Privacy Policy

 

CDL Rapid Screening Consortium Privacy Policy

CDL Rapid Screening Consortium (the “Consortium”), its Members and Participants together with provincial, territorial and federal public health agencies and authorities have developed a system for conducting COVID-19 screening that can be administered on a cost effective basis and produce rapid results for the purpose of reopening the economy, schools and other organizations during the COVID-19 pandemic (the “Project”) in compliance with provincial, territorial and federal health guidelines and regulations.    

The Consortium values and respects your privacy. This privacy policy describes our personal information practices when you visit our website at https://www.cdlrapidscreeningconsortium.com/ (the “Website”), register or complete a COVID-19 screen administered at a Consortium member’s (“Member”) or participating organization’s (“Participants”) rapid antigen screening site (“Site”) (or remotely, under the direction or with the support of the Member or Participant’s virtual supervision), or otherwise interact with us.

Table of Contents

  • Collection, Use and Disclosure of Information in Connection with the Project

  • Collection and Use of Personal Information through our Website and Other Interactions

  • Sharing of Personal Information

  • Information About Our Website

  • Safeguards and Retention

  • Your Choices

  • Access to Information

  • Updates to The Privacy Policy

  • Contact Us

Collection, Use and Disclosure of Information in Connection with the Pilot

Collection of De-Identified Registration Information and Screening Results by the Consortium

·         Participation in the Project is completely voluntary. If you choose to participate in the Project at a Member’s Site, the Member will collect certain registration information either directly from you or via a web-based application and disclose certain elements of this information as well as details about your screening to the Consortium. To help maintain your privacy, this information will be de-identified and associated with a unique identifier assigned by the Member or Participant. Your name, contact information and other personal information will not be shared with the Consortium as part of this de-identified data.

·         The de-identified information disclosed to the Consortium includes the Participant or Member company’s name, Site postal code, and the following information:

  • if you participate at a Member Site, your role category (e.g. employee, guest, vendor), responses to the COVID-19 symptom and exposure assessment questionnaire, age range, gender, screen type, screen result, screening date, screening start and end time, check-in and check-out times, total turnaround time and, if applicable, self-reported PCR (polymerase chain reaction) test result, date, location, and CT (cycle threshold) value. This information is de-identified and associated with a unique identifier but not your name or other contact information.

  • If you participate at a Participant Site, your screen date, screen result, screen type, PCR test date and result. This information is associated with an identifier that is unique to each screening event. The information is not associated with you or any individual. 

Use of De-Identified Data by the Consortium

·         If you participate at a Member Site, the Consortium will use the unique identifier to link your screen results over time in order to assess and compare the operational efficiency of the Sites and different types of screens used throughout the Project, ensure that screened participants conform to the participation parameters of a given Site, evaluate the effectiveness of the COVID-19 screens, improve the operational performance of COVID-19 screening programs, inform public health agencies and authorities on the use of the screens in practice and measure if there are any site-specific or general issues within the workplace, educational, or other environments in respect of the screening program. The Consortium will also use the de-identified data to create and provide aggregated statistical reporting to the Member, and in combination with information from other Members and Participants in the Project, to:

  • develop, enhance, and make available the Consortium’s services and products to Members, Participants and other third parties, such as a specific dashboard for Members and Participants,

  • create and monitor best practices, benchmarks, and operational standards for Members and Participants that assess and compare the efficacy of the use of the COVID-19 screens at their workplace, and

  • produce and publish data, information, or other materials that are not identified as relating to a particular individual, Member or Participant.

 Consent for the Collection. Use, and Disclosure of De-Identified Data

• The Consortium relies on its Members and Participants to obtain consent to collect, use and disclose your personal information in connection with the Project, including to share de-identified data with the Consortium.

• The Member may provide the Consortium with information sufficient to validate your consent (which may, in limited circumstances, include a copy of your completed consent form, such as in the event of a complaint or legal proceeding). 

