Privacy Policy

Privacy Policy

Privacy Commitment

Bayshore Specialty Rx Ltd. (“Bayshore”) is and always has been committed to ensuring the confidentiality and protection of personal information in its possession.

This Privacy Policy explains how we collect, use, store, transfer, disclose and safeguard the personal information that you provide to us on omnipod.diabetesexpress.ca (referred to as "the Site"), which is controlled by Bayshore and which links to this Privacy Policy.

Please read this Privacy Policy before using the Site or submitting personal information to us. "Personal information" means information that identifies you or could reasonably be used to identify you and which is submitted to and/or collected through the Site and maintained by Bayshore in an accessible form, in the course of our commercial activities. Examples of personal information include your name, your postal address and your telephone number. Personal information also includes financial information such as your credit card number. Further, personal information includes personal health information such as your physical or mental health.

Bayshore’s Privacy Management Program is governed by the information handling practices of the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial and professional standards.

We Are Accountable

At Bayshore, all employees are accountable and committed to ensuring that your personal information is held in the strictest confidence. The Quality and Risk Program Manager is Bayshore’s Privacy Officer, and is responsible for the overall compliance to the requirements of all privacy legislation and Bayshore privacy practices. However, all Bayshore employees are accountable for maintaining the privacy and confidentiality of all information they have access to in their course of their work with us. To help ensure this, all Bayshore staff are trained in our Privacy Management Program and acceptable privacy practices.

As required, Bayshore will amend this document and its Privacy Management Program when changes to privacy legislation or best practices are known.

What We Collect and Why

Bayshore will collect, store, process and use information about you that we feel is necessary for the purposes of providing your care and providing the services offered through the Site. We do not indiscriminately collect information, and constantly review

our practices to ensure this remains true. Personal information is collected when you submit the data yourself, as, for example, in an inquiry form on this Site.

Our staff will endeavor to ensure that all personal information is accurate, complete and up•to• date, so that we can provide you with the appropriate care and services. We need your assistance in doing this, however; please let us know if any information relevant to your health care needs to be changed.

Your Permission

The submission of personal information (including e-mail addresses, names and addresses) on this Site is done on an explicitly voluntary basis. In submitting such information you hereby consent to your personal information being collected, stored, processed, used and transferred for legitimate business purposes that include the purpose of making contact with you, responding to your requests for information, fulfilling product orders, or for other purposes indicated by you, as well as for the protection of our own legitimate business interests.

Further, Bayshore may collect information about your visits to the Site without you actively submitting such information. Unidentifiable information may be collected using various technologies, such as cookies, Internet tags, and web beacons. Your Internet browser automatically transmits to the Bayshore Site some of this unidentifiable information, such as the URL of the web site you just visited and the browser version your computer is operating. Passive information collection technologies can make your use of this Site easier by allowing Bayshore to provide better service, customize sites based on consumer preferences, compile statistics, analyze trends, and otherwise administer and improve Bayshore websites. Certain features of this Site may not work without use of passive information collection technologies. Information collected by these technologies cannot be used to identify you without additional identifiable information.

Bayshore will seek your consent to disclose personal information outside of the multidisciplinary team or “circle of care” when appropriate access requests are received. Bayshore documents personal information disclosures that are made to third parties which would not require your information for routine, day•to• day purposes.

Please contact Bayshore at any time if you wish to withdraw or change the conditions of your consent.

How We Use Your Personal Information

Your personal information is only used for the purpose of providing your health care services, making contact with you, responding to your requests for information, fulfilling product or services orders, or for other purposes indicated by you, as well as for the protection of our own legitimate business interests. Your information may also be reviewed during auditing and quality improvement activities. Where appropriate, these activities are done without reference to specific individuals. This is an important aspect of our Quality Management System and allows us to continually monitor our performance and improve your services. Client names are NEVER shared with any individual or organization for the purposes of commercial activity, such as selling, trading and/or renting your personal information.

During the course of your service and use of the Site, Bayshore will maintain your personal information as accurately as is reasonably necessary for the purposes set out in the Privacy Policy. We need your assistance in this, however. Please notify us of any relevant changes in your information as soon as possible.

Who We Share Your Personal Information With

When you start service with Bayshore, and you sign the Client Consent, we discuss with you who we will likely share your information with – who are those individuals that we consider the members of your “multidisciplinary care team” or “circle of care.” All employees of Bayshore do not have access to your personal information, even though they are employees of Bayshore and you are a client of Bayshore. Information is only shared with individuals involved in your care. At the start of care, or anytime during your service, you may inform us of anyone whom you do not want receiving your information (in part or in whole).

In rare cases, we may be required by law or other lawful authority to release personal information, such as when we receive a court order or subpoena. In such cases, Bayshore will verify the lawful authority prior to release the information, and will endeavour to release only what is necessary for the stated purpose of the request.

How Long We Keep Your Personal Information

Bayshore keeps personal information only as long as necessary to satisfy the purposes for which it was collected, however, some personal information is kept for a number of years to comply with legal requirements.

Bayshore will continue to have access to your information even after your services or use of this Site have been discontinued. We retain all discontinued client records for a minimum of 10 years, or longer if required by provincial regulation. We retain children’s records until the child reaches the age of majority plus 10 years. These records, whether at our offices or off-site, are stored in a manner that ensures ongoing security. Bayshore uses off-site storage facilities that cite privacy practices which are in compliance with relevant privacy legislation and only after a Confidentiality Agreement has been signed with the facility. Records are kept of the location of files retained, so that we may retrieve them as required. At the end of the 10 year period, all information that we have, regardless of format, is destroyed in a confidential manner.

