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In-Common Laboratories (“ICL”, “we”, “us” or “our”) is a Canadian not-for-profit corporation dedicated to ensuring client access to a national and international accredited laboratory test referral network. ICL, through our laboratory information and network systems simplifies ordering patient tests, routing and tracking samples, and providing results.
ICL provides the following services:
ICL does not provide patient testing services directly to the public. We perform some specimen collection services on patients and capture their personal information but only in conjunction with test requisitions received from organizations or individuals who are authorized to request ICL services. In a small number of instances, organizations or individuals may request ICL to collect Personal Information directly about individuals.
For information about patients and their laboratory test results, as a service provider, ICL is subject to Personal Health Information protection statutes in those jurisdictions where the information is obtained. Where Personal Information is collected (information other than Personal Health Information), ICL is subject to federal or provincial legislation governing Personal Information. In Ontario, for example, ICL is subject to the provincial Personal Health Information and Protection Act (PHIPA) and the federal Personal Information Protection and Electronic Documents Act (PIPEDA).
For the purposes of this Privacy Statement, “Personal Information” is defined broadly and means any information about an individual that is, or can reasonably be, associated with that individual. Similarly, “Personal Health Information” is information, in any format, that can identify an individual and relates to their health or healthcare. This includes information about their physical or mental health, family history, healthcare providers, health card number as well as related administrative matters such as healthcare payments and eligibility.
We may also refer to the “processing” of Personal Information and Personal Health Information, which means the collection, use, protection, storage and disposal of Personal Information and Personal Health Information.
To review sections of this Privacy Statement, please select the drop-downs below.
Generally, ICL receives Personal Information and Personal Health Information from:
ICL will also collect Personal Information from its clients who are requesting tests and those individuals who provide business or professional services to ICL.
The Personal Information and Personal Health Information we receive will consist of information needed to process test requisitions and will include:
ICL may also collect Personal Information for other individuals. In such instances, the Personal Information we generally collect will include:
Means of Receipt or Collection. ICL will most often receive Personal Information and Personal Health Information indirectly from patients where such information is provided to us for testing by a healthcare provider. Generally, requests for lab tests are made by healthcare providers but in some instances, an individual may go to an ICL location, where limited information (for billing purposes) and sample collection occurs directly. In other instances, depending on the circumstances, we may be provided Personal Information and Personal Health Information by government agencies, insurers or participants in a provincial health information registry.
Where we obtain Personal Information from a third party, ICL will take reasonable steps to ensure that the third party has the authority to disclose Personal Information to us.
Images of individuals visiting ICL offices or facilities may be captured by video recording devices used to maintain the physical security of those offices and facilities. ICL maintains control or custody or access to such facilities-related recordings.
Form of Receipt or Collection. We may collect, create, record and use Personal Information and Personal Health Information in physical and electronic form, and will process such information as set out in this statement and in accordance with applicable personal information protection laws in Canada.
In general, we use Personal Information and Personal Health Information for the following purposes:
Social Media. ICL maintains a public presence on the LinkedIn social media platform.
If sharing our digital content through social networks, cookies may be sent from these third-party websites. We do not control the setting of these plugins/cookies and ICL has no knowledge of the content of the data transmitted to these social networks or of how they individually use such data. If interacting with ICL via social media, the terms of service and privacy policies of these third-party service providers and those of any applications used to access them should be read.
Web Analytics. Web analytics is the collection, analysis, measurement, and reporting of data about web traffic and visits. This data is generally used to improve a website and complete administrative tasks such as:
ICL uses Google Analytics. We do this to ensure ICL’s site is meeting the needs of its users and to help us make improvements. Google Analytics stores information about:
Google Analytics doesn’t collect or store a user’s personal information (e.g., name or address.). We don’t allow Google to use or share our analytics data.
Data collected by Google Analytics is sent to Google servers which may be in the United States and may be subject to the applicable legislation in that country. A user’s IP address is anonymized prior to being stored on Googles’ servers to help safeguard privacy.
If a user does not wish to have his/her information shared with the Analytics software, Google makes a “plug-in” available for users of the Internet Explorer, Firefox, Safari and Chrome browsers which prevents a user’s browser from sharing any information with the Analytics software. This plug-in may be downloaded here: http://tools.google.com/dlpage/gaoptout.
Website Information Collection. ICL’s website(s) may automatically collect information including but not limited to the Internet Protocol (IP) address of a user’s computer, the operating system, the parts of the Site visited, the pages and images viewed, the content downloaded from the Site and a user’s internet service provider’s IP address. Such information collected is generally used to improve the Site and for Site administration purposes. The information may be used to create aggregate tracking information reports regarding Site traffic patterns and Site user demographics.
