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Genzyme Canada is committed to the protection of the personal information of individuals with whom it comes into contact. Accordingly, Genzyme Canada adheres to the Privacy Principles described below. These principles are based on the principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada). "Personal Information", as used in this Code, means information about an identifiable individual, but does not include the name, title or business address or telephone of an employee of an organization.
1.0 Principle 1 – Accountability
1.1 Accountability for compliance with these policies and procedures rests with the Privacy Compliance Officer of Genzyme Canada. However, other individuals within the company may be responsible for the ongoing collection and processing of personal information. In addition, the Privacy Compliance Officer may, from time to time, designate one or more other individuals within the company to act on his or her behalf.
1.2 The contact information for Genzyme Canada’s Privacy Compliance Officer is:
Privacy Compliance Officer
Genzyme Canada is responsible for personal information in its possession or control, including information that has been transferred to a third party for processing. This personal information may be shared with a third party for reasons such as data processing, administrative services and conducting programs on behalf of Genzyme Canada, where the third parties do not make any independent use of the personal information. Any existing and future contracts with third parties require the third parties to commit to protecting personal information to a level comparable to that provided by Genzyme Canada.
1.3.1 The implementation of procedures to protect personal information;
1.3.2 The implementation of procedures to quickly receive and respond to complaints and inquiries;
1.3.3 Training and communicating to staff about Genzyme Canada’s policies and practices; and
1.3.4 Developing information to explain Genzyme Canada’s policies and procedures.
2.0 Principle 2 – Identifying Purposes
2.1 Genzyme Canada collects, uses and discloses personal information at different times for a variety of legitimate business purposes such as:
2.1.1 Receiving and/or responding to requests, complaints and adverse event reports relating to Genzyme products and reporting these to relevant regulatory bodies, and other companies as required or prudent.
2.1.2 Administering disease awareness/management programs or other similar programs organized by Genzyme Canada;
2.1.3 Notifying individuals of matters that Genzyme Canada may be required by law to notify them of (e.g., product recalls);
2.1.4 Administering clinical trials or other research organized by Genzyme Canada;
2.1.5 In the case of the Healthcare Professional, personal information may be collected for establishing and managing customer relationship profiles, marketing Genzyme Canada products and services, recommending particular products to meet health care professional needs, and developing, planning and sponsoring educational or other programs, conferences, symposia, etc.
2.1.6 In the case of employees and potential employees, personal information will be collected regarding evaluation of employment applications, hiring, evaluating and managing performance and administering employment-related services such as payroll and benefits. This personal information may be disclosed to benefit providers and other third parties to perform services on behalf of Genzyme Canada, as well as regulatory agencies (e.g., Canada Revenue Agency), as required.
2.1.7 Monitoring and reviewing Genzyme Canada’s compliance with relevant codes of conduct in its dealing with customers.
2.2 Genzyme 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. If any personal information collected is to be used for a purpose not previously identified, Genzyme Canada will identify and document the purpose before such use.
3.0 Principle 3 – Consent
3.1 The form of the consent sought by Genzyme Canada, including whether this consent is express or implied, will vary depending upon the sensitivity of the information and the reasonable expectations of the individual. An individual may withdraw consent at any time, subject to legal and contractural restrictions and reasonable notice.
3.2 Genzyme Canada will generally seek consent for the collection, use or disclosure of personal information at the time of collection. In certain circumstances, consent may be sought after collection, but before use.
3.3 Genzyme 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 fulfill identified purposes.
3.4 There may be some circumstances where Genzyme Canada will collect, use or disclose personal information without consent where permitted or required by law. These circumstances include: personal information which is subject to solicitor-client privilege or is publicly as available as defined by regulation; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to investigate a breach of agreement of a contravention of the law; to act in respect to an emergency that threatens the life, health or security of an individual; for debt collection; or to comply with a subpoena, warrant or court order.
4.0 Principle 4 – Limiting Collection
4.1 Genzyme Canada will limit the amount and type of personal information collected to that which is necessary to fulfill the purposes identified.
5.0 Principle 5 – Limiting Use, Disclosure and Retention
5.1 Genzyme 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 Genzyme 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 Genzyme Canada will erase, destroy or make anonymous personal information that is no longer required to fulfill identified purposes, legislative requirements or legitimate business purposes.
6.0 Principle 6 – Accuracy of Personal Information
6.1 Genzyme Canada will take reasonable steps to ensure the accuracy and completeness of the personal information it uses or discloses.
7.0 Principle 7 – Safeguards
7.1 Genzyme 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 the safeguards varies depending on the sensitivity of the information that has been collected. More sensitive information is safeguarded by a higher level of protection.
7.3 The methods of protection include:
(a) Physical measures – building security, locked filing cabinets, etc.
(b) Organizational measures – limited access on a “need to know” basis
(c) Technological measures – use of passwords and encryption
8.0 Principle 8 – Openness
8.1 Genzyme Canada shall make information regarding its policies and practices available in a form that is generally understandable, including:
(a) How to contact the Privacy Compliance Officer;
(b) How to gain access to personal information held by Genzyme Canada;
(c) A description of the type of personal information held by Genzyme Canada;
(d)A description of what personal information is made available to related organizations (e.g., subsidiaries) or other third parties.
9.0 Principle 9 – Individual Access
9.1 Upon written request, Genzyme Canada will give an individual access to their personal information, within a reasonable period of time, except where required by law not to disclose personal information to the individual, information that contains references to other individuals, or for commercial proprietary reasons.
9.2 An individual may challenge the accuracy and completeness of the information and Genzyme Canada will make the appropriate amendments.
10.0 Principle 10 – Challenging Compliance
10.1 An individual can address a challenge concerning compliance with the above principles to the designated Privacy Compliance Officer who is accountable for Genzyme Canada’s compliance with the policies and related procedures.
10.2 Genzyme Canada has procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information.
10.3 Genzyme Canada will investigate all complaints. If a complaint is found to be justified, Genzyme Canada will take appropriate measure which may include amending its policies and practices.