Privacy policy

Who we are

Your Functional Health (“we,” “us,” “our”) is a virtual hormone therapy clinic serving patients located in British Columbia. Care is provided by Xenia Kempf, MSN, Nurse Practitioner, registered with the BC College of Nurses and Midwives (BCCNM).

This policy explains how we collect, use, disclose, store and protect your personal information, including your personal health information, and the choices and rights you have. It applies to our website and to the care we provide.

As a private health practice in British Columbia, we are governed by BC’s Personal Information Protection Act (PIPA) and by the professional standards of BCCNM.

Our privacy officer

Xenia Kempf is our privacy officer and is accountable for how we handle personal information. Questions, requests and concerns about privacy can be sent to xenia@yourfunctionalmednp.com.

Information we collect

Information you give us

• Contact and identity details: name, date of birth, address, email, phone number and BC Personal Health Number (PHN).
• Health information: medical history, symptoms, medications, allergies, family history, lab results, intake questionnaires and anything you share during consultations.
• Insurance and billing details: extended health plan information you choose to give us, and payment information processed through our booking platform.
• Pharmacy and care team details: your preferred pharmacy and, if you choose, your family doctor or nurse practitioner.

Information we create

• Clinical notes, assessments, treatment plans, prescriptions, lab requisitions and correspondence that form your health record.

Information collected when you use our website

• Our website does not use analytics or advertising cookies. Like any website, our hosting provider may keep basic server logs such as IP address, browser type and pages visited, for security and reliability.
• Pages on our site load fonts from Google Fonts and some images from third-party image services. These providers may receive your IP address when the page loads, under their own privacy policies.

We do not record video consultations.

How we use your information

We use your personal information only for purposes a reasonable person would consider appropriate, including to:

• assess your health, provide treatment and monitor your care;
• order and review laboratory tests and send prescriptions to your pharmacy;
• book, confirm and manage appointments and send reminders;
• communicate with you about your care;
• process payments and issue receipts for insurance claims;
• meet our legal, regulatory and professional obligations, including record-keeping required by BCCNM;
• maintain the security and quality of our services.

We do not sell your personal information, and we do not use your health information for marketing.

Consent

By booking with us and providing your information, you consent to its collection, use and disclosure for the purposes described in this policy. For purposes directly related to your care, consent may be implied. We will ask for your express consent before using or disclosing your information for any other purpose, unless the law permits or requires otherwise.

You may withdraw your consent at any time, subject to legal or professional obligations, by contacting our privacy officer. Withdrawing consent may affect our ability to continue providing care, and we will explain any such consequences.

When we share information

We share your information only as needed to provide your care, with your consent, or as required or permitted by law:

• Laboratories (such as LifeLabs and Dynacare) to process tests we order;
• Pharmacies you choose, including compounding pharmacies when needed, to fill prescriptions;
• Your family doctor or other providers, with your consent, to coordinate your care;
• Your insurer, only if you ask us to provide information for a claim;
• Service providers who support our practice (listed below), under confidentiality obligations;
• Regulators and authorities where the law requires it, such as a BCCNM request, a court order, or a duty to report.

Service providers and storage

We use trusted third-party providers to run the practice, including:

• Practice Better for electronic health records, booking, secure messaging, video consultations, forms and payment processing;
• Google Workspace for email;
• a website hosting provider.

These providers may store or process information on servers in Canada, the United States or elsewhere. Information stored outside Canada may be subject to the laws of that country, including access by authorities there. We choose providers that use industry-standard safeguards and contractually limit their use of your information to the services they provide to us.

How we protect your information

We use reasonable administrative, technical and physical safeguards to protect your information against unauthorized access, use, disclosure, copying, modification or destruction. These include encrypted platforms, access controls, strong passwords with multi-factor authentication, and secure devices.

If a privacy breach occurs that creates a real risk of significant harm to you, we will notify you and take steps to contain it, and will notify regulators where required.

How long we keep records

We keep your health record for the period required by BCCNM and applicable law, even after you stop receiving care from us. When records are no longer required, we destroy them securely.

Under PIPA, if we use your personal information to make a decision that directly affects you, we keep that information for at least one year after the decision so you have a reasonable opportunity to access it.

Your rights: access and correction

You have the right to:

• access the personal information we hold about you and learn how it has been used and to whom it has been disclosed;
• request a correction if you believe information is inaccurate or incomplete.

Send requests in writing to our privacy officer. We will respond within the time limits set by PIPA, generally within 30 business days. We may charge a minimal fee for copies, and will tell you the cost in advance. In limited cases the law allows or requires us to refuse access, for example where disclosure could threaten someone’s safety; if so, we will explain why.

If we do not make a requested correction, we will note your request on your file.

Questions and complaints

Please contact our privacy officer first. We take concerns seriously and will try to resolve them promptly.

If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner for British Columbia at oipc.bc.ca. Concerns about professional conduct can be raised with the BC College of Nurses and Midwives at bccnm.ca.

Changes to this policy

We may update this policy from time to time. The “last updated” date at the top shows when it was last revised. Significant changes will be posted on this page.