection Act (Ontario) (“PHIPA”), the Personal Information Protection Act (Alberta and British Columbia) (“PIPA”), the Health Information Act (Alberta) (“HIA”), the Personal Information Protection and Electronic Documents Act (Northwest Territories) (“PIPEDA”), and the Act Respecting the Protection of Personal Information in the Private Sector (Quebec). We will maintain the privacy of your personal information as required by applicable privacy laws, including without limitation, PHIPA, PIPA, HIA, and PIPEDA and the regulations under those Acts.
Complex passwords are required for all users to access the Wagon app, including developers, administrators, counsellors, and clients.
While you use the Wagon app, your data is encrypted both in transit and at rest, using AES_256 level encryption. This is a specification approved by the National Institute of Standards and Technology for symmetric key data encryption and has been adopted by the US government to replace previous methods of encryption.
In addition, EHN Outpatient Services Inc. uses HTTPS to authenticate communication between all entities within the system. HTTPS provides a reasonable guarantee that data is being transferred only between the components of EHN Outpatient Services Inc. (database, server, and app) and that the data cannot be read or forged by any third party.
Depending on the type of online treatment program you register for, EHN Outpatient Services Inc. uses Zoom Video Communications Inc. (Zoom) or Microsoft Teams (Teams) as the technology for providing safe and secure online therapy sessions. Zoom and Teams are compliant with the Health Insurance Portability and Accountability Act (HIPPA). For more information on how Zoom protects the privacy of your online sessions, see Zoom’s Privacy Policy. For more information on how Teams protects the privacy of your online sessions, see Microsoft’s Privacy Policy.
While we use all standard measures at our disposal to safeguard and protect information that is under our control from unauthorized access, use or disclosure, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We cannot guarantee its absolute security. It is up to you the user to ensure you protect yourself. Use caution when using any app or the Internet. Don’t allow unauthorized access to your account, protect your passwords and usernames, and limit access to your devices. Lock your mobile device when not in use, and never leave yourself logged in to a site or app.
EHN Outpatient Services Inc. stores data in Canada.
You understand and agree that we store your information or data in Canada. This is subject to Canadian privacy laws.
EHN Outpatient Services Inc. is not responsible for third-party sites or services we do not directly control.
If you click on a link to a third-party site, be sure you are familiar with their privacy policy. We are not responsible for those third-party sites.
You can access your information
At any time you can request to access, update, or correct your personal information by contacting your counsellor directly. We may request certain personal information for the purposes of verifying your identity.
You can delete your information
You may request deletion of your personal information by EHN Outpatient Services Inc. , but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete personal information, it will be deleted from the active database, including from our archives. Once we disclose some of your personal information to third parties, we may not be able to access that personal information any longer as maintained by the third party and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.
What EHN Outpatient Services Inc. will do if this policy is updated.
EHN Outpatient Services Inc. may need to amend their privacy practices from time to time. Please be sure to check for updates periodically.
We want to hear from you if you have questions or concerns.
You can submit your general inquiry or concern with a detailed message to [email protected]