 Retention of De-Identified Data

• The Consortium will retain the de-identified data for the duration of the Project period. Upon completion of the Project, the Consortium will then take additional steps to anonymize the de-identified data and will retain this anonymized information for the sole purposes of statistical modelling and research purposes.

Disclosure of De-Identified Data by the Consortium 

Public Health Agencies and Authorities

• The Consortium may share de-identified data with provincial, territorial and federal public health agencies and authorities or, if required by law, other governmental authorities, to monitor the efficacy of the COVID-19 screening devices and programs, determine the prevalence of COVID-19, and facilitate safe and responsible employment practices to allow individuals to safely return to work, school or other environments. Such public health agencies and authorities of, if applicable other governmental authorities may also use this data to inform how they deploy resources in combatting of COVID-19 and to assist public health care providers in detecting, preventing and treating COVID-19 infections in their regions. 

• Provincial and territorial public health agencies and authorities may also share this data with Health Canada according to their established protocols and in accordance with applicable provincial or territorial legislation. Provincial public health agencies and authorities include Ontario Public Health, Alberta Health Services, Public Health New Brunswick, the Health and Welfare Commissioner of Quebec, and other provincial public health agencies and authorities, boards, arms-length corporations, and offices. 

Participating Organizations

• The Consortium will share aggregated data that does not identify any individual, Member or Participant with other Members, Participants, and the public for analysis and to share best practices related to the operational efficiency of Project sites. 

Other Organizations

• The Consortium may produce, publish and share with other organizations aggregated statistical reports, data, information, or other materials that are not identified as relating to a particular individual, Member or Participant.

Collection and Use of Personal Information through our Website and Other Interactions 

We collect and use personal information for the purposes identified below.

Subscribe to our Email Updates: If you subscribe for our email updates, we collect your email address. If you no longer wish to receive these communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of the emails. Alternatively, you can opt-out of receiving our email updates by contacting us at the contact information under “Contact Us” below. Please note that you may continue to receive certain transactional or informational communications from us.

Registration: If you register your organization for our Workplace Rapid Screening Program, we collect your first and last name, title, email address in order to send you a participation agreement and other CDL RSC resources, and to contact you regarding your organization’s participation in the program.

Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you, such as your name, organization name, role/title/position, email address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service.

Sharing of Personal Information

We do not sell, rent or disclose your personal information to third parties without your consent, except as described below or as required or permitted by applicable law. 

• Service Providers: Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as administering our surveys, hosting the Website, storing de-identified data associated with the Project, and sending our marketing communications. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.

• Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property. If we receive a request for information about a participant in the Project, we will be unable to respond to such request as we only have de-identified data. In these circumstances, we will inform the requester to contact the applicable Member or Participant.

• Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of the Consortium or as part of a corporate reorganization or other change in corporate control.

Information About Our Website

Visiting our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.

Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. Cookies may provide us and our service providers with information that we will use to provide features or functionality on the Website or to personalize our Website in accordance with a user’s preferences. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features.

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available here. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:


https://policies.google.com/technologies/partner-sites  and


https://support.google.com/analytics/topic/2919631 

Third Party Links: Our Website may contain links to other websites that the Consortium does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

Safeguards and Retention

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to de-identified Project data and personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements. For information on the retention of Project data, see “Collection and Use of De-Identified Data by the Consortium” above. 

Your Choices

As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below. 

If you wish to withdraw your consent to participate in the Project, please contact the applicable Member or Participant. 

Access to Information

Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody and control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

The Consortium only retains data in a de-identified form, as such we are unable to respond to any requests to access or correct your personal information that was collected in association with the Project. You should refer your request to the applicable Member or Participant. 

Updates to the Privacy Policy

We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.

Contact Us

If you have any questions or comments about this privacy policy or the manner in which we or our service providers treat your personal information, or to request access to your personal information in our records, please contact our Privacy and Security Manager at info@cdlrapidscreeningconsortium.com.

Please refer to the English version for the most up-to-date version of the Privacy Policy as of Oct 28, 2021.