Digital Markers. A digital marker is a small text file placed on a user’s computer, smartphone or other device by websites visited. Examples of digital markers are “cookies” or HTML5 web storage. Digital markers are commonly used to store visitor preferences (for example: language or location), to track what website information is viewed, and to manage visitor sessions.
Users may adjust their browser settings to reject digital markers, including cookies. However, if done, it will affect a user’s ability to interact with this site.
Surveys. Occasionally ICL conducts online surveys, some of which are conducted on our behalf by a third party. Our third-party service providers may use cookies to identify unique visitors, to provide per-user customization, and to make the surveys easier to use. Such service providers do not share such cookies or use them to track user behavior on other sites.
In connection with any of the purposes outlined in the above section “How ICL Uses Personal Information and Personal Health Information”, we may disclose Personal Information and/or Personal Health Information with other companies, organizations, and individuals outside of ICL. This will occur in a variety of circumstances when we provide our services to:
Should ICL believe it appropriate to disclose Personal Information or Personal Health Information without consent, it will limit the disclosure of information to what is necessary.
Where we disclose Personal Information or Personal Health Information to a non-governmental third party, other than a medical laboratory, we will contractually require that third party to reasonably ensure the protection of Personal Information or Personal Health Information and to have appropriate security measures in place to do so.
We may anonymize or de-identify Personal Information or Personal Health Information (i.e., information has been removed to ensure the identity of any individual cannot reasonably be ascertained). After undergoing anonymization or de-identification, such information is not considered to be Personal Information or Personal Health Information. We may disclose such information for health-related research purposes and may receive compensation for doing so.
Unless permitted or required by law, ICL will not directly collect Personal Information or Personal Health Information. When we provide our services to a healthcare organization such as a hospital, a physician, or other healthcare practitioner we do not ensure that they have obtained consent for the direct or indirect collection by them of Personal Information or Personal Health Information.
ICL works to maintain appropriate physical, procedural, and technical safeguards to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information or Personal Health Information in our custody. Our measures to keep Personal Information and Personal Health Information secure include:
We also endeavour to ensure that any Personal Information and Personal Health Information in our custody is as accurate, current, and complete as necessary for our use of that information.
Users should note that the transmission of data over the internet, including through e-mail, is never completely secure and accordingly we cannot guarantee the security of Personal Information or Personal Health Information sent to or by us using the Internet.
Currently, ICL stores Personal Information and Personal Health Information in its custody in Canada and is subject to the laws of those jurisdictions where it is located. In some instances, Personal Information and Personal Health Information will be transferred to accredited laboratories outside of Canada for the purpose of analyzing the test.
For test processing, ICL only discloses Personal Information and Personal Health Information to laboratories that are accredited under ISO Standard 15189: 2022 Medical laboratories — Requirements for quality and competence or equivalent standards. Such an accreditation provides evidence that a quality management system, specific to medical laboratories, is in place. Adherence to such a standard effectively requires laboratories to handle private information about patients in a secure and confidential manner.
ICL will only retain Personal Information and Personal Health Information for as long as is necessary to fulfil the purposes for which it was processed, including for the purposes associated with legal, tax, reporting, or accounting requirements. We will generally hold Personal Information and Personal Health Information for the period of time established in our data retention schedule, our contracts with healthcare providers and any applicable law.
If a legal claim is made against ICL, relevant Personal Information and Personal Health Information may be retained for a longer period in order that it may be referred to by all parties in relation to that claim and any subsequent appeal.
Personal Information and Personal Health Information which is (i) scheduled for removal or (ii) no longer needs to be retained will be securely destroyed or permanently erased from our records. Please note that rights to access or correction cease after the information has been destroyed.
In the event Personal Information and Personal Health Information is anonymized or otherwise de-identified so that it no longer permits personal identification, we may retain such information for a longer period.
ICL clients who directly or indirectly provide Personal Information may:
Any requests in this regard can be directed to ICL’s Privacy Officer. These requests can be exercised free of charge and will be addressed as early as possible.
Where ICL acts as a service provider receiving Personal Information and Personal Health Information to conduct or facilitate requested testing, any request for access to such information, including requests to view, correct, or delete the information, will be referred to the healthcare provider who requested the service. ICL considers that healthcare providers are responsible for responding to any such access request. ICL will, however, respond to reasonable requests by clients to assist with their response to such requests.
Any questions or concerns about how ICL processes Personal Information and Personal Health Information, may be directed to our Privacy Officer:
Depending on the province of residency, the activity in question and which law applies, ICL will be subject to the jurisdiction of either the federal or a provincial privacy authority.
ICL reserves the right to update this Privacy Statement at any time and we encourage clients to review it from time to time. The modified or amended Privacy Statement will apply from the indicated date of last revision. Should changes affect processing activities, involving Personal Information, performed on the basis of the original consent, ICL will seek a new consent where required.