PRIVACY
POLICY
INTRODUCTION
Canada US Pharmacy Inc. (the "Pharmacy")
is committed to preserving the privacy interests of its
customers in regard to both personal information and personal
health information, collectively referred to as Personal
Information, that is submitted by its valued customers.
The Pharmacy is dedicated to maintaining the accuracy,
confidentiality and security of information provided to
it, and accordingly, has developed a strict Privacy Code
to be followed in dealing with Personal Information.
The following Privacy Code applies to all Personal Information
managed and maintained by the Pharmacy, whether provided
orally, electronically or in writing. It should be noted
that the Privacy Code does not impose any limits on the
collection, use or disclosure of information that is publicly
available. This Privacy Code is subject to the requirements
or provisions of any applicable legislation, regulations
or agreements, orders of any court, or other lawful authority.
PRIVACY CODE - SUMMARY OF
PRINCIPLES
Principle 1 - Accountability
The Pharmacy is responsible for
the personal information provided to it which is under
its control, and has designated an employee, the Personal
Information Manager, to ensure that the Pharmacy is in
compliance with the following principles and to receive
any inquiries in regard to the Personal Information.
In the event that Personal Information in the control
of the Pharmacy must be transferred to a third party,
the Pharmacy shall use contractual and other means to
provide a comparable level of protection while the Personal
Information is in the custody of the third party.
The Pharmacy shall implement policies and procedures to
ensure that the provisions of this Privacy Code are being
met, including procedures to protect Personal Information
and the development of a Personal Information inquiry
process. The Pharmacy shall obtain a Pledge of Confidentiality
from its employees concerning the Personal Information.
Principle 2 - Identifying
Purposes for Collection, Use or Disclosure of Personal
Information
The Pharmacy collects Personal Information
in order to provide pharmacy services to its Customers,
and accordingly, will require detailed Personal Information.
The Pharmacy shall identify any additional purposes for
the collection of such Personal Information at or before
the time it is collected, and the Pharmacy shall use the
Personal Information solely for the purpose for which
it was collected.
Principle 3 - Obtaining
Consent for Collection, Use or Disclosure of Personal
Information
The Pharmacy shall collect, use
and disclose the Personal Information only with the knowledge
and consent of the Customer, except in circumstances where
this would be impossible or inappropriate, such as when
the Customer is a minor, seriously ill or mentally incapacitated.
The Pharmacy will generally seek consent to use and disclose
the Personal Information at the time it is collected,
but may in certain circumstances be forced to request
consent at a later date.
It should be noted that the Pharmacy will require Customers
to consent to the collection, use and disclosure of certain
Personal Information as a condition of supply of goods
or services, should the Pharmacy deem such Personal Information
a requirement of fulfilling the purposes identified.
The Pharmacy may collect, use or disclose Personal Information
without knowledge or consent if there is an emergency
where the life, health or security of the Customer or
an individual is threatened, where required by law, including
court order or subpoena, or where such disclosure is to
the lawyer representing the Pharmacy, to collect a debt
or respond to any issues relating to the Personal Information.
Principle 4 - Limiting Collection
of Personal Information
The Pharmacy shall collect only
that Personal Information necessary for the purposes identified
to the Customer at or before the time of collection.
Principle 5 - Limiting Use, Disclosure and Retention of
Personal Information
The Pharmacy shall not use or disclose
Personal Information for purposes other than those for
which it was collected, except with the consent of the
Customer or as required by law.
For greater
certainty the Pharmacy shall not use, provide, disclose
or cause to be used Personal Information for any
purposes commercial or otherwise other than those for
which it was collected.
Personal Information shall
be retained only as long as necessary to fulfill the purposes
for which it was collected.
The Pharmacy has developed guidelines concerning the destruction
of Personal Information, in that Personal Information
that is no longer required to fulfill the identified purposes
shall be destroyed, erased or made anonymous.
Principle 6 - Accuracy
Personal Information that is maintained
by the Pharmacy shall be as accurate, complete, and up-to-date
as is necessary for the purposes for which it is used.
The Pharmacy shall confirm all Personal Information collected
from Customers each time additional goods and/or services
are requested.
Principle
7 - Security Safeguards
Given the sensitive nature of the
Personal Information collected, the Pharmacy shall employ
security safeguards appropriate to the sensitivity of the
information, and shall focus on the protection of the Personal
Information against loss or theft, unauthorized access,
disclosure, copying, use or modification.
The Pharmacy shall implement controls that limit who has
access to the Personal Information maintained by the Pharmacy,
such that the Personal Information Manager shall authorize
access to the Personal Information only to those employees
who must have access in the general course of their duties.
Given that the Pharmacy receives information in electronic
form, it shall implement appropriate additional safeguards
to protect information stored in this manner, and shall
produce an electronic record of every successful or unsuccessful
attempt to gain access to the Personal Information, to add
to, delete or modify the Personal Information, and that
records every transmission of Personal Information using
electronic means.
Principle 8 - Openness
The Pharmacy shall make specific Personal
Information readily available to the Customer, and shall
train the Pharmacy's employees in regard to the practices
and policies to be used when dealing with Personal Information.
Principle 9 - Customer and
Employee Access to Personal Information
The Pharmacy shall inform the Customer
of the existence, use and disclosure of his or her Personal
Information and shall grant the Customer access to his or
her Personal Information. The Customer shall be able to
challenge the accuracy and completeness of the information
and to have it amended accordingly. If for some reason,
access cannot be granted, the reasons for denying access
should be provided to the Customer upon request.
Principle 10 - Challenging
Compliance
The Customer shall be able to address
a challenge concerning compliance with the Personal Information
Manager.
|
