This policy explains how Celestra Health Systems protects personal health information related to our Gait Measurement Platform.
Last updated: 16 January 2025
Commitment to Privacy
The appropriate collection, use and disclosure of patients’ personal health information is fundamental to everything that we do. All employees of Celestra Health Systems abide by our commitment to privacy in the handling of personal information.
Applicability of This Privacy Policy
Our Privacy Policy attests to our commitment to privacy and demonstrates the ways we ensure that patient privacy is protected. Our Privacy Policy applies to the personal health information of all our patients that is in our possession and control. This information includes, but is not limited to, data collected via the Celestra Health smart phone app, including walking-related data collected from 3rd party smart insoles, results from digital self-assessment tests, exercise-related data collected from the patient’s smart phone, responses to digital surveys, patient journaling, patient identity (such as name and date of birth) and contact information.
What is Personal Health Information?
Personal health information means identifying information about an individual relating to their health, including health-related digital survey responses and contact information. Refer to the previous section for a description of the type of data collected.
The 10 Principles of Privacy
Our Privacy Policy reflects our compliance with fair information practices, applicable laws and standards of practice.
1. Accountability
We take our commitment to securing patient privacy very seriously. Each Celestra Health employee is responsible for the personal information under his/her control. Our employees are informed about the importance of privacy and receive information periodically to update them about our Privacy Policy and related issues.
2. Identifying Purposes: Why We Collect Information
We ask you for information to establish a relationship and serve your medical needs. We obtain most of our information about you from you, based on information that you manually input into the Celestra Health app on your smart phone, else from data that we collect with your approval on an ongoing basis.
The Celestra Health platform relies on smart insoles to collect raw walking data from patients with neurological conditions such as Multiple Sclerosis (MS) and Parkinson’s Disease. The data collected from the smart insoles includes pressure sensor, gyroscope and accelerometer data. This raw data is securely transmitted to the cloud, where our proprietary machine learning algorithms are used to calculate key gait metrics for each walking session; a walking session is typically of 10-to-15-minute duration and is conducted in the patient’s natural environment-. These metrics are used to detect subtle changes in walking quality over time and are shared with your clinician.
We will limit the information we collect to what we need for gait measurement purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose.
3. Consent
You have the right to determine how your personal health information is used and disclosed. For most health care purposes, your consent is implied as a result of your consent to use the Celestra Health Gait Measurement Platform. Within the Celestra Health smart phone app, you will be presented with various options to control what information you are willing to share with Celestra Health.
Patients can withdraw consent at any point by contacting their clinician and requesting that their Celestra Health account be terminated and that their data be deleted.
4. Limiting Collection
We collect information by fair and lawful means and collect only that information which may be necessary for purposes related to the provision of the Celestra Health Gait Measurement Platform.
5. Limiting Use, Disclosure and Retention
The information we request from you is used for the purposes defined. We will seek your consent before using the information for purposes beyond the scope of the posted Privacy Policy.
Under no circumstances do we sell patient lists or other personal information to third parties.
We will retain your information only for the time it is required for the purposes we describe and once your personal information is no longer required, it will be destroyed.
6. Accuracy
We endeavour to ensure that all health information that we collect is accurate; however, we rely on you to disclose all material information and to inform us of any relevant changes.
7. Safeguards: Protecting Your Information
We protect your information with appropriate safeguards and security measures. Celestra Health maintains personal information in the form of electronic files stored in the cloud.
Access to personal information will be authorized only for the clinicians and employees associated with Celestra Health’s Gait Measurement Platform, and other agents who require access in the performance of their duties, and to those otherwise authorized by law.
Celestra Health uses advanced encryption and protection of all patient data. All in-transit data sent from the smart insoles to the Celestra app uses 128-bit Advanced Encryption Standard - Counter with CBC-MAC (AES-CCM) to create a 128-bit “shared secret” key. In-transit data sent between the Celestra app and the cloud is protected by using SSL 1.2 (2048 bit). Data at rest is encrypted when stored in our cloud-based database.
