Privacy policy

This policy explains how Cliniques Familio Inc. (“Familio,” “we,” “our”) collects, uses, discloses, and protects the personal information you provide to us when you use our clinical services, our website, and our digital tools. It is drafted in accordance with Quebec’s Act respecting the protection of personal information in the private sector, as amended by Bill 25.

1. Identity of the Data Controller

The data controller for your personal information is:

Cliniques Familio Inc.
3244 Beaubien Street East, Montreal, Quebec H1Y 1H7
Phone: +1 833-326-4546
Email: confidentialite@familio.ca

2. Person Responsible for the Protection of Personal Information

In accordance with Section 3.1 of Bill 25, Familio has designated a person responsible for the protection of personal information. You may contact this person with any questions, requests for access or correction, or complaints:

Name: Jean-François Michaud
Email: jfmichaud@familio.ca
Address: 3244 Beaubien Street East, Montreal, Quebec H1Y 1H7

3. Personal Information We Collect

We collect only the information necessary to provide our services:

Registration and contact information: last name, first name, date of birth, address, email, phone number, relationship (when the request concerns a minor or a person under legal representation).
Clinical data: reason for consultation, relevant medical history, clinical notes, assessment results, intervention plans, correspondence with other healthcare professionals. This information is protected by professional confidentiality.
Payment data: payments are made by Interac e-transfer, cash, or cheque. Familio does not use an online payment processor and does not collect or store credit card numbers.
Browsing data: IP address, browser type, pages visited, aggregated analytics data. See our cookie policy.
Data submitted via forms: information voluntarily provided through our contact forms, appointment booking forms, or job application forms.

4. Purposes of Processing

Your personal information is used for the following purposes:

To match you with a professional who meets your needs (psychologist, neuropsychologist, etc.) and plan your care.
To maintain, update, and retain your clinical record in accordance with the standards of the relevant professional associations.
To bill for our services and manage payments.
To communicate with you (appointment reminders, administrative follow-ups, essential clinical communications).
To improve the quality of our services, for statistical and anonymized purposes.
Comply with our legal and regulatory obligations (Régie de l'assurance maladie du Québec, professional associations, requests from competent authorities).

5. Legal Bases for Processing

We process your personal information on the following grounds:

Your explicit consent, particularly for sensitive clinical information.
The performance of a service contract between you and Familio.
Compliance with legal obligations imposed by Quebec and Canadian law.

6. Disclosure of Information to Third Parties

We never sell your personal information or disclose it for commercial purposes. Your information may be shared only in the following cases:

With the professionals assigned to your case at Familio, to the extent necessary for your care.
With third-party clinics (laboratories, other clinics, other healthcare professionals) when necessary for your care, and only with your prior authorization.
With our subcontractors who act strictly in accordance with our instructions and are bound by confidentiality agreements, including:
- Hosting and database: Supabase (hosted in the United States, on Amazon Web Services infrastructure; see Section 12 on transfers outside Quebec).
- Productivity tools: email services, calendars, electronic signatures.
When required by law, for example in response to a court order or a legal reporting obligation.

7. Retention Period

We retain your personal information only for as long as necessary to fulfill the purposes described above, and in accordance with the rules applicable to the relevant profession:

Adult clinical records: a minimum of five (5) years after the end of treatment, in accordance with professional association standards.
Clinical records of minors: until the client reaches the age of majority, plus five (5) years.
Accounting and billing data: in accordance with applicable tax requirements (generally six [6] years).
Job application data: up to twenty-four (24) months after receipt, unless consent is given for an extension.

Once these periods have elapsed, your information is securely destroyed or anonymized.

8. Your Rights

Bill 25 grants you the following rights regarding your personal information:

Right of access: to obtain a copy of the information we hold about you.
Right to rectification: to have inaccurate, incomplete, or ambiguous information corrected.
Right to withdraw consent at any time, subject to contractual or legal obligations.
Right to de-indexation: in certain cases, request the cessation of the dissemination of information or the de-indexation of a hyperlink.
Right to data portability (effective since September 2024): to receive your information in a structured, commonly used, and machine-readable format.
Right to information regarding automated decisions affecting you (see Section 10).

To exercise these rights, write to confidentialite@familio.ca specifying the nature of your request. We will respond within a maximum of thirty (30) days.

9. Security

We implement reasonable technical and organizational measures to protect your personal information against loss, unauthorized use, or disclosure:

Encryption of communications in transit (TLS/HTTPS).
Encryption at rest for sensitive data, where applicable.
Strict access controls: access limited to individuals with a legitimate need to know.
Strong authentication for administrative accounts.
Regular backups and a business continuity plan.
Staff training and awareness.

In the event of a privacy incident posing a risk of serious harm, we will notify the affected individuals and the Commission d'accès à l'information du Québec, in accordance with the law.

10. Automated Decisions

When you fill out our service request form, we use automated rules to suggest a match with a professional from our team based on criteria such as the reason for the consultation, availability, client base, and location. This suggestion is then reviewed by a team member before the appointment is finalized.

You have the right to be informed of this use and to request human intervention or to contest the result by writing to confidentialite@familio.ca.

11. Cookies and Similar Technologies

Our site uses cookies to ensure it functions properly, measure its audience, and improve your experience. You can manage your preferences via the consent banner displayed during your first visit, or by resetting your preferences at the bottom of the page.

12. Transfers Outside Quebec

Some of our subcontractors may process your information outside of Quebec (for example, cloud hosting in the United States or elsewhere in Canada). Before any transfer outside of Quebec, Familio conducts a privacy impact assessment in accordance with Section 17 of Bill 25 to ensure that the information will be adequately protected. Our primary hosting provider, Supabase, processes and stores data on Amazon Web Services infrastructure located in the United States (US East region, Northern Virginia).

13. Changes to This Policy

We may amend this policy from time to time to reflect changes in our practices or legal requirements. The date of the last update is displayed at the top of this page. In the event of a significant change, we will notify you by an appropriate means.

14. Complaint to the Commission d’accès à l’information du Québec

If you believe that Familio has not fulfilled its obligations regarding the protection of personal information, you may first contact us at confidentialite@familio.ca. If you are not satisfied with the response, you have the right to file a complaint with the Commission d'accès à l'information du Québec:

Commission d'accès à l'information du Québec
Website: www.cai.gouv.qc.ca
Phone: 1-888-528-7741