Any patient, agent, or other third party (the “User”) in the course of its dealings with Sentrex Health Solutions (“SHS”) or otherwise, acknowledges that when visiting the SHS website at www.sentrex.com (the “Website”), or other online resources maintained by SHS, the User may provide personal information and/or personal health information to SHS.
What is Personal Information?
Personal Information is defined in Personal Information Protection and Electronic Documents Act (“PIPEDA”) as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card or information that is available in public records. Personal Information includes, but is not limited to, a User’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, interests, browsing preferences, web logs, Internet protocol addresses, network and server particulars, and/or other information relevant to the Website, promotional and marketing activities.
Personal health information is more specific, and is defined in the Personal Health Information Protection Act, 2004 (Ontario) (“PHIPA”) as identifying information about an individual which relates to that individual’s physical or mental health, the provision of health care to that individual, payments made or eligibility for health care or health care coverage of that individual, organ, tissue and fluid donations made by that individual, that individual’s provincial health card number and the identity(ies) of that individual’s substitute decision-maker(s).
Moreover, as a pharmacy, SHS is subject to the more stringent obligations imposed by PHIPA to the extent personal health information is collected, used and disclosed. Where these more stringent obligations apply, SHS will abide by these higher standards.
Any personal information collected or disclosed without the consent of a User will only be collected or disclosed in limited circumstances that are expressly permitted by law. For example, privacy legislation permits the collection or disclosure of personal information in certain circumstances where there is a concern for health and safety, or in an emergency.
A User may withdraw their consent to allow SHS to collect personal information and/or personal health information, however SHS will still be required to maintain certain records with regard to the distribution of medication to comply with provision laws.
If a User withdraws or limits its consent for SHS to collect or disclos
ure personal information and/or personal health information, SHS may be limited in its ability to provide pharmacy services – as this may limit SHS’s ability to access essential information, or limit its ability to contact a User’s insurer, physician, guardian, etc.
Importantly, this Website is intended for users who are over 18 years of age. Persons who are 18 years of age or less should not provide any personal information or personal health information directly to SHS, and SHS will require a parent or guardian to communicate directly with SHS for all services related to children or minors.
How is Personal Information Collected?
SHS collects Users’ personal information and personal health information in order to enable us to communicate with Users and provide them with our services. SHS collects a User’s Personal Information in one of three ways; unsolicited information provided by a User or their health care provider, information obtained from the public or third parties, and information collected from a User’s computer or other electronic devices.
- Unsolicited Information
SHS may collect unsolicited personal information and personal health information provided by a User voluntarily, such as data entered into forms or data fields on the Website, on patient prescription documents or via any other online resources.
- Information from Public or Third-Parties
SHS may collect personal information and personal health information from Users that register on the Website from public or third-party information sources to verify their professional credentials and identity. If names and contact information for a User’s physician and other health practitioners are provided via the Website or via any other online resources, SHS may contact them to collect further information.
- Information Collected from a User’s Computer or Other Electronic Devices
SHS only collects personal information and personal health information to the extent that it is necessary to accomplish the specific purposes for which it is being collected.
How is the Personal Information Used?
SHS collects, uses and discloses personal information to better understand a User’s needs and to provide a User with better services. In particular, personal information and personal health information is collected for the following reasons:
- internal record keeping, including keeping record of medications dispensed, to comply with existing federal and provincial legislation;
- to identify products, facilitate orders and otherwise provide SHS’s services;
- to ensure that Users are not given medication that is not appropriate;
- to improve services;
- in order to receive payment from Users and from their health plan providers;
- to co-ordinate care with other pharmacies and health care providers;
- to register a User for, and facilitate a User’s participation in, certain areas of the Website;
- to provide information and reminders to Users regarding their prescriptions;
- to tell Users about health-related benefits or services that may be of interest;
- to gather a User’s opinion and feedback;
- to audit online resources for authorized access and security;
- to submit reports to Health Canada;
- to contact a User’s pharmacist or prescribing physician to discuss prescription related information and concerns;
- communicate with individuals involved in your care or the payment of your care;
- to customize the Website according to a User’s interests; and
- such other uses as may be permitted or required by applicable law.
