| PhotoCounter by
Procurity Inc.
("Procurity")
PRIVACY POLICY
Established in 1978 (formerly known as United Pharmacists Ltd.), Procurity
is the purchasing, distribution, and marketing arm supplying and servicing a network of
pharmacies across Canada. Procurity is 100% owned and operated by independent pharmacists
and is governed by a Board of Directors.
In the course of carrying on its business, namely the purchase, distribution
and marketing of pharmaceuticals, private label products and over 50,000 products to be
distributed for retail sale, as well as the provision of services to its customers including
training and merchandising seminars and administering advertising programs. Procurity
must collect, use and disclose certain personal information about its customers and others.
Procurity understands the importance of keeping your personal information
confidential. Procurity is committed to protecting the confidentiality of the personal
information that you provide and is dedicated to upholding certain confidentiality obligations
at law, pursuant to the Personal Information Protection and Electronic Documents Act and
Regulations, and as set out in this Privacy Policy.
To comply with its obligations at law, Procurity has undertaken to
ensure that its employees, agents and authorized persons take all reasonable steps to
protect the confidentiality of personal information. Procurity's obligations include the
protection of personal information from risks such as inappropriate collection, use, disclosure,
storage or destruction. Procurity has appointed a Privacy Officer who is accountable for
Procurity's compliance with its obligations at law. The Privacy Officer may appoint other
individuals to take responsibility for the day-to-day collection and processing of personal
information.
If there are any matters that have not been expressly addressed in
this Policy, or (i) if an individual requires clarification as to how to implement or
interpret this Policy, or (ii) if an individual would like to request access to his or
her personal information or to amend such information, such concerns should be brought
to the attention of the Privacy Officer immediately.
The Privacy Officer can be contacted as follows:
Mail - Procurity Inc.
Attn: Nathalie Veillette, Privacy Officer
160 Eagle Drive
Winnipeg, Manitoba
R2R 1V5
Direct Line - (204) 631-3533I. Definitions
1.1 The following definitions are to assist in the
interpretation of this Privacy Policy and are subject to change given amendments to applicable
legislation:
(a) "collection" means the
gathering, acquiring, recording, or obtaining of personal information from any source,
including third parties, whether written or verbal;
(b) "consent" means voluntary agreement for
the collection, use and disclosure of personal information for defined purposes. Consent
can be either expressed or implied and can be provided directly by the individual or by
an authorized representative. Express consent can be given orally, electronically or in
writing, but is always unequivocal and does not require any inference on the part of Procurity.
Implied consent is consent that can reasonably be inferred from an individual's action
or inaction;
(c) "commercial activity" means any particular
transaction, act or conduct or any regular course of conduct that is of a commercial character,
including the selling, bartering or leasing of donor, membership or other fundraising
lists;
(d) "disclosure" means making personal information
available to a third party;
(e) "personal information" means information
about an identifiable individual, but does not include the name, title or business address
or telephone number of an employee of an organization;
(f) "record" includes any correspondence,
memorandum, book, plan, map, drawing, diagram, pictorial or graphic work, photograph,
film, microfilm, sound recording, video-tape, machine-readable record and any other documentary
material, regardless of physical form or characteristics, and any copy of any of those
things; and
(g) "third party" means an individual or
organization outside of Procurity. II. Application of the Privacy Policy
2.1 This Privacy Policy applies to all personal information
collected, used, stored or destroyed by Procurity, where Procurity has collected, used,
stored or destroyed such information in the course of commercial activity.
2.2 This Privacy Policy applies to all personal information,
including all records of personal information, whether written, photographed, recorded
or stored in any manner, on any storage medium or by an means including by graphic, electronic
or mechanical means.
2.3 This Privacy Policy applies to all personal information,
regardless of whether it was received, collected or acquired prior to or after the implementation
of the Policy.
2.4 This Privacy Policy governs the conduct of all
employees and agents of Procurity and each employee and agent shall sign a "Pledge
of Confidentiality" in the form attached hereto as Schedule "A", acknowledging
that he or she is bound by the terms of this Privacy Policy and is aware of the consequences
of breaching the Policy.
2.5 Should Procurity transfer personal information
to a third party for processing or other permitted transactions, it shall use contractual
or other means to provide a comparable level of protection which the information is being
processed by a third party. III. Access to Personal Information
3.1 Upon request, an individual shall be informed of
the existence, use and disclosure of his or her personal information and shall be given
access to that information, subject to certain exceptions specified by law. An individual
shall be able to challenge the accuracy and completeness of the information and have it
amended as appropriate.
3.2 Where Procurity records contain information about
a third party, Procurity shall not provide access to such information unless the information
applicable to the third party can be severed from the record.
3.3 All requests for access or amendment to personal
information by the person who is the subject of the information shall be made in writing
to the Privacy Officer. Where an employee of Procurity receives such a request, it shall
be forwarded to the Privacy Officer forthwith.
3.4 In releasing personal information to an individual,
Procurity shall indicate the source of the information and shall provide an account of
the use that has been made or is being made of this information and an account of the
third parties to which it has been disclosed, namely the name of the organizations to
which the personal information has been disclosed and if possible, shall specify the information
disclosed.
3.5 The Privacy Officer shall respond to a request
for access to personal information or requesting an amendment to such personal information
within 30 days. Should the Privacy Officer determine, on a reasonable basis, that a request
for an amendment to such personal information is appropriate, the Privacy Officer shall
ensure that the personal information is amended accordingly and where appropriate, the
amended information shall be transmitted to third parties having access to the information
in question.
3.5 If however, the Privacy Officer determines that,
at law, no access to the record of personal information shall be granted, the Privacy
Officer shall keep a record of the refusal, including reasons for refusal on file.
3.6 When a challenge concerning the accuracy or completeness
of personal information has been made, but has not been resolved to the satisfaction of
the individual, the Privacy Officer shall keep a record of the substance of the unresolved
challenge, and where appropriate, shall transmit the existence of the unresolved challenge
to third parties having access to the information in question. IV. Purposes for Collection
and Use of Personal Information
4.1 Procurity shall only collect personal information
for the following purposes:
• to process applications for services and to establish credit facilities;
• to provide customers with updates regarding issues, products or services concerning
the pharmaceutical and retail sales industries,
• to process sales and to facilitate collections;
• to keep track of its customers' sales volumes and production statistics over time
and to provide such information from time to time to pharmaceutical companies and others
in accordance with existing company practice and/or as is standard in the pharmaceutical
industry.
4.2 In certain circumstances, personal information
can be collected, used or disclosed without the knowledge or consent of the individual.
Procurity will only engage in such conduct where required or permitted to do so by law.
4.3 The identifiable personal information collected
will only be used for the specified purposes. For greater certainty, Procurity may compile
certain statistics using or based upon personal information and may provide such statistics
to third parties upon request.
4.4 Unless permitted by law, personal information will
be collected directly from the individual who is the subject of the information. Procurity
shall, generally speaking, obtain consent concerning the collection and use of personal
information.
4.5 An individual may withdraw consent at any time,
subject to legal or contractual restrictions and reasonable notice. V. Limiting Use, Disclosure
and Retention
5.1 Personal information shall not be disclosed for
purposes other than those for which it was collected, except with the consent of the individual
or as required or permitted by law.
5.2 Procurity shall retain files containing personal
information for a period of no longer than 7 years from the termination of the customer
relationship.
5.3 Personal information that is no longer required
by Procurity to fulfill the purposes for which the information was collected shall be
shredded and disposed of in a manner that safeguards the confidentiality of the information.
VI. Safeguarding Personal Information
6.1 Procurity shall take reasonable steps to protect
personal information against loss or theft, as well as unauthorized access, disclosure,
copying, use or modification of personal information. All personal information under the
custody or control of Procurity in written form shall be kept in locked filing cabinets
or in secured office space and access to such files shall be limited to those employees
who require access in order to complete their duties. Personal information that is stored
electronically shall be protected by an appropriate firewall and password encrypted.
6.2 The Privacy Officer shall, on a regular basis,
ensure that such office policies are being adhered to and that all such personal information
is being stored and safeguarded in accordance with this Privacy Policy. VII. Challenging
Compliance
7.1 Should an individual have issue with the manner
in which Procurity, its employees or agents are collecting, using, storing, disclosing
or destroying information, he or she may contact the Privacy Officer at the address previously
set out above.
7.2 The Privacy Officer shall have 30 days from receipt
of the complaint to investigate the complaint and to provide a response, including the
remedy to be employed, if any.
|
