TREAN
Trean Clinical Services Inc.

Patient Privacy Policy

Version 1.2 · Effective 19 September 2026

1. Who we are

Trean Clinical Services Inc. is an independent medical practice. We are the health information custodian for your personal health information under Ontario’s Personal Health Information Protection Act, 2004 (PHIPA). Decisions about your health record are made here.

Medical Director: Dr Karim Vellani, MD CCFP, CPSO #97637. Care is provided by physicians registered with the College of Physicians and Surgeons of Ontario. Prescriptions are reviewed by a pharmacist registered with the Ontario College of Pharmacists.

Trean Health Inc. provides our technology platform and acts as our agent for that purpose. It handles your information only on our instructions and only to help us provide care.

Contact

Privacy Officer / Contact Person for the purposes of PHIPA s.15:

2. What we collect

CategoryWhat it includes
IdentityName, date of birth, contact details, province, and your health card number where the service is insured
ClinicalHistory, medications and supplements, symptoms, allergies, family history, consultation notes, prescriptions, laboratory results
MeasurementsVO2, grip strength, resting metabolic rate and body composition, where you have them
Wearable data you choose to shareResting heart rate, heart-rate variability, sleep duration, steps and workout summaries
CorrespondenceSecure messages between you and your care team

Wearable measures we deliberately do not take: sleep staging, blood oxygen, and proprietary readiness or recovery scores. These are either not accurate enough to act on clinically or not transparent enough to verify. The exclusion is enforced by the system rather than left to judgement.

Every value in your record carries its source and how reliable that source is, so a laboratory result and a wrist reading are never treated as the same kind of evidence.

3. Why we collect it

We do not use your personal health information for marketing. Information you share for care is used for care. No automated process generates a message, recommendation or offer to you from your clinical data.

4. Consent

Within your circle of care. Your clinician may rely on your implied consent to share information with other custodians involved in your care — the pharmacy dispensing your prescription, the laboratory doing your bloodwork, a specialist we refer you to, or your family physician.

Outside it. A trainer or coach is not a health information custodian. Nothing is shared with them unless you give express, written consent that names the person, states the categories of information, and can be withdrawn at any time without affecting your care.

Withholding or withdrawing consent. You may restrict what we share, including in part. If a restriction could affect our ability to care for you safely, your clinician will tell you. In some cases the law requires us to notify a recipient that information has been withheld.

5. Virtual care, and its limits

Care delivered electronically carries risks that in-person care does not. We use reasonable safeguards, but no electronic system can be guaranteed secure. Specifically:

6. Who we share with, and where it is held

RecipientWhyWhere
TELUS HealthOur clinical record systemCanada
LifeLabsLaboratory testing you consent toCanada
Your pharmacyDispensing a prescriptionCanada
Your family physician or a specialistReferral and continuity of careCanada
Your trainerOnly with express written consent, limited to agreed categoriesCanada
OHIPBilling for insured servicesCanada

We disclose outside these purposes only where the law requires or permits — a legal order, a mandatory report, or where there is a significant risk of serious bodily harm.

7. Your rights

Information and Privacy Commissioner of Ontario · 2 Bloor Street East, Suite 1400, Toronto ON M4W 1A8 · 1-800-387-0073 · ipc.on.ca

8. Safeguards

If there is a breach, we will notify you at the first reasonable opportunity and notify the Information and Privacy Commissioner of Ontario where PHIPA requires. We keep a record of every privacy breach and report statistics to the Commissioner annually.

9. How long we keep your record

Medical records are retained for at least 10 years after your last interaction with us, or for a patient who was a minor, 10 years after the day they turned 18. These periods are set by law and by our regulator. We cannot delete a clinical record on request.

10. Changes

We will post any updated version with a new date and tell you directly where a change is significant.