Last Updated: January 18, 2022
Who We Are
BounceBack (“us”, “we”, “our”) is a Canadian Mental Health Association, National (CMHA) program. The purpose of BounceBack is to help adults and youth (15+) build skills to manage low mood, mild to moderate depression, anxiety, stress or worry. We understand that we may be handling sensitive personal information and we want to ensure we gain your trust in handling this information. We also strongly believe that your privacy should be protected.
This Privacy Policy details how we collect, use, share, and protect personal information in connection with the services we offer through our English and French websites (referred to as the “Sites”) and through your dealings with us (referred to as the “Program”).
BounceBack does not provide medical services, diagnoses, or counselling. While our questionnaires used in the Program may be similar to those used in diagnosis, BounceBack and our coaches cannot provide diagnoses or medical advice. If you require medical diagnoses or advice, you should speak to your Primary Care Provider.
What is Personal Information?
Personal Information is information that can be used to reasonably identify a person. Personal Information includes information you provide to us voluntarily or information we may collect automatically when you visit our Sites.
Certain information is excluded from this definition, such as specific business contact information, or information that has been made anonymous or has been permanently de-identified, which means that we cannot identify you.
Applicability of This Privacy Policy
This Privacy Policy applies to the National BounceBack Program which serves all regions in Canada where a separate Provincial Program is not offered. These separate Provincial Programs are offered in British Columbia, Ontario, New Brunswick, Quebec and parts of Manitoba. Depending on your province of residence, you may be redirected to a local BounceBack website. Participation in the Program within those provinces are governed by their respective privacy policies.
This Privacy Policy does not apply to CMHA National as a whole, which has its own privacy policy. Click here to access CMHA’s Privacy Policy. Please note that this will redirect you to a different website.
What Information We Collect and How We Use It?
In administering the Program and Sites, we may collect certain information from you. Below are instances in which we may collect and process your Personal Information. You may voluntarily provide us with information, or we may automatically collect certain information via our Sites.
Registering for the Program
When you register for the BounceBack Program, you will be asked for your information. This information is required in order to deliver the Program to you and manage your account. There are three main categories of information we will request from you in order to proceed.
Your Health Information
As part of registering for the Program, we require you to complete eligibility criteria questions to help ensure BounceBack is right for you. This includes a self-assessment asking you to rate your mood, confirm whether you are taking medication for depression or anxiety, and identify certain mental health challenges that apply to you. This information is used to help determine whether BounceBack is a good fit for you.
Should you be eligible for and registered with the Program, your coach will complete another self-assessment with you. This information is collected directly from you and is used to determine any changes to your mood, and to assist you with the CBT materials.
Medical records are not requested from, nor provided by, you or your primary care provider.
Your Personal Information
We will gather details such as your name, contact details, birthdate, gender, and address. We use this information to register you as a participant in the program should you qualify for it.
Your Parent or Guardian’s Information
In cases where you are between the ages of 15 and 18, we will require your parent or guardian’s contact information in order to contact them with your consent or in cases of emergencies. You do not need permission to participate in the program and we ask for this information to ensure we can contact someone in the case of an emergency. Unless your coach believes you are at risk of hurting yourself or someone else, your coach will not contact your parent or guardian, and will never share any personal or private information about you without your permission. One of our coaches will connect with you about this during your first call.
Communicating with your Primary Care Provider
As part of registration, we require the contact information of your Primary Care Provider (PCP), such as a family physician, nurse practitioner or psychiatrist. This information includes their name, contact details, and facility details. We contact your PCP before you join the Program to confirm that you are their patient, and only with your explicit consent. We also keep their contact information in case of an emergency and to update your care provider on your progress.
Communicating With You
To deliver the Program, we need to communicate with you. There are a number of ways in which we will communicate with you during your participation in the Program.
Facilitating the Program
During the Program, your coaches will book appointments with you to discuss your work with the BounceBack Program materials. We use your information provided during registration to contact you, schedule appointments, facilitate coaching sessions, and to determine which material to work on.
Managing Requests
We may use your information to manage additional requests to us or our coaches, such as rescheduling appointments, booking booster sessions, and other requests you make of us.
Surveys that Measure the Effectiveness of Our Program
We collect feedback about our Program by means of surveys when you complete (or leave) the Program. These surveys are optional. Although we collect some of your demographic information, such as your age, gender identity, and your city/town, we do not request your name or contact details. The information provided in these surveys is purely voluntary, and you may choose to leave out information if you are concerned about re-identification.
Usage Data
We automatically collect some information from you, such as the type of mobile device you use, type of browser you use, and unique device identifiers, when you visit our Sites. While most of the information we collect is anonymized and consists of aggregated usage data (such as how many individuals visited our Sites, peak hours of visits, and which page(s) were viewed), we may also collect your Internet Protocol (“IP”) address. We collect this information through the use of cookies, analytics, and similar technologies (See Our Use of Cookies). We collect this information to better understand how our Sites are being used and how we can better improve visitors’ experience on our Sites.
BounceBack Videos
The BounceBack video series is not hosted on the BounceBack Sites, but on a site owned by Five Areas: the provider of the BounceBack material. When you choose to register for the BounceBack Video platform, you will be registering on the Five Areas site which is governed by their own privacy policy, available here. Your information (email address and province) will be collected in order to facilitate your registration and will be shared with CMHA by Five Areas for statistical purposes.
Other Purposes
We may collect your Personal Information and use it for these other purposes, such as:
- To deliver services and features on our Sites and through our Program;
- Keep our Sites secure and safe; and
- Comply with our legal obligations.