All data stored in our database is automatically backed up on a regular basis. All backups are automatically encrypted, cataloged, easily discoverable, and retained until explicitly deleted.
We provide information to your clinician acting on your behalf, on the understanding that your clinician is also bound by law and ethics to safeguard your privacy. Other organizations and agents must agree to abide by our Privacy Policy and may be asked to sign contracts to that effect. We will give them only the information necessary to perform the services for which they are engaged, and will require that they not store, use or disclose the information for purposes other than to carry out those services.
The cloud-based public infrastructure used by Celestra Health is password-secured and configured in such a way that only authorized individuals can access secure systems and databases. We use serverless technology from a leading public cloud computing provider - this cloud-native development model allows Celestra Health to build and run applications without having to manage servers. And while Celestra Health’s backend system is partitioned to ensure that patient data is only accessible to the applicable patient and their clinician, Celestra Health does not control the exact location in which the patient’s data is physically stored but does have control over selecting the country or region in which the data is physically stored.
Audit trails are always in effect and can be used to determine exactly which information was accessed and/or updated and by whom. Each audit event includes information, such as who performed an action and when, which resources were impacted, and many other details.
Application Security Testing is performed by a 3rd party agency every 6 months to assess all components of our Gait Measurement Platform for security vulnerabilities. Similarly, Business Continuity testing is conducted every 6 months, or upon significant environment changes, to ensure continuing effectiveness.
Through the use of a leading public cloud computing provider, Celestra Health complies with ISO 27018, a code of practice that focuses on protection of personal data in the cloud. It extends ISO information security standard 27001 to cover the regulatory requirements for the protection of Personally Identifiable Information (PII) or personal data for the public cloud computing environment and specifies implementation guidance based on ISO 27002 controls that is applicable to PII processed by public cloud service providers.
Furthermore, Celestra Health’s public cloud provider’s infrastructure is regularly validated by third-party agencies against security and compliance standards for finance, retail, healthcare, government, and beyond. Supported security standards and compliance certifications include PCI-DSS, HIPAA/HITECH, FedRAMP, GDPR, FIPS 140-2, and NIST 800-171.
If you send us an e-mail message that includes personal information, such as your name included in the "address", we will use that information to respond to your inquiry. Please remember that e-mail is not necessarily secure against interception. If your communication is very sensitive, you should not send it electronically unless the e-mail is encrypted, or your browser indicates that the access is secure.
8. Openness: Keeping You Informed
Celestra Health has prepared this plain-language Privacy Policy to keep you informed. You may view a copy by visiting our website at www.celestrahealth.com.
In the unlikely event of a data breach, our cloud provider publishes public notifications in the form of Security Bulletins, which are monitored by Celestra Health. Celestra Health will, in turn, notify in a timely manner, all patients that have been directly impacted by the breach.
If you have any additional questions or concerns about privacy, we invite you to contact us by e-mail at privacy@celestrahealth.com and we will address your concerns to the best of our ability.
9. Access and Correction
With limited exceptions, we will give you access to the information we retain about you within a reasonable time, upon presentation of a written request and satisfactory identification.
If you find errors of fact in your personal health information, please notify us as soon as possible and we will make the appropriate corrections.
If we deny your request for access to your personal information, we will advise you in writing of the reason for the refusal and you may then challenge our decision.
10. Challenging Compliance
We encourage you to contact us with any questions or concerns you might have about your privacy or our Privacy Policy. We will investigate and respond to your concerns about any aspect of our handling of your information.
In most cases, an issue is resolved simply by telling us about it and discussing it. You can reach us by email, else by writing to us at the following address:
Celestra Health Systems / Privacy Officer
390 March Road, Suite 110,
Ottawa, Ontario, Canada K2K 0G7
If, after contacting us, you feel that your concerns have not been addressed to your satisfaction, you have the right to complain to the Ontario Information and Privacy Commissioner (IPC). The Commissioner can be reached at:
2 Bloor Street East, Suite 1400,
Toronto, Ontario, Canada M4W 1A8
1-800-387-0073
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