Katz Group Canada Ltd. (Katz Group Canada) and its banner pharmacies, including Pharma Plus, Rexall™, Rexall™ Pharma Plus, Herbies and Rexall Direct, respect the privacy rights of our customers and employees and are committed to protecting the personal information that we collect from you. We have adopted this Privacy Statement to guide how we collect, use and disclose the information you provide to us.

The practices that we have adopted reflect requirements set out in both provincial and federal legislation. This includes the Personal Information Protection and Electronic Documents Act (PIPEDA), which applies to the collection, use, and disclosure of personal information in the course of commercial activities, including pharmacy services and retail stores.

Katz Group Canada...
 

• is accountable for the personal information that you give to us. (more) 
• will inform you as to why we must collect any of your personal information before the information is collected. (more) 
• will obtain your consent before or when we collect, use, or disclose personal information about you. You may withdraw your consent at any time. (more) 
• limits the amount and type of personal information we collect. We will collect personal information only for the purposes that we have identified or as otherwise permitted by law. (more) 
• will use or disclose your personal information only for the reasons that you provided it to us. We will keep your personal information only as long as is necessary to accomplish these purposes. (more) 
• will endeavour to maintain the accuracy of the personal information in our possession or control. (more) 
• protects your personal information with safeguards appropriate to the sensitivity of the information. (more) 
• will be open about the procedures used to manage your personal information. (more) 
• will, at your request, advise you of what personal information we have in our possession or control about, what it is being used for, and to whom and why it has been disclosed. (more) 

You may challenge Katz Group Canada's compliance with this Privacy Policy
Privacy and our employees
Our Web site privacy policy
Contact information

Principle 1

Katz Group Canada is accountable for the personal information that you give to us.

Katz Group Canada is accountable for all personal information in our possession or control. This includes any personal information that we must share with third parties in order to provide services to you. We have established policies and procedures aimed at maintaining the privacy of our customers and our employees. We have appointed a Privacy Officer to oversee privacy issues for Katz Group Canada. We have also educated our employees about our Privacy Policy and their role in protecting your privacy. If you have questions about our privacy practices, you are free to contact our Privacy Officer.


Principle 2

Katz Group Canada will inform you as to why we must collect any of your personal information before the information is collected.

How we use and disclose your personal information
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 designate's involvement in your care or payment for your care.

Health-related educational communications: We may contact you to provide refill reminders such as our e-Fill e-mail reminders or information about treatment alternatives, events in our stores, or other health-related benefits and services that may be of interest to you. We may also contact you about store openings or closings in your area.

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.

Members of the Katz Group Management Team may only have access to personal health information to perform specific management functions or as outlined in the Privacy Policy (e.g. reviewing prescription incident reports, complaints, audits, systems support etc). They shall not use or disclose any personal health information for their own use or in any manner not expressly provided in the Katz Group Canada policy.

In order to keep your information up-to-date, the pharmacist and pharmacy staff at any Katz Group Canada pharmacy 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, Katz Group Canada and its affiliated banners 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.


Principle 3

Katz Group Canada will obtain your consent before or when we collect, use or disclose personal information about you. You may withdraw your consent at any time.

Why do pharmacists need your consent
Effective January 1, 2004, under Canadian privacy legislation, pharmacists and pharmacy staff must get your express consent to collect, use and disclose your personal health information. This may include information we currently have on record and have always collected, used and disclosed to provide you with pharmacy services. While previously you could give us your permission in an informal way, such as providing us with your insurance card to register you for a prescription, the new legislation requires us to formally ask for your consent to collect, use and disclose your personal information as well as to document the consent you provide to us.

How will we ask for your consent?
When you first visit one of our banner pharmacies, the pharmacist or one of their pharmacy staff will provide you with a description of why your personal information is required and to whom they must disclose it. You will be asked to confirm your consent and this will be documented in our dispensary files. On occasion, you will be asked to update this consent to ensure that our records remain accurate.

There may be times when you want us to share prescription-related information with a family member or authorized representative or, alternatively, to specifically restrict with whom we may share the information. We will comply with your request upon notification by you. For example, if you would like to have special provisions made for the pick-up or delivery of your prescription, we will follow your instructions upon your request. We will maintain a record of your instructions. Simply contact your pharmacy and they will be pleased to update this information.

What happens if you choose not to give us your consent? What if you withdraw your consent at a later date?
If you choose not to provide us with your consent to collect and use the health information, we will still be obliged to comply with all the provincial laws that require us to keep a record of the medicine that we dispense to you. However, we may not have sufficient health information in your record to provide you with the full range of pharmacy services. If you do not give us your consent to communicate with your insurance company, you may be required to pay for your medicine and send the information required for reimbursement directly to your pharmacy benefits plan.

Exceptions to requiring consent

Katz Group Canada will collect, use or disclose personal information without your consent only in limited circumstances as permitted by law.

There have always been, and may continue to be, instances where we may collect, use or disclose your personal information without your consent. These instances are permitted under privacy legislation in order to ensure that the consent requirement is not a hindrance to your health and safety.

Personal information may be collected without consent where the collection is clearly in the interest of the individual and consent cannot be obtained in a timely way.

Personal information may be used without consent where it is used for the purpose of acting in respect to an emergency that threatens the life, health or security of an individual.

