PTM Privacy Policy
Introduction
Professional Targeted Marketing (“PTM”) is dedicated to maintaining the accuracy, confidentiality, security and privacy of personal information. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We are also open and transparent as to how we handle personal information. As an organization that handles personal information on a daily basis, we are conscious of our continued responsibility to respect personal privacy, safeguard confidentiality, and implement appropriate security and personnel measures. Our company and employees comply with all federal and provincial laws respecting privacy and has adopted our Privacy Policy based on the principles set out in Schedule 1 of the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and are compliant with Canadian AntiSpam Legislation (CASL) with respect to personal email usage.
Who We Are
Our company provides a number of healthcare related services including, but not limited to, mailing, broadcast services, sampling, research, promotion and data collection. Like all data and marketing companies, we collect, use and disclose personal information in order to service our clients. Our clients include pharmaceutical companies, government agencies, healthcare products manufacturers, and medical journal publishers. We maintain and continually update a database of healthcare professionals and related organizations and use this database to provide marketing and data analytic services.
Personal information provided to us may be used for marketing research, to improve customer service, or to communicate about product updates. All data collected will be specified as to the reason for collection. PTM only collects data by fair and lawful means. All communications from PTM will include a method (such as a link or fax number) that can be used to unsubscribe to further communications about a particular campaign at any time. PTM does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
PTM’s Privacy Principles
PTM is committed to the protection of the personal information of individuals with whom it comes into contact. Accordingly, PTM adheres to the principles set out below (the "Privacy Principles"). The Privacy 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. PRINCIPLE - ACCOUNTABILITY
PTM is responsible for the personal information under its control and has designated an individual as its Privacy Officer who shall be accountable for the organization's compliance with the following principles.
| 1.1 | Accountability rests with the Privacy Officer of PTM, even though other individuals with the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals may be delegated to act on behalf of the designated individual. | |
| 1.2 | PTM shall make known, upon request, the identity, title and contact information of the person designated to oversee PTM's compliance with its policy. | |
| 1.3 | PTM is responsible for personal information in its possession or control. As such, PTM will use appropriate means to ensure that all existing and future contracts ensure a level of privacy protection equal to PTM's policies when information is being processed by third parties. | |
| 1.4 | PTM shall implement policies and practices to give effect to these principles, including; | |
| a) | The establishment of procedures to quickly receive and respond to complaints and inquiries; | |
| b) | Training and communicating to staff about PTM's policies and practices; and | |
| c) | Developing information to explain PTM's policies and practices. | |
2. PRINCIPLE - IDENTIFYING PURPOSES
PTM shall identify the purposes for which personal information is collected at or before the time the information is collected.
| 2.1 | Personal information may be collected, among other purposes, to: | |
| • | Maintain a record of queries, requests for information, complaints and adverse event reports relating to products that we or our clients deliver, and report these to relevant regulatory bodies or other concerned organizations; | |
| • | Administer disease awareness / management programs or other similar programs organized by PTM or clients of PTM; | |
| • | Notify clients of matters that PTM may be required by law to notify clients of (eg., product recalls); | |
| • | Develop, implement, market and manage PTM's services and products which we market on behalf of our clients; | |
| • | Send clients materials and contact clients regarding products, services or developments which may be of interest; | |
| • | Tailor marketing services to better suit client needs; | |
| • | Administer research organized by clients of PTM and which any individual may agree to participate in or be involved with; | |
| • | Identify, develop and administer continuing education programs, conferences, symposia, expert panels, seminars or other meetings or events organized by PTM or clients of PTM; | |
| • | Establish and maintain customer relationships, including: managing, planning and arranging meetings between clients and PTM sales representatives; and | |
| • | Monitor and review PTM's compliance with relevant codes of conduct in its dealings with clients or other individuals; | |
| 2.2 | If we plan to use Personal Information we have collected for a purpose not previously identified, we will identify and document this purpose before such use. | |
| 2.3 | PTM will make reasonable efforts to specify the identified purpose, orally or in writing, to the individual from whom the information is collected either at the time of collection or after collection but before use. | |
3. PRINCIPLE - CONSENT
The knowledge and consent of the individual are required for the collection, use and disclosure of personal information, except where inappropriate.
