# C-LIST Manage - Privacy Policy
**Effective Date**: October 15, 2025
**Last Updated**: October 15, 2025
**Version**: 1.0
## 1. Introduction
This Privacy Policy explains how the C-LIST Appointment Management mobile application ("the App") collects, uses, discloses, and protects your personal information during the pilot project at Thunder Bay Regional Health Sciences Centre (TBRHSC).
**Important**: This App is a pilot research project and does NOT process or store Personal Health Information (PHI). The App handles only administrative appointment scheduling data and user account information.
## 2. Who We Are
**Application Provider & Data Processor**: Dogfish App Development Inc.
**Data Provider**: Thunder Bay Regional Health Sciences Centre (TBRHSC)
**Project Type**: Grant-funded pilot research project
Dogfish App Development Inc. is responsible for all data processing, security, and deletion. TBRHSC provides appointment data for the pilot project.
## 3. Legal Authority for Collection
Personal information is collected under the following legal authority:
- **Freedom of Information and Protection of Privacy Act (FIPPA)** - Ontario's privacy law for public institutions
- **Personal Health Information Protection Act (PHIPA)** - Ontario's health privacy law (applicable to TBRHSC as custodian)
- Grant project authorization for pilot testing and research evaluation
Collection is necessary for:
- User authentication and access control
- System administration and security
- Pilot project evaluation and research purposes
## 4. What Information We Collect
### 4.1 User Account Information
When you register for the App, we collect:
- **Name**: Your full name for account identification
- **Email Address**: For account communications and password recovery
- **Professional Role**: Your role at TBRHSC (Admin, Nurse, or Surgeon)
- **Doctor Mnemonic** (for surgeons): Your coded physician identifier to match you with your appointments
- **Password**: Encrypted and stored securely for authentication
### 4.2 Device Information
For push notifications, we collect:
- **Device Token**: A unique identifier provided by your mobile device to send notifications
- **Device Platform**: iOS or Android (for notification compatibility)
### 4.3 Usage and Audit Information
For system security and pilot evaluation, we automatically collect:
- **Login Activity**: Date and time of login attempts and sessions
- **Actions Performed**: Changes made to C-LIST items (who made changes, when, and what changed)
- **IP Address**: For security monitoring and access control
- **App Usage Patterns**: Frequency of use, features accessed (for effectiveness analysis)
### 4.4 Appointment Data (Non-PHI)
The App displays administrative appointment scheduling data imported from MEDITECH EHR:
- Appointment ID (internal system identifier only)
- Appointment Type (procedure code)
- Appointment Duration
- Doctor Mnemonic (coded physician identifier)
- Priority Level (1-5)
- Wait List Date and Time
- Patient Type Category
**What We Do NOT Collect**:
- Patient names or identifiers
- Medical Record Numbers (MRN)
- Health Card Numbers
- Patient contact information
- Patient demographic information
- Clinical or diagnostic information
- Treatment details beyond procedure codes
- Any free text fields
- Any other Personal Health Information (PHI)
## 5. How We Use Your Information
### 5.1 Primary Purposes
Your personal information is used for:
1. **User Authentication**: Verify your identity and provide secure access to the App
2. **Role-Based Access Control**: Ensure you only see information appropriate to your role
3. **System Administration**: Manage user accounts, troubleshoot issues, provide technical support
4. **Security and Audit**: Track system access and changes for security and compliance
5. **Push Notifications**: Send you alerts about C-LIST updates relevant to your cases
6. **Pilot Evaluation**: Analyze system effectiveness and surgeon usage patterns for grant reporting
## 6. How We Protect Your Information
### 6.1 Security Measures
We implement industry-standard security measures:
- **Encryption**: All data encrypted in transit (HTTPS/TLS) and at rest (AES-256)
- **Access Controls**: Role-based access with minimum necessary principle
- **Authentication**: Secure password-based authentication with session timeouts
- **Account Protection**: Automatic lockout after failed login attempts
- **Audit Logging**: All access and modifications logged for security monitoring
- **Network Security**: Firewall protection and secure server infrastructure
- **Physical Security**: Data stored in secure, SOC 2 certified Canadian data centers
### 6.2 Data Storage Location
All personal information and appointment data is:
- **Stored in Canada only**
- **Processed in Canada only**
- **Backed up within Canada only**
No data is transferred outside of Canada.
## 7. Who We Share Your Information With
### 7.1 No Third-Party Sharing
Your personal information is NOT shared with any third parties.
### 7.2 Legal Requirements
We may disclose your information if required by law or court order, or to protect the rights, property, or safety of TBRHSC, Dogfish App Development, or others.
## 8. Your Privacy Rights
Under FIPPA, you have the right to:
1. **Access Your Information**: Request a copy of the personal information we hold about you
2. **Correction**: Request correction of inaccurate or incomplete personal information
3. **Account Deletion**: Request deletion of your account and personal data at any time by contacting Dogfish App Development Inc.
4. **Withdraw Consent**: Stop using the App at any time (your account will be deactivated)
5. **File a Complaint**: Contact the Ontario Information and Privacy Commissioner if you have concerns
**Note**: As this is a pilot research project, some aggregated anonymized data may be retained for research purposes even after you stop using the App (see Data Retention below). However, all personal identifiers will be deleted upon request.
## 9. Data Retention and Deletion
### 9.1 Retention Periods
- **Active User Accounts**: Maintained for the duration of the 3-month pilot
- **Pilot Data**: Minimum 6 months for analysis (3 months collection + 3 months evaluation)
- **Research Data**: Up to 12 months for grant reporting and evaluation
- **Audit Logs**: 12 months for compliance and security purposes
### 9.2 Secure Deletion
At the end of the pilot project:
- All personal information and appointment data will be securely deleted within 30 days of pilot completion
- You will receive written confirmation of data destruction upon request
- Deletion method: Secure overwriting of all data to prevent recovery
### 9.3 Research Data Retention
Aggregated, anonymized research findings (with no personal identifiers) may be retained indefinitely for grant reporting and academic purposes.
## 10. Cookies and Tracking Technologies
The mobile App does not use cookies. We collect minimal technical information as described in Section 4.2 (Device Information) for push notifications only.
## 11. Children's Privacy
This App is intended only for healthcare professionals at TBRHSC. It is not intended for use by individuals under 18 years of age.
## 12. Changes to This Privacy Policy
We may update this Privacy Policy during the pilot to reflect changes in our practices or legal requirements. We will notify you of material changes by:
- In-app notification
- Email to your registered address
- Updated "Last Updated" date at the top of this policy
Your continued use of the App after changes constitutes acceptance of the updated policy.
## 13. Contact Information
### For Privacy Questions, Account Deletion, or to Exercise Your Rights
**Dogfish App Development Inc.**
Technical Lead: Mitchell Pynn
Mitchell.Pynn@gmail.com
To request account deletion, data access, or corrections, please contact us through the App's support feature.
### To File a Privacy Complaint
If you are not satisfied with how we handle your privacy concerns, you may contact:
**Information and Privacy Commissioner of Ontario**
2 Bloor Street East, Suite 1400
Toronto, ON M4W 1A8
Phone: 416-326-3333 or 1-800-387-0073
Website: https://www.ipc.on.ca
## 14. Consent
By creating an account and using the C-LIST Appointment Management App, you acknowledge that you have read, understood, and agree to this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.
You may withdraw your consent at any time by discontinuing use of the App and requesting account deletion by contacting Dogfish App Development Inc. (see Section 13).