SHS may remove identifying data from your personal information and personal health information to be used to assess various factors, including trends in prescriptions, compliance
, and health, in order to improve upon our services. Personal information and personal health information from which identifying data has been removed may be shared with third parties for the purposes set out above.
In certain limited circumstances, SHS may be required to release or provide access to personal information or personal health information in response to a subpoena, search warrant, court order, law, or regulation. In such cases, SHS will take all appropriate measures to ensure that Users’ personal information and personal health information is protected to the greatest extent possible while SHS cooperates fully with court and law enforcement authorities in this regard.
Pharmacy Specific Services
SHS allows Users to request the filling of prescriptions and refills directly to patients or medical clinics. In order to complete this process, SHS will collect, use and transmit personal information and personal health information across computer systems and networks. By submitting the prescription information and other personal information and personal health information, our representatives, pharmacists and pharmacy technicians will have access to the User’s personal information.
In order to properly provide Users with pharmacy services, SHS may need to contact:
(a) health insurance providers (if applicable) to assess coverages and benefits;
(b) doctors or other medical professionals to discuss a User’s medical background and prescription requests; and/or
(c) such other persons as may be required in order to complete fulfill a prescription request.
A User’s personal information may be disclosed to the above-mentioned persons to the extent required to properly and safely provide pharmacy services.
To Whom Does SHS Provide Personal Information and Personal Health Information?
SHS may communicate with and disclose a User’s personal information or personal health information to persons who Users expressly designate to be involved in their health care or health care decisions, such as a physician, guardian or attorney.
SHS will not transfer a User’s personal information or personal health information outside of Canada.
SHS may disclose a User’s personal information or personal health information to a buyer or transferee in connection with the sale, assignment
Requests for Non-Disclosure
A User may withdraw their consent to SHS’s collection, use and disclosure of
P personal information and personal health information at any time, subject to legal and/or contractual restrictions and upon reasonable notice, by contacting SHS’s Privacy Officer. Please note certain personal information and personal health information will be collected automatically when a User visits the Website. A User’s continued use of the Website will be deemed consent to obtain any personal information and personal health information that derives from the User’s use of the Website.
How Does a User Limit Disclosure of a User’s Personal Information?
A User may choose not to provide personal information to SHS by electing not to enter any personal information into a form or data field, and by not using any personalized services provided by the Website or by any other online resources. However, some of the Website may only be available to Users that provide personal information or request the use of personalized services.
If a User previously agreed to permit the use of personal information for marketing or promotional purposes, a User may revoke consent by following the opt-out instructions in each communication, or by writing to SHS’s Privacy Officer.
How Does SHS Protect a User’s Personal Information?
SHS employs physical, administrative, and technological security safeguards appropriate to the sensitivity of the information. With respect to personal health information collected, SHS acts as custodian thereof and takes all precautions required by PHIPA to prevent the unauthorized disclosure thereof.
How May a User Access and Correct Personal Information and Personal Health Information?
Users may access, update, and correct personal information in the possession of SHS, subject to certain exceptions prescribed by law.
Upon written request, SHS will provide a User with any personal information and personal health information in its possession to the extent required by law.
If a User would like to access any of its personal information and personal health information, or believes that any of the personal information and personal health information collected by SHS relating to a User is incorrect or incomplete, a User may send an electronic message to SHS’s Privacy Officer, as provided below.
Retention of Information
To comply with existing federal and provincial legislation, and to ensure that we are able to refer to a User’s personal information and personal health information when necessary, SHS keeps records of all prescription medications dispensed. Personal information and personal health information is retained by SHS for minimum time periods required by law. When personal information and personal health information is no longer required to be maintained, SHS will delete it, or remove personal identifying data from such information.
- Former Users
- Terms and Conditions of Use of Website
Any applicable terms and conditions of use governing a User’s use of the Website contain important provisions, including provisions disclaiming, limiting
- Third Party Links and Web Sites
orliability for, or control over any third-party websites or their collection, use and disclosure of a User’s personal information and/or personal health information.
For More Information
Attn: Privacy Officer
Sentrex Health Solutions
3-250 Shields Court
Markham, ON L3R 9W7
For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Or your provincial office of the Information and Privacy Commissioner for more information.