Privacy Policy

Effective Date: January 1, 2025 | Last Updated: March 2025

Clinique de Cancérologige Cutanée (operating as The Skin Cancer Clinic Montreal, hereafter “the Clinic,” “we,” “our,” or “us”) is committed to protecting the privacy and confidentiality of your personal and medical information. This Privacy Policy explains what information we collect, how we use it, how we protect it, and your rights with respect to it.

By booking an appointment or using our services, you acknowledge that you have read and understood this Privacy Policy. If you have any questions, please contact us before using our services.

1. Information We Collect

1.1 Personal Identification Information

Full name, date of birth, and gender
Contact details: address, phone number, and email address
Health insurance number (for administrative purposes only; services are not covered by RAMQ)
Emergency contact information

1.2 Medical and Clinical Information

Personal and family medical history, including history of skin cancer
Current medications, allergies, and relevant health conditions
Skin cancer risk factors disclosed during your consultation
Physician examination notes and clinical assessments
Biopsy referrals and pathology results, where applicable

1.3 Imaging and Biometric Data

Because our core service involves total body mole mapping and AI-assisted dermoscopy, we collect a significant volume of sensitive imaging data, including:

High-resolution total body photographs captured using the FotoFinder ATBM system
Close-up dermoscopic images of individual moles and lesions
AI-generated analysis and classification data derived from those images
Comparative imaging data generated across multiple visits over time

This imaging data constitutes sensitive health information. It is treated with the highest level of care and is subject to all protections described in this policy.

1.4 Administrative and Transactional Information

Appointment history and scheduling records
Payment information (processed securely through third-party payment providers; we do not store full card details)
Refund and cancellation records
Communications with our clinic, including emails and phone records

1.5 Website and Digital Information

IP address, browser type, and pages visited on skincancermontreal.com and cancerdelapeau.ca
Cookies and similar tracking technologies used for basic analytics
Contact form submissions and newsletter opt-ins

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Providing Clinical Care

Conducting skin cancer screening, mole mapping, and dermoscopic examination
Generating a personalized screening baseline and tracking changes over time
Identifying lesions that require further assessment, biopsy, or specialist referral
Communicating results and next steps to you and, where appropriate, to other members of your care team

2.2 Clinic Operations

Scheduling, confirming, and managing your appointments
Processing payments and administering refunds
Sending appointment reminders and annual screening recall notices
Maintaining accurate and complete medical records

2.3 Quality Assurance and Safety

Reviewing clinical processes and imaging accuracy to ensure high standards of care
Monitoring AI-assisted analysis tools for accuracy and performance
Training clinical staff using de-identified or consented case examples

2.4 Communication and Education

Responding to your inquiries and questions
Sending educational content about skin cancer prevention and screening (only if you have opted in)
Notifying you of changes to our services, pricing, or policies

2.5 Legal and Regulatory Compliance

Fulfilling our obligations under Quebec and Canadian privacy legislation
Maintaining records as required under applicable medical practice standards
Cooperating with lawful requests from public health authorities or courts

3. Imaging Data: Special Considerations

Given the sensitive nature of the total body photographs and dermoscopic images we capture, we apply the following specific safeguards and practices:

Imaging data is stored exclusively on encrypted, access-controlled servers
Access is restricted to authorized clinical personnel directly involved in your care
Images are linked to your file using a secure patient identifier, not your name, in our imaging system
We do not use your photographs for marketing, advertising, or public-facing content without your separate, explicit written consent
Imaging data is retained for a minimum of seven (7) years following your last visit, in accordance with Quebec medical record retention standards
You may request access to your imaging data at any time (see Section 8: Your Rights)

Our FotoFinder ATBM imaging platform is provided by a third-party technology vendor. This vendor is bound by a data processing agreement that prohibits them from accessing, selling, or using your images for any purpose other than providing the platform service to our clinic.

