Note that this Policy does not apply to the collection, use, retention, disposal, destruction, and protection of Information by Authorized Counsellors or Authorized Non-Counsellors. Authorized Counsellors and Authorized Non-Counsellors are subject to privacy legislation and professional requirements that govern their management of Information, including Information they collect, use and retain in the course of providing services through the Future Directions Platform. Please feel free to ask any Authorized Counsellor or Authorized Non-Counsellors to whom you are referred if you have questions about how he or she will treat your Information.
Collecting and using Information
Future Directions collects and uses Information only as necessary to provide our services, including to develop, assess, and improve our services. We only collect Personal Information if non-identifying information will not suffice. We minimize our collection and use of Information to what is needed for these purposes. For example, we do not record the audio or video portions of interactions between Users and Authorized Counsellors and between Users and Authorized Non-Counsellors through the Future Directions Platform.
As mentioned, Authorized Counsellors and Authorized Non-Counsellors are responsible for their collection, use, disclosure, retention, destruction and protection of Information. As a result, the following description is an overview only of the use generally made of Information for the purpose of providing services through the Future Directions Platform. A particular Authorized Counsellor or Authorized Non-Counsellors may or may not choose to collect or use Information as described below in connection with a particular interaction with a User.
Authorized Counsellors and Authorized Non-Counsellors may collect Information about you or any Registered Dependent (as defined below) when you provide it during an Educational Services consultation (e.g., verbally or in texts), by viewing the Information that you have entered or uploaded to the Future Directions Platform and/or by creating or compiling Information in the Future Directions Platform. Information that will be available to Authorized Counsellors and Authorized Non-Counsellors includes: the details that you provide in your consultation request; information you’ve entered or uploaded to profiles and information created during earlier interactions through the Future Directions Platform with other Authorized Counsellors and/or Authorized Non-Counsellors; the name, email address, phone number, gender and date of birth and province/territory that you provided when you registered; and your emergency contact’s name and contact information. Authorized Counsellors and Authorized Non-Counsellors use Information to provide you with Educational Consulting Services and/or Informational Services and, as with any Counsellor, must comply with the privacy legislation and medical record-keeping obligations to which they are subject. They may export or print copies of your Information that they collect. You are responsible for advising your emergency contact that you are providing their name and contact information to Future Directions and Authorized Counsellors and Authorized Non-Counsellor Providers, and for obtaining any necessary consent from them for the provision and use of their information in connection with the Future Directions Platform.
Authorized Counsellors and Authorized Non-Counsellors collect and use Information that you provide in the course of obtaining Informational Services, by viewing the information that you have entered or uploaded to the Future Directions Platform and by creating or compiling Information in the Future Directions Platform. The Information that they collect, and use includes: the details that you provide in your request for Informational Services and information that you provided to register to use the Future Directions Platform (name, gender, date of birth and place of residence) to confirm your eligibility to receive Informational Services. Authorized Counsellors and Authorized Non-Counsellors are bound to comply with privacy legislation applicable to providers of Informational Services.
Provision of the Future Directions Platform
- We collect and use your Information to register you, create your User Account, authenticate you when you log in and personalize your experience while using the Future Directions Platform. We confirm your eligibility to use the Future Directions Platform for Healthcare Services and/or Informational Services by asking you to confirm your place of residence and date of birth that you provide when registering.
- You may choose to enter or upload and store your Information in the Future Directions Platform such as your education records, and the name and contact information for your emergency contact.
- When seeking Counselling Services, you may also choose to enter or upload and store Information about individuals for whom you have the legal authority to make decisions regarding their education and for whom you have created a profile by providing their first and last name, gender and date of birth (each a “Registered Dependent”). We use their date of birth where applicable and your assertion of their relationship with you to confirm your eligibility to obtain Healthcare Services for them, and their eligibility to receive Counselling Services.
- We use Information that you enter, or upload, or which is created as part of an interaction with an Authorized Counsellor or Authorized Non-Counsellor to make it available to you when you access your User Account.
- We may use Information for loss prevention and anti-fraud purposes, and to comply with regulatory and legal requirements.
- We may use Information to help us create, develop, operate, deliver, support and improve the Future Directions Platform, its content and advertising provided to you through it (Future Direction’s and third parties’) unless you have decided not to receive such advertising.
Users eligible for Healthcare Services:
- To request Counselling Services, you select any applicable relevant to your request. We do not identify you, or, if applicable, the Registered Dependent for whom you’re seeking the Guidance Counseling Services. Once the Authorized Counsellor or Authorized Non-Counsellor confirms that your request is eligible, we identify the Authorized Counsellor or Authorized Non-Counsellor to you. The Future Directions Platform presents to the Authorized Counsellor or Authorized Non-Counsellor the Information you provided in your consultation request, your name and, if applicable, the name of the Registered Dependent for whom you’re seeking the consultation. Unless you have elected to withhold access to information held in the Future Directions Platform about you or any Registered Dependent, the Authorized Counsellor or Authorized Non-Counsellor will be able to view it too.
Users eligible for Informational Services:
- When you request Informational Services, you select any topics for which you are seeking. On your behalf, we present the information that you provide to an Authorized Counsellor or Authorized Non-Counsellor to determine whether your request is eligible for Informational Services. We do not identify you. Once the Authorized Counsellor or Authorized Non-Counsellor confirms that your request is eligible, we identify the Authorized Counsellor or Authorized Non-Counsellor to you. The Future Directions Platform presents to the Authorized Counsellor or Authorized Non-Counsellors the Information you provided in your request for Informational Services and your name.
- We use your Information to text or email you to notify you about services that you request, for example, about the status of your request for Informational Services.
- We may collect location data through the use of GPS technology and your IP address to support you in receiving services, e.g., ensuring you are connected to an Authorized Counsellor or Authorized Non-Counsellor who is authorized to provide such services in the jurisdiction where you are located. We also use your IP address for security purposes, e.g., presenting you with information about your account activity in your account settings.
Communicating with you
- Medical emergencies associated with requests for Services. Should you submit Information about a medical issue, which is deemed an emergency by an Authorized Counsellor or an Authorized Non-Counsellor prior to their acceptance of your request for Counselling Services Future Directions reserves the right to contact you at any time using any of the contact information you have provided. This contact is strictly for the purpose of informing you that an Authorized Counsellor or Authorized Non-Counsellor has viewed your anonymized request and has declined the request based on their belief that your symptoms may represent a medical emergency.
- Customer support. If you email, fax, write to us or complete a ‘contact us’ form on the Future Directions Platform, we will collect the name and contact information that you provide to us and will use it to respond to you.
We only permit our Personnel to access Information to the extent necessary to perform their designated functions. We require them to protect the Information and maintain its confidentiality by complying with our policies, procedures and applicable law.
We will not disclose, share, sell or rent your Information with or to any third party (except to the extent we disclose to Authorized Counsellors or Authorized Non-Counsellor emergency contacts and in compliance with regulatory and legal requirements as set out in this Policy), except with your consent, or to the extent necessary, in our good faith judgment, to: comply with applicable laws or regulations, respond to a subpoena, order, or similar obligation to produce information; establish or exercise Future Direction’s legal rights or defend against legal claims; or investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or safety of any person. We may use or disclose your email address, but never PHI, information to market a product or service, either directly, or through a service provider or partner that performs services on our behalf.
We may disclose Information for the purposes of the due diligence required for or for the completion of a transaction such as a merger, acquisition or asset sale. We will comply with any applicable legal requirements, including notice requirements, that apply to such transactions.
Retaining and disposing of Information
Unless we otherwise give you notice, we will retain your Information on the Future Directions Platform on your behalf until such times as you or we terminate your User Account. On termination, you will have an opportunity to print or make copies of your Information subject to the following. To ensure that Authorized Counsellors and Authorized Non-Counsellors may exercise any authority they have to withhold Information they compile in connection with Healthcare Services from patients under the law, you will be required to request any access you would like to note made by an Authorized Counsellor or an Authorized Non-Counsellor about your consultation from the Authorized Counsellor or Authorized Non-Counsellor. With the exception of residents of Prince Edward Island receiving Healthcare Services in Prince Edward Island, Future Directions is not the custodian of Information held on the Future Directions Platform; rather it holds Information on behalf of Users or Authorized Counsellors and Authorized Non-Counsellor.
Accessing and correcting Information
You can access your Information or that of your Registered Dependents to check that it is accurate, complete, and up to date by logging in to your User Account.
You may update and edit any of your Information except Information an Authorized Counsellor Authorized Non-Counsellor has viewed or created Information during an Educational Services consultation when you log in to your User Account.
You can access Information you provided in your request(s) for Informational Services by logging in to your User Account.
The Future Directions Platform offers you functionality and choices for protecting your privacy which include:
- You may enable two-factor authentication on your account to help ensure that only you can access your account. If you do, in addition to entering your password to log in to your account to access the Future Directions Platform, we will send a code to your mobile number, which you will need to enter. This added security prevents anyone else from accessing your Future Directions account unless they have access to your login information and your mobile phone.
- You may choose whether to use audio, chat, or video for interactions with Authorized Counsellors and Authorized Non-Counsellor.
- When seeking Counselling Services, you may withhold Information, e.g., consultation information and medical records from Authorized Counsellors and/or Authorized Non-Counsellor. Please be aware that Authorized Counsellors and Authorized Non-Counsellors may be unable to provide you with Educational Services as a result. They will advise you of the implications of your choice.
- When seeking Informational Services, any previous Information collected e.g., consultation information and records, will not be accessible by the Authorized Counsellor or Authorized Non-Counsellor providing the services unless you specifically elect to provide access.
- You may choose whether to receive communications by email or SMS.
- You can check your log-in history when you access the Future Directions Platform.
Please contact us directly at firstname.lastname@example.org for assistance with using the privacy functionality or with any questions about using the Future Directions Platform. Additionally, you may contact us at any time to: stop receiving emails or other correspondence from us, seek assistance with viewing and correcting Information, and close your User Account. To protect privacy, we may request information to verify your identity when you contact us.
Future Directions takes the security of your information seriously. We store your information in electronic format within Canada, using computer systems with restricted access and housed in facilities using physical security measures. More generally, we have in place appropriate physical, technological, and organizational safeguards to protect Information against loss, theft, and unauthorized access, use and disclosure. As mentioned, Future Directions Personnel are obligated to protect Information by adhering to our policies, practices and applicable laws.
You also play an important role in protecting your privacy and the confidentiality of your Information. For example:
- Create a strong and unique password for your User Account, using Future Direction’s password strength estimator, and update it periodically.
- Do not share your User Account or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request.
- Log out of your User Account once you are finished using it, especially if you share your Device with anyone else.
- Have a strong and unique password on your Device, too.
- Choose a quiet, private location from which to receive services from Authorized Counsellors and Authorized Non-Counsellor.
Collecting, using and sharing Data
Cookies and similar technologies
Links and third-party websites and applications
The Future Directions Platform may contain links to other websites that we do not own or operate. These links are not intended as an endorsement of or referral to the linked websites. We strongly encourage you to review the privacy policies applicable to any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites or their operators which are provided solely for your convenience.
We publish the current version of our Policy at https://futuredirections.ca/privacy-policy/. We reserve the right to amend our Policy at any time. Check back often to ensure you are aware of our current practices for collecting, using, disclosing, retaining, destroying and protecting Information.
If you have any questions, concerns or suggestions about our privacy practices, please contact our Chief Compliance Officer. Please include your name and contact information if you’d like us to respond to you.
Future Directions Corporation
ATTN: Chief Compliance Officer
- “Authorized Counsellor” means a Counsellor who is registered and trained in a Province or Territory of Canada, meets Future Directions other criteria, and is permitted to provide Guidance Services and/or Informational Services through the Future Directions Platform.
- “Data” means information collected or compiled through the Future Directions Platform which has been de-identified.
- “De-identify” in relation to PHI, means to remove information that identifies the individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify the individual.
- “Device” means a mobile or desktop device owned or controlled by a User and used to access Future Directions Counsellor Services.
- “Future Directions Platform” means the hardware, software, applications, websites, content, products and services owned and/or operated by us, which include the software that enables Authorized Counsellors and Authorized Non-Counsellors to provide Educational Guidance Services and Informational Services to Authorized Users.
- “Personal Information” means information about an identifiable individual which is not PHI, and which is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Future Directions Platform.
- “Personnel” in relation to Future Directions, means its employees and agents including independent contractors and subcontractors, for whom Future Directions is responsible at law.
- “PHI” or “personal health information” means information about an individual’s health or healthcare that is subject to Privacy Law and that is collected, created, compiled, used, disclosed or otherwise transmitted and/or stored on or by means of the Future Directions Platform.
- “Privacy Law” means the applicable legislation governing the collection, use, disclosure, and/or protection of PHI in the Province or Territory in which a User resides.