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Commercial Virtual Healthcare Services in Canada: Digital Trails, De-identified Data and Privacy Implications


Women’s College Hospital



Project leader(s)

Sheryl Spithoff


In this analysis, the researchers explore the privacy implications of direct-to-patient commercial virtual care platforms (VCPs) in Canada. A commercial VCP is a proprietary software platform that provides virtual healthcare services performed by a physician or nurse practitioner. The use of VCPs in Canada exploded with the COVID-19 pandemic, transforming access and care while raising concerns about the privacy of health data.

The research paper argues that some of the commercial virtual care industry’s business practices pose threats to patient privacy. Many companies engage in the widespread commercial use and—in some cases—sharing of registration information, de-identified health data and user data. Patients are often unable to opt out of these commercial uses of their data if they want to use the VCP.

Current oversight and monitoring of these services appear to be impaired by gaps in legislation, complex jurisdiction and infrequent audits. The harms caused by these uses of the data are likely to fall disproportionately on marginalized groups. The researchers contend that changes to legislation, regulation and regulatory practices may reduce the risk of such harms. However, if the commercial virtual care industry cannot survive without monetizing data in ways that expose people to harms, the research concludes that public or non-profit models may be more appropriate.

The research report contains several recommendations. Notably, that policymakers and regulators find mechanisms to better protect patient privacy when they interact with commercial VCPs. Policymakers and regulators should also clarify jurisdictional issues and increase protections for personal health information under the Personal Information Protection and Electronic Documents Act. Lastly, they should also bring de-identified health information within the scope of federal and provincial legislation and give it appropriate protections.

Project deliverables are available in the following language(s)


OPC-funded project

This project received funding support through the Office of the Privacy Commissioner of Canada’s Contributions Program. The opinions expressed in the summary and report(s) are those of the authors only and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada. Summaries have been provided by the project authors. Please note that the projects appear in their language of origin.

Contact information

Sheryl Spithoff, Md MSc CCFP (AM)
Women’s College Hospital
76 Grenville Street
Toronto, Ontario M5S 1B2
Phone: 1-416-323-6400 ext. 5729
Email: Sheryl Spithoff

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