4. How We Share Your Information

We do not sell your personal or medical information. We do not share your data with advertisers or third-party marketing organizations. We may share information in the following limited circumstances:

4.1 With Other Healthcare Providers

With your knowledge (verbal or written permission) and in your direct clinical interest, we may share relevant clinical information and imaging data with dermatologists, surgeons, oncologists, or your family physician when a referral or coordination of care is required.

4.2 With Technology Service Providers

We work with a small number of trusted service providers who assist us in operating our clinic, including our imaging platform vendor, our electronic health record system, and our payment processor. These providers are contractually obligated to protect your data and may not use it for any purpose beyond the service they provide to us.

4.3 As Required by Law

We may disclose information when required to do so by law, court order, or a lawful request from a regulatory or public health authority. We will notify you of such a request where legally permitted to do so.

4.4 With Your Explicit Consent

For any disclosure not described in this policy — including the use of your images in case studies, educational materials, or research — we will obtain your separate, explicit written consent before proceeding.

5. Data Security

We take the security of your health information seriously. Our safeguards include, but are not limited to:

Encryption of data at rest and in transit
Role-based access controls limiting data access to authorized personnel only
Secure, password-protected workstations and clinical devices
Regular security reviews of our systems and third-party vendors
Staff training on privacy obligations and data handling best practices

No system is completely impenetrable. In the unlikely event of a data breach that poses a risk of serious harm, we will notify affected individuals and the Commission d’accès à l’information du Québec (CAI) as required by Law 25 (Bill 64).

6. Data Retention

We retain your personal and medical information for as long as necessary to fulfill the purposes described in this policy and to comply with applicable legal and professional obligations. As a general guideline:

Medical records and imaging data: minimum 7 years from your last visit, or longer if required by law
Financial and billing records: minimum 7 years for tax and regulatory purposes
Marketing opt-in data: until you withdraw consent
Website analytics data: retained in aggregated, anonymized form

When data is no longer required and is scheduled for deletion, it is destroyed securely in a manner that prevents recovery.

7. Cookies and Digital Tracking

Our websites (skincancermontreal.com and cancerdelapeau.ca) use cookies and similar technologies for basic analytics purposes, such as understanding how visitors navigate our site. We do not use tracking cookies for behavioral advertising. You may adjust your cookie preferences through your browser settings at any time.

8. Your Rights

Under applicable Quebec and Canadian privacy legislation, including Law 25 and the Personal Information Protection and Electronic Documents Act (PIPEDA), you have the following rights with respect to your personal information:

Right to Access: You may request a copy of the personal information we hold about you, including your clinical records and imaging data.
Right to Correction: You may request corrections to inaccurate or incomplete information in your file.
Right to Withdrawal of Consent: You may withdraw your consent to certain uses of your information at any time, subject to legal and professional obligations.
Right to De-indexing: In certain circumstances, you may request the de-indexation of personal information about you from systems where it is no longer necessary.
Right to Complaint: You have the right to file a complaint with the Commission d’accès à l’information du Québec (CAI) if you believe your privacy rights have been violated.

To exercise any of these rights, please contact us using the information provided in Section 10. We will respond within 30 days of receiving your request, or advise you if additional time is required.

9. Minors

Our services are available to individuals who are 18 years of age or older. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will delete it promptly.

10. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or the handling of your personal information, please contact us:

Clinique de Cancérologie Cutanée

38 Place du Commerce, Suite 240

Île-des-Sœurs (Verdun), Montréal, QC H3E 1T8

Email: info@cancerdelapeau.ca

Phone: 514-944-7328

Website: skincancermontreal.com // cancerdelapeau.ca

11. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. When we do, we will revise the “Last Updated” date at the top of this document. Material changes will be communicated to active patients by email. We encourage you to review this policy periodically.

This privacy policy was prepared in accordance with Quebec Law 25, PIPEDA, and applicable professional standards governing medical records in Quebec.