We will only use your Personal Information for purposes described in this Privacy Policy or for purposes that we informed you of at the time of collecting your information. If we intend to use or disclose your Personal Information for a new purpose, we will ask you for your consent first, unless we are otherwise permitted by law or court order.
We may use de-identified and aggregated information for research and advocacy purposes. This information, whether used alone or in combination with other information, cannot identify you.
Who Do We Share Your Personal Information With?
We limit who we share your Personal Information with and how much information we disclose.
We may disclose your Personal Information to certain parties under certain circumstances. These parties and circumstances include:
- Primary Care Providers (PCP) in cases of emergencies, such as risk of harm to self or another person, and in advance of your participation in the Program to confirm you are a patient. Information may also be shared with your PCP in terms of changes in your mood and outlook, as well as any changes to participation status including completion of the Program.
- Your Parent or Guardian in case of emergencies (if you are between 15 and 18 years old), or when you have given consent for us to do so.
- Your Coach in order to schedule sessions and deliver coaching services to you. Our coaches are trained to ensure that your privacy and confidentiality are upheld to the highest standard.
- Service Providers in order to deliver the Programs and Sites to you. These providers offer solutions for hosting, marketing, payment processing, and other business critical operations. They are contractually required to comply with our privacy requirements and standards, ensuring that your Personal Information is protected and remains confidential.
- CMHA branches, regions, or divisions, where we share information with them to administer the Program. For example, your coach may be located in a different branch, region, or division. Personal Information that is collected will only be used with authorized CMHA staff to fulfil the purpose for which it was originally collected or for a use consistent with that purpose.
- Authorities such as law enforcement or competent courts, when it is necessary, or we are compelled to do so. This may include instances where there is a serious risk of harm to you or others, and/or where we have to take legal action to protect our or third-party rights.
We may share de-identifiable information with third parties for research purposes or to evaluate the effects of our Program. Individuals will not be identifiable from this information.
We will not sell or rent your Personal Information. Furthermore, our contracts with service providers dictate that they may not use your information for their own benefit or for any services other than those requested by us.
Our Use of Cookies
Our Sites, like most other websites, use cookies, which are small text files installed on your computer when you visit our Sites. Cookies collect non-identifiable information about you and help us understand how visitors use our Sites so we can improve their design, layout, content and function.
We may use first-party, analytics, and third-party cookies on our Sites. First-party and analytics cookies are set and maintained by us, while third-party cookies are maintained by external companies.
Our first-party cookies are used to store your provincial location preferences so that you don’t have to enter them every time you visit our Sites. They also make our Sites more functional.
Analytics cookies are used internally for our research and are not shared with any third-parties. Their purpose is to aid in improving our Sites and services to you. These cookies assess how you interact with our Sites. The information we collect is de-identified.
We may engage third-parties, who use third-party cookies, to monitor and analyze the use of our Sites. For example, we use Google Analytics to track, monitor, and report on traffic to our Sites. Google may track information such as your IP address, the type of web browser being used, and pages visited on our Sites. Any such third-party cookies are governed by the respective terms of service and privacy policies of those providers. For more information on how Google Analytics collects and processes information, please visit Google’s Sites “How Google uses data when you use our partners’ Sites or apps” located at www.google.com/policies/privacy/partners/.
You can delete all cookies that are already on your browser by clearing your browser history. You can also disable cookies being stored on your device; however, this may affect the functionality of our Sites and other sites you have visited. These settings are found in the “Settings” section of your browser.
Be aware that clearing your browser history will clear all of the cookies for all the Sites you have visited, even those where you have opted in. You may also lose saved login information and preferences for other websites.
Where Is Your Personal Information Processed?
All information that we collect from you in the BounceBack program is stored on a secure Canadian-based server.
How Is Your Personal Information Protected?
We have technical, organizational, and physical safeguards appropriate to the sensitivity of your Personal Information. These include safeguards such as ensuring our staff sign confidentiality agreements, limiting access to our facilities, and granting access to information based on a need-to-know basis. We review and update our safeguards regularly to ensure your Personal Information is protected.
It is important to note that no computer system or online communication is perfectly secure. We encourage you to take appropriate steps to protect your information, including not sharing with us more information than is necessary.
How Long Do We Retain Your Personal Information?
We will retain your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy. We will retain the information in accordance with our legal obligation under applicable law, legal agreements, or in the event of a dispute. We may retain de-identified information, which cannot identify you, for longer for internal analysis purposes.
What Are Your Rights?
You have the right to access and correct the Personal Information you provide to us. Simply send us a written request to [email protected]. Before granting you access to your Personal Information, we may need to authenticate you and obtain written authorization. Please note there may be exceptional circumstances, in accordance with law, that we will be unable to grant you access or correct your information. If this is the case, we will inform you and provide you with a reason why we cannot fulfill your request.
While you may update your information, it is your duty to ensure you provide us with accurate and up-to-date information, such as your contact information if you would like to receive newsletters from us.
At any time, you may also withdraw your consent to have your Personal Information processed. You may also withdraw your consent for us to contact your PCP. In order to withdraw your consent, you can send us a written request to [email protected]. If you wish to stop receiving marketing or promotional emails from us, including newsletters, you can opt-out of these communications by unsubscribing directly in the email or by contacting us.
Changes To The Policy
This Privacy Policy is current as of the date, which appears at the top. We recommend that you read this Privacy Policy carefully on a periodic basis as we may revise it from time to time. When you share your Personal Information with us, you consent to the collection and processing of your Personal Information as described in this Privacy Policy.
Contact Us
If you have any questions or concerns, we would like to address them. Please contact us at [email protected] or
Canadian Mental Health Association, National
250 Dundas St. West, Suite 500
Toronto, Ontario
M5T 2Z5
(416) 646-5557