Policies & Procedures
WHAT IS PERSONAL INFORMATION?
WHO WE ARE
WE COLLECT PERSONAL INFORMATION
Like all pharmacies we collect, use and disclose personal information in order to serve our clients.
Treatment: We may use your personal information to provide you with pharmacy or health-related services. We may use your information to co-ordinate care with other pharmacies and health care providers as we have always done in the past. Examples include filling your prescription or speaking to your doctor regarding your prescription for clarification purposes.
Payment: We may use and disclose your personal information in order to receive payment for the drugs you receive. For example, we need to give information about prescriptions we have filled for you to your health plan to obtain payment.
Communication with individuals involved in your care or payment for your care: Health professionals such as pharmacists, using their professional judgment, may disclose to your health care designate any personal information that is directly relevant to your designates involvement in your care or payment for your care.
Health-related educational communications: We may contact you to provide refill reminders such as our web fill or information about treatment alternatives, events in our stores, or other health-related benefits and services that may be of interest to you.
Communication about products and services: We may use and disclose your personal information to tell you about or recommend possible treatment options or alternatives, or to tell you about health-related benefits or services that may be of interest to you.
In order to keep your information up-to-date, the pharmacist and pharmacy staff will discuss with you regularly the personal information we have in our records. They will also remind you why they require your personal information and will ask for your consent to collect and use it.
Other reasons that we may require your personal information
From time to time, we may offer promotions, loyalty programs and other pharmacy services such as wellness programs and health educational events in which you may want to participate. In order to provide you with the full benefit of these services, we may ask you to provide us with certain personal information. At the time of collection, we will advise you of the specific purpose for which the information is required and we will provide you with the option to consent to the collection, use and/or disclosure of that information. If you choose to withhold your consent, we may not be able to provide the service contemplated.
We may use aggregate pharmacy data for research purposes to better serve you, however this information will only be used and analyzed with non personal identifiers.
On our website we will only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a seminar, to subscribe to our newsletter).
Our pharmacy reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, the external consultants (e.g., lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our pharmacy, including reviewing client files and interviewing staff.
Pharmacists are regulated by Professional Colleges and Regulatory Bodies who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals we report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behaviour to authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
You can choose not to be part of some of these related or secondary purposes (e.g., by declining special offers or promotions, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
About Contract Staff, Volunteers and Students
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. Village Pharmacy protects your personal information with safeguards appropriate to the sensitivity of the information.
We protect your personal information by using physically secure facilities, industry-standard security tools and practices. Security measures are in place to prevent the loss, misuse and alteration of the information under our control. To prevent unauthorized electronic access to personal information, we maintain information collected in password-protected environments.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We keep our client files for about ten years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our clients, newsletters, seminars and marketing activities for about six months after the newsletter, seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire client file to our client.
YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
DO YOU HAVE A CONCERN?
Our Information Officer, Mike Hyde, can be reached at:
135 Queen St, Lakefield, ON K0L 2H0
PHONE: 705 652-3300
He will attempt to answer any questions you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
If you have a question about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
College of Pharmacists of Ontario
483 Huron Street , Toronto, ON M5R 2R4
tel 416-962-4861 – toll free 1-800-220-1921
This policy is made under the Personal information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Privacy Commissioner can be reached at:
112 KENT STREET | OTTAWA, ONTARIO | K1A 1H3
PHONE (613) 995-8210 | TOLL-FREE 1-800-282-1376 | FAX (613) 947-6850 | TTY (613) 992-9190 www.privcom.gc.ca