In certain circumstances, records created by Bayshore are retained by other health care organizations (“health information custodian”) such as a government care program, medical facility or clinical trial group. In these cases, these organizations will be applying their own retention schedule to these records and access requests will be redirected to them.

Children’s Privacy

We understand the need to protect children's privacy online. We do not knowingly collect or use any personal information from children, without the consent of a parent or legal guardian. We do not knowingly allow children to register with us, communicate with us, or to use any of our online services.

Safeguards

Bayshore considers your personal information, including any health information, extremely confidential, and has put many safeguards in place to ensure its security.

Information is found in many different formats at Bayshore, due to the nature of our work. Your information is stored electronically, in paper files and in the knowledge of our staff.

All employees are orientated and trained on privacy practices at the time of hire and sign a Confidentiality and Conflict of Interest Agreement and Conditions of Employment Agreement at that time. Training occurs routinely throughout our staff’s employment with Bayshore and information is available about our privacy practices to everyone through our staff website.

The knowledge and information our staff have is considered private and confidential, and is only used for the purpose of doing their work with Bayshore and is not shared with anyone. At any time, if a caregiver receives a request to share information or is asked about any client of Bayshore, he/she will not provide any information and will forward the request to their supervisor.

Electronic information is protected by computer firewalls, user names and passwords according to assigned authorization levels.

Hard copy files are protected by being stored in appropriate locations in the branch office, where access is permitted only to staff with the necessary authority. After hours, these files are kept in a locked, secured area.

Faxes are sent via pre-programmed fax numbers to reduce the possibility of sending information to the wrong place and a cover letter is sent with a Confidentiality Statement that tells a receiver what to do if they receive something in error.

In addition, email signatures include a confidentiality statement explaining what to do if an email is received in error. In the case of either a misdirected fax or email, the direction is to contact Bayshore’s Privacy Officer.

Despite these safeguards, no transmission of personal information, including transmission over the Internet can be guaranteed to be completely secure. Consequently, Bayshore, its affiliates, related companies, third party service providers, other third parties who receive access to your information pursuant to this Privacy Policy, and their respective officers, directors, employees and agents do not represent, warrant, or guarantee that personal information will be protected against misuse, loss, or alterations and do not accept any liability for personal information submitted to them.

Other Third Party Sites

From time to time, Bayshore may provide links to other third party websites that it does not control. Bayshore is not responsible for the privacy practices of organizations with links on this Site and this Privacy Policy does not apply to those third party websites. Bayshore urges you to review the privacy policies posted on these third party websites at the time you first visit such sites. Bayshore undertakes no obligation to review or ensure enforcement or compliance with the privacy policy of any website to which it link.

Your Right To See Your Personal Information

If you would like to see or access your personal information at any time, you may do so by putting your request in writing and forwarding it to Bayshore’s Privacy Officer. As your file may contain words that are particular to the medical and nursing community, we will invite you to meet with one of our nurse managers when you review your file, so that they may be available to answer any of your questions. Similarly, you may request a copy of your file, in part or in whole, if required, by submitting a request in writing to your local Bayshore branch. We will assist any individual who needs assistance in preparing a written request for access to their personal information.

If you have a sensory disability, please let us know so that we can endeavour to provide you access to information in an alternate format. In addition, translators will be made available, as required.

Please note that we may need to collect additional personal information to validate the identity and authority of the individual making the access request. This is to ensure that only individuals authorized to access your information can do so. This additional information will only be used for the purpose of validating the information request.

A reasonable fee may be charged for retrieval and copying of records, based on the nature of the request. Please contact us if you have a concern regarding the reasonableness of the fee.

Bayshore endeavors to respond to all requests for access to personal information within 30 days. Some requests for access to information may be subject to limitations or refusal. Reasons for refusal may include: the proprietary nature of the material; the information may infringe on the privacy of another individual; the law prohibits its release; and/or if we exercise our discretion to withhold or limit the information because we believe harm may result from the disclosure.

When requests for access to information are refused, you will be notified of the reason(s) for refusal, including recourses available to you.

Your Right To Correct Your Personal Information

You may contact Bayshore to request a correction of an error or omission to your personal information or to update your personal information. This request must be in writing. As appropriate, Bayshore will make the correction as soon as is reasonably possible. If a correction cannot be made, Bayshore will notify you in writing as to why the correction can not be made. Both the request for correction and our response will be retained in the record.

If You Need More Information, or Have a Question or Concern About Bayshore and its Privacy Practices

Anyone may contact Bayshore with any complaint, question, concern or compliment relating to Bayshore’s information handling practices. All inquires will be investigated thoroughly, and if found to be justified, appropriate corrective measures will be taken, up to and including making revisions to current policy and practices. Any such corrective actions will be included in our response to the individual making the inquiry.

All Bayshore employees are responsible for ensuring the privacy and confidentiality of your personal information. If you have any questions or concerns about your personal information, or if you would like more information about Bayshore’s policies and practices for managing and handling personal information, you are invited to contact your local Bayshore office. If your privacy concerns cannot be addressed to your satisfaction, or you wish further information, your inquiry will be forwarded to Bayshore’s Privacy Officer.

You may contact Bayshore’s Privacy Officer directly by email at privacyofficer@bayshore.ca, by phoning 1•800•886•9490, Ext. 32298, or in writing to 2101 Hadwen Rd., Mississauga, Ontario L5K 2L3.

You are also entitled to contact your provincial Privacy Commissioner’s Office if you feel this is necessary. While we would appreciate the opportunity to do what we can to address your concerns, we would also assist you in contacting your Privacy Commissioner’s Office if you believe this is warranted.

Bayshore's community-based health care services are governed by ISO 9001 quality standards. Bayshore is committed to ensuring the confidentiality and protection of personal information.

®™ Trademarks of Bayshore Specialty Rx Ltd.