Privacy Policy (Last updated:
October, 2005)
ASTRAZENECA CANADA’S PERSONAL INFORMATION MANAGEMENT PRACTICES
AstraZeneca Canada Inc. (“AstraZeneca Canada”) is committed to controlling
the collection, use and disclosure of personal information.
AstraZeneca Canada collects, uses and discloses various types of personal
information in carrying on business, including information about health care
professionals (including physicians, pharmacists and other health care workers),
patients, participants in clinical studies, customers and employees.
AstraZeneca Canada collects, uses and discloses personal information in
accordance with the following ten fair information principles.
Principle 1 - Accountability
Principle 2 - Identifying Purposes
- 2.1 AstraZeneca Canada collects, uses and discloses personal information for a range of purposes.
- 2.2 AstraZeneca Canada may from time to time collect, use and disclose personal
information about health care professionals for legitimate business purposes
that include satisfying regulatory requirements, conducting clinical studies in
which health care professionals have agreed to participate, establishing and
managing a customer relationship profile, marketing AstraZeneca Canada products
and services, responding to requests about AstraZeneca Canada products,
recommending particular products to meet health care professional needs,
providing health care professionals with clinical evaluation packages, and
establishing and sponsoring educational or other programs. To carry out these
legitimate business purposes, AstraZeneca Canada may from time to time disclose
the personal information of health care professionals to regulatory agencies
(e.g., Health Canada), companies affiliated with AstraZeneca Canada, and other
third parties to perform services on behalf of AstraZeneca Canada for the
purposes explained in this section.
- 2.3 AstraZeneca Canada may from time to time collect, use and disclose personal
information about individuals that use or may use AstraZeneca Canada products
for legitimate business purposes that include receiving and/or responding to
requests, complaints or adverse event reports about AstraZeneca Canada products
or services, administering health condition awareness/management or similar
programs sponsored by AstraZeneca Canada, satisfying regulatory requirements,
notifying individuals about product-related matters where prudent to do so, and
marketing AstraZeneca products and services. To carry out these legitimate
business purposes, AstraZeneca Canada may from time to time disclose the
personal information of these individuals to regulatory agencies (e.g., Health
Canada), companies affiliated with AstraZeneca Canada, and other third parties
to perform services on behalf of AstraZeneca Canada for the purposes explained
in this section.
- 2.4 AstraZeneca Canada may from time to time collect, use and disclose personal
information about individuals that participate in clinical studies sponsored by
AstraZeneca Canada for legitimate research and business purposes that include
research and development, satisfying regulatory requirements, notifying
individuals about research-related matters where prudent to do so, and receiving
and/or responding to requests, complaints or adverse event reports about
AstraZeneca Canada products. To carry out these legitimate research and business
purposes, AstraZeneca Canada may from time to time disclose the personal
information of these individuals to regulatory agencies (e.g., Health Canada),
companies affiliated with AstraZeneca Canada, and other third parties to perform
services on behalf of AstraZeneca Canada for the purposes explained in this
section.
- 2.5 AstraZeneca Canada may from time to time collect, use and disclose personal
information about employees and potential employees for legitimate business
purposes that include evaluating employment applications, hiring, evaluating and
managing performance and administering employment-related services such as
payroll, benefits, making travel arrangements, satisfying regulatory
requirements (including compliance with Health Canada Regulations on Good
Manufacturing Practices (GMP)) and corporate compliance to policies. To carry
out these legitimate business purposes, AstraZeneca Canada may from time to time
disclose employees’ personal information to benefits providers, regulatory
agencies (e.g., Canada Revenue Agency), companies affiliated with AstraZeneca
Canada, and other third parties to perform services on behalf of AstraZeneca
Canada for the purposes explained in this section.
- 2.6 AstraZeneca Canada will make reasonable efforts to identify the purposes for
which personal information is collected to the individual from whom the personal
information is collected at or before the time of collection. Depending upon the
way in which the information is collected, AstraZeneca Canada will identify
these purposes verbally or in writing. For example, subjects participating in
studies sponsored by AstraZeneca Canada are presented with written consents
specifying that their doctor will collect their personal information such as
date of birth and gender for purposes relating to administering and conducting
the study, research and statistical analysis.
- 2.7 When AstraZeneca Canada uses or discloses personal information that has been
collected for a purpose not previously identified, it will identify and obtain
consent to the new purpose prior to use or disclosure, except as permitted or
required by law.
- 2.8 People collecting personal information will explain to individuals the
purposes for which the information is being collected, including any purposes
that may not be immediately obvious to the individual. For example, AstraZeneca
Canada will make clear to individuals who provide testimonials regarding
AstraZeneca Canada products for distribution to the public that their personal
information may be shared with other companies affiliated with AstraZeneca
Canada.
Principle 3 - Consent
- 3.1 Generally, AstraZeneca Canada will seek consent for the collection, use or
disclosure of personal information at the time of collection. In certain
circumstances, consent with respect to use or disclosure may be sought after the
information has been collected but before use (for example, when AstraZeneca
Canada wants to use information for a purpose not previously identified).
- 3.2 The form of the consent sought by AstraZeneca Canada, including whether this
consent is express or implied, may vary depending upon the circumstances and the
type of information. In determining the form of consent to use, AstraZeneca
Canada will take into account the sensitivity of the information and the
reasonable expectations of the individual. For example:
- An employee filing an application for AstraZeneca Canada’s dental, health, life
insurance and long-term disability coverage plan would reasonably expect that
the relevant information (employee identification number, name, date of birth)
would be collected, used and communicated to third parties in accordance with
the dental, health, life insurance, long-term disability coverage, and for as
long as the coverage was in effect.
- When submitting a resume or application for employment with AstraZeneca Canada,
an individual may implicitly be consenting to the collection of the information
he or she discloses on the form. AstraZeneca Canada may also bring to the
applicant’s attention the use that will be made of the information on the form.
Consent in such cases is indicated by the applicant completing and signing the
relevant forms.
- 3.3 An individual may withdraw consent at any time, subject to legal or other
contractual obligations and restrictions. AstraZeneca Canada must also be
provided with reasonable notice that an individual wishes to withdraw consent.
The period of reasonable notice will vary depending on the nature of the
information and the uses to which it is being put by AstraZeneca Canada.
AstraZeneca Canada will inform the individual of the implications of withdrawing
consent.
- 3.4 AstraZeneca Canada will not, as a condition of the supply of a product or
service, require an individual to consent to the collection, use, or disclosure
of information beyond that required to fulfil the explicitly specified and
legitimate purposes. For example, employee contact information is required for
employment purposes, AstraZeneca Canada’s customers’ contact information is
required for billing purposes and consent to the collection, use and disclosure
of certain information will be required from participants in clinical studies in
order to facilitate the research purposes for which the study is being
conducted.
- 3.5 There may be some circumstances where AstraZeneca Canada will collect, use
or disclose personal information without consent where permitted or required by
law. For example, when information is being collected for the detection and
prevention of fraud or for law enforcement, seeking the consent of the
individual might defeat the purpose of collecting the information. Seeking
consent may be impossible or inappropriate when the individual is a minor,
seriously ill or mentally incapacitated, in which case consent must be obtained
from parents, guardians or legal representatives of such individuals.
Principle 4 - Limiting Collection
- 4.1 AstraZeneca Canada will limit the amount and the type of information it
collects to that which is necessary to fulfill the purposes identified.
- 4.2 When possible, AstraZeneca will collect personal information from the
individual directly. However, with your consent or where permitted or required
by law, AstraZeneca Canada may also collect personal information from outside
sources such as companies that sell health care professionals’ personal
information, credit bureaux, professional references, marketing agencies and
public relations agencies.
Principle 5 - Limiting Use, Disclosure and Retention
- 5.1 AstraZeneca Canada limits the use and disclosure of personal information to
what is necessary for the identified purposes or as required or permitted by
law.
- 5.2 AstraZeneca Canada will retain information, including personal information
that has been used to make a decision about an individual long enough to allow
the individual access to the information after the decision has been made.
- 5.3 AstraZeneca Canada will destroy, erase or make anonymous personal
information that is no longer required to fulfill the identified purposes,
legislative requirements or legitimate business purposes.
Principle 6 - Accuracy
- 6.1 AstraZeneca Canada will take reasonable steps to ensure the accuracy and
completeness of the personal information it uses or discloses. Please make
a written request to the AstraZeneca Canada Privacy Compliance Officer if you
wish to request correction of any of your personal information.
Principle 7 - Safeguards
- 7.1 AstraZeneca Canada has security safeguards to protect personal information
against loss or theft, as well as unauthorized access, disclosure, copying, use
or modification, regardless of the format in which the information is held.
- 7.2 The nature of these safeguards vary depending on the sensitivity of the
information that has been collected; the amount, distribution and format of the
information; and the method of storage. More sensitive information is
safeguarded by a higher level of protection.
- 7.3 The methods of protection include
- physical measures (e.g., locked filing cabinets and restricted access to desks);
- organizational measures (e.g., security clearances and limiting access on a
“need to know” basis); and
- technological measures (e.g., the use of passwords and encryption).
- 7.4 AstraZeneca Canada has made its employees aware of the importance of
maintaining the confidentiality of personal information.
Principle 8 - Openness
- 8.1 This Privacy Policy outlines AstraZeneca Canada’s personal information
practices. If you visit one of AstraZeneca Canada’s web sites, you will
also see AstraZeneca Canada’s Web Site Privacy Statement, which outlines our
personal information management practices as they specifically relate to those
web sites.
- 8.2 Individuals are able to acquire further information about AstraZeneca
Canada’s policies and practices without unreasonable effort by contacting
AstraZeneca Canada’s Privacy Compliance Officer. The information that
AstraZeneca Canada will make available upon request includes:
- the name or title and the address of the Privacy Compliance Officer;
- the means of gaining access to personal information held by AstraZeneca Canada;
- a description of the type of personal information held by AstraZeneca Canada,
including a general account of its use;
- copies of any brochures or other information that explain AstraZeneca Canada’s
privacy policy; and
- a description of what personal information is made available to related
organizations (e.g., subsidiaries) or other third parties.
Principle 9 - Individual Access
- 9.1 AstraZeneca Canada may establish a file of personal information for
individuals, for the purposes described above, which will be accessible at 1004
Middlegate Road, Mississauga, Ontario, Canada L4Y 1M4. If an individual
wishes to request access to, or correction of, his/her personal information in
our custody or control, he/she must write to the above address, attention:
Privacy Compliance Officer. We will provide an individual with access to
his/her personal information in accordance with applicable law, except where
permitted or required by law not to disclose personal information to the
individual.
Principle 10 - Challenging Compliance
- 10.1 AstraZeneca Canada has put simple and easily accessible procedures in place
to receive and respond to complaints or inquiries about its policies and
practices relating to the handling of personal information.
- 10.2 AstraZeneca Canada will inform individuals who make inquiries or lodge
complaints about its complaint procedures.
- 10.3 AstraZeneca Canada will investigate all complaints. If a complaint is found
to be justified, AstraZeneca Canada will take appropriate measures, including,
if necessary, amending its policies and practices.
- 10.4 If an individual is not satisfied with the response from the Privacy
Compliance Officer, he or she may have recourse to the Office of the Privacy
Commissioner at:
-
Federal Privacy Commissioner 112 Kent Street Ottawa, Ontario K1A 1H3Phone:
(613) 995-8210 Toll-Free:
(800) 282-1376 Fax:
(613) 947-6850 Internet:
www.privcom.gc.ca |
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