Personal information may be disclosed without consent where the disclosure is made to a person who needs the information because of an emergency that threatens the life, health or security of an individual.


Principle 4
Katz Group Canada limits the amount and type of personal information we collect. We will collect personal information only for the purposes that we have identified or as otherwise permitted by law.

We will limit the collection of your personal information to that which is required to accomplish the purposes for which it is being collected. For example, if the purpose of the collection is to enable a pharmacy to submit a drug benefit claim to an adjudicator or benefit manager for payment, the pharmacy will only collect from you the information required to submit the claim.

Principle 5
Katz Group Canada will use or disclose your personal information only for the reasons that you provided it to us. We will keep your personal information only as long as is necessary to accomplish these purposes.

In order to provide you with quality health care and in compliance with existing federal and provincial legislation, we keep a record of the medicines dispensed to you at our pharmacy. We also include in our records any relevant health information that we require to ensure that you are not given, or advised to take, a medicine that is not appropriate for you. We will retain your personal information for the period of time that is required by law (we have to keep prescription files for a designated number of years even though the individual may no longer be a customer).
We will not share your personal information with any third parties, except as expressly consented to by you or as may be required by law.

Other purposes
Where we have collected your personal information in relation to a loyalty program, contest, promotion or some other non-pharmacy-related purpose, we will use your information only for those purposes and for any other related purpose that we have disclosed to you and to which you have consented. We will keep your information only as long as is necessary to provide you with those services. We will not share your personal information with any third parties, except as expressly consented to by you or as may be required by law.
If we intend to use your personal information for a new purpose, not previously identified to you, we will obtain your prior consent to the new purpose. When your personal information is no longer required, it will be destroyed or depersonalized.

Principle 6

Katz Group Canada will endeavour to maintain the accuracy of the personal information in our possession or control.

In order to provide you with a high degree of professional service, we must ensure that the personal information that we collect about you is accurate, complete and current. From time to time, you will be asked by your pharmacist to update your personal information. For example, information about allergies may need to be reviewed on a regular basis.

You are encouraged to advise your pharmacist of any changes to your personal information that may be relevant to the services they are providing to you. This may include, for example, a change in your medical situation, such as a new diagnosis, or a change in your employment or residence. At any time, you can ask your pharmacist to allow you to review the personal information they have about you and, where necessary, you will be able to update that information to ensure that it is accurate.

Principle 7

Katz Group Canada 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, and clearly defined internal policies 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


Principle 8

Katz Group Canada will be open about the procedures used to manage your personal information.


Principle 9

At your request, Katz Group Canada will advise you of what personal information we have in our possession or control about you, what it is being used for, and to whom and why it has been disclosed.
Each person has the right to review and obtain a copy of his or her personal information on record at our pharmacies, with limited exceptions. This information usually will include prescription and billing records. To find out what information your pharmacist has about you, contact them in person or in writing. In most instances, they will respond to your request within 30 days.

If you have any concerns about the access provided to you, or if you wish to amend the information, you are encouraged to discuss it with your pharmacist, who will be pleased to assist you.

Other information

To access personal information that you believe we may have in our possession in relation to a loyalty program, contest, promotion or some other non-pharmacy-related purpose, contact the Privacy Officer. In most instances, you will receive a response to your request within 30 days.


Principle 10

You may challenge Katz Group Canada's compliance with this Privacy Policy.
Katz Group Canada will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.

To challenge compliance with this Policy in relation to pharmacy-related activities, please forward your concerns in writing to your pharmacist at any Katz Group Canada pharmacy, with a copy to the Katz Group Canada Privacy Officer. Your pharmacist is responsible for investigating your complaint and responding to you in a timely fashion and will do so, in most instances, within 30 days.

Where you have concerns relating to personal information collected in relation to a loyalty program, contest, promotion or some other non-pharmacy-related purpose, contact the Privacy Officer. The Privacy Officer is responsible for investigating your complaint and responding to you in a timely fashion and will do so, in most instances, within 30 days.

Where you believe that your concerns have not been satisfactorily addressed, contact the Privacy Officer directly (please see Contact Information, page 6). The Privacy Officer will ensure that a complete investigation of your complaint has been undertaken and will report their findings to you, in most instances, within 30 days.


Privacy and our employees

We have taken steps to help ensure that our employees govern themselves in accordance with this policy. In addition, our employees' own privacy rights are important to us, and we have taken steps to protect the information they provide to us in the employment environment, including:
 

• Limiting the information collected on employment and benefits applications to the information that is necessary to administer their employment and benefits.
• Safeguarding their employment information.
• Providing them with personal access to their employment files, with limited exceptions.
• Providing them with an opportunity to challenge our privacy practices.

Our Web site Privacy Policy

Our Privacy Policy also applies to the Katz Group Canada Web site - www.rexall.ca.


Contact information

Privacy Officer Tel. 905-502-5965
E-mail privacyofficer@rexall.ca
Mailing Address:
Katz Group Canada Ltd.
5965 Coopers Avenue
Mississauga, ON L4Z 1R9

For more information on your privacy rights, you may also contact the
Federal Privacy Commissioner at:

112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3

Or your provincial office of the Information and Privacy Commissioner for more information.

© 2009, Katz Group Canada Ltd.