| 3.1 | The way in which we seek consent, including whether it is express or implied consent, may vary depending on the sensitivity of the information and the reasonable expectations of the individual. An individual may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. | |
| 3.2 | PTM will typically seek consent for the use or disclosure of personal information at the time of collection, but in certain circumstances consent may be sought after collection but before use. In some circumstances, we may not seek consent if, for example, the personal information is being collected for an obvious reason (such as providing personal information for a product request). | |
| 3.3 | PTM will only ask individuals to consent to the collection, use or disclosure of personal information as a condition of the supply or purchase of a product, if such use, collection or disclosure is required to fulfill an identified purpose. | |
| 3.4 | In certain circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge and consent of the individual. These circumstances include: Personal information which is subject to solicitor-client privilege or is publicly 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. PRINCIPLE - LIMITING COLLECTION
PTM will limit the amount and type of personal information collected to that which is necessary for the purposes identified by PTM. We will only collection personal information by fair and lawful means.
5. PRINCIPLE - LIMITING USE, DISCLOSURE AND RETENTION
PTM shall not use or disclose personal information for purposes other than those for which it was collected, except with consent of the individual or as required by law. Personal information shall be retained only as long as is necessary for the fulfilment of those purposes.
| 5.1 | PTM will not disclose personal information about you to any person except in the following circumstances, and then only that information which is necessary. | |
| • | Third parties we use in the ordinary course of our business, such as for conference organizing, marketing, data processing and associated printing and mailing; | |
| • | Companies related to PTM for the same kinds of purposes as listed above; and | |
| • | Such third parties as otherwise permitted or required by law. | |
| 5.2 | PTM shall retain personal information only as long as it remains necessary or relevant for the identified purposes, to contribute to our database, or as required by law. In some circumstances where personal information has been utilized to make a decision about an individual, PTM shall retain that personal information for a period of time that is reasonably sufficient to allow for access by the individual. | |
| 5.3 | Personal information that is no longer required to fulfill an identified purpose shall be erased, destroyed or made anonymous. | |
6. PRINCIPLE - ACCURACY OF PERSONAL INFORMATION
PTM will use its best effort to ensure that personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
| 6.1 | Personal information used by PTM shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an individual. | |
| 6.2 | PTM shall not routinely update personal information about individuals, but only as and when necessary to fulfill identified purposes. | |
7. PRINCIPLE - SAFEGUARDS
PTM will protect personal information by security safeguards appropriate to the sensitivity of the information.
| 7.1 | PTM shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. PTM shall protect personal information regardless of the format in which it was held. | |
| 7.2 | Nature of the safeguards taken: | |
| a) | Physical measures - building security, lock boxes, secure rooms, etc.; | |
| b) | Organizational measures - "need to know" basis; and | |
| c) | Technological measures - use of encryption and passwords | |
| 7.3 | PTM shall make its employees aware of the importance of maintaining the confidentiality of personal information by signing a Secrecy Document as a precondition of full time / part time / or contract employment | |
8. PRINCIPLE - OPENNESS
PTM will make readily available to individuals specific information about its policies and practices relating to the management of personal information.
| 8.1 | PTM shall make information regarding its policies and practices available in a form that is generally understandable, including: | |
| a) | How to gain access to personal information held by PTM; | |
| b) | The type of personal information held by PTM, including a general account of its use; | |
| c) | Personal information available to related organizations (affiliates); and | |
| d) | How to contact our Privacy Officer. | |
9. PRINCIPLE - INDIVIDUAL ACCESS
Upon written request, PTM will inform an individual of the existence, use and disclosure of his or her personal information, subject to internal, legal and practical limitations, and we will give the individual access to that information. An individual can challenge the accuracy and completeness of the information and have it amended as appropriate.
| 9.1 | PTM will respond to an individual's written request for information within a reasonable period of time. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information. This information shall be provided in an understandable, timely and low-cost manner from the perspective of the individual. | |
| 9.2 | Should an individual successfully demonstrate any inaccuracy or incompleteness in the records, PTM will make the appropriate amendments to the information. When a challenge is not resolved to the satisfaction of the individual, a statement of disagreement shall be attached to the individual's records. When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question. | |
| 9.3 | In certain situations, PTM may not be able to provide access to all the personal information it holds about an individual. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. The reasons for denying access shall be provided by PTM upon request. | |
10. PRINCