We are bound by the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy legislation. This legislation is designed to protect the confidentiality of personal information and the privacy of individuals by regulating the way personal information is collected, used, disclosed and otherwise managed.
Information about PIPEDA, as well as links to resources about applicable provincial privacy legislation, may be accessed from the website of the Office of the Federal Privacy Commissioner at http://www.priv.gc.ca/ Opens in new window
Personal information collected by us
We collect personal information for many aspects of our activities, including the following:
Healthcare Professionals and their Staff
We collect personal information about healthcare professionals such as physicians and pharmacists who prescribe and dispense our products so that we can communicate with them. This information may include an individual’s name, contact details, specialty, and areas of interest. In most cases, if you do not provide information about yourself which we have requested, we may not be able to provide you with the relevant service or information required.
We may collect personal information about healthcare professionals/investigators who are interested in conducting clinical trials with us, and their staff who assist in conducting the clinical trials. This personal information is provided voluntarily by healthcare professionals through surveys and questionnaires, and generally includes the individual’s name, address, telephone details, area of expertise, past experience, financial information, research interests, qualifications, and position, including information provided on Curriculum Vitae.
We do not collect personal information from members of the public or patients but may obtain it through our websites or during business activities both in writing and from telephone inquiries. We may use this personal information solely for the purpose of managing services to which the individual is enrolled, either directly or through third party contractors, for the purpose of responding to an inquiry made to us by the individual, or in connection with a product complaint or adverse event. Generally, the type of information we collect in these situations includes a person’s name and contact details and information relating to the service being provided or the inquiry made by the individual.
Patients may participate in clinical trials of biopharmaceutical products as part of our medical research and development programs. The trials are conducted by hospitals or other institutions, but are funded and supported by us. Patients who participate in these clinical trials provide express written consent to the manner in which their personal information will be collected, used, transferred, accessed and/or disclosed in connection with the research related to the trial.
Generally, we only receive de-identified information relating to clinical trial patients from physicians and investigators conducting the clinical trial. Personal identifiers related to this information, such as the patient’s name and residential address, are not collected by us except in limited circumstances and only with the patient’s express consent. These circumstances include certain clinical trials where our employees or our authorized contractors may view personal information at a clinical trial site to audit and/or monitor the trial and to comply with regulatory requirements.
In general, we use personal information for the following purposes:
- To maintain a record of medical queries, complaints and adverse event reports relating to our products and, as required by law, reporting these to relevant regulatory agencies (e.g., Health Canada’s Health Products and Food Branch).
- To provide requested products or services.
- For administering conferences, symposia, seminars or other similar programs that we organize.
- To involve physicians/investigators (and the people who assist them) in clinical trials in accordance with Good Clinical Practice, International Conference of Harmonization, and regulatory requirements.
- To notify you of matters of which we may be required by law to notify you (e.g., product recalls).
- To coordinate and manage the relationships between healthcare professionals/investigators and our sales and marketing staff and scientific affairs departments, as applicable.
- To conduct market research.
- For the purpose of improving our products and services.
We may transfer personal information on a confidential basis to our affiliates worldwide and third party contractors or service providers within or outside of Canada. These companies, which are engaged by us to provide services such as, database management, specialist mailing services, care management services, conference organization, marketing or advertising services, or clinical trial-related activities, will receive personal information necessary for the purposes for which they are engaged. We remain accountable for all personal information we transfer to these third party contractors and service providers, and take appropriate measures to ensure that these third parties safeguard the confidentiality of all personal information.
There may be circumstances where we share your personal information with third party contractors and service providers (including our affiliates) that are located outside Canada. In particular, your personal information may be stored on servers in the United States, Europe and other countries and may therefore be subject to other additional local legislation. Other jurisdictions, including the United States, may have laws and regulations that require the disclosure of personal information to governmental authorities under different circumstances than would Canada.
We may disclose personal information to third party manufacturers and service providers in circumstances involving a product or service complaint received by us, or to regulatory bodies where we are under a legal obligation to provide personal information. We may also disclose personal information for the purposes of an emergency that threatens the life, health or security of an individual. If such a disclosure is made, we will notify the individual about whom personal information was disclosed.
In addition, we must provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law. We may also disclose personal information to assist us in collecting a debt owed by you.
We reserve the right to transfer any information we have about you in the event we merge with, sell or transfer all or a portion of our business or assets to another party.
Personal information – Management and Security
We endeavour to ensure that the personal information we hold is accurate, complete and up-to-date.
The protection of your privacy and the safety of your personal information are very important to us. We will retain your personal information only for the time it is required for the purpose for which it was collected and to comply with applicable laws. We will securely destroy obsolete personal information.
- Chief Privacy Officer
- Email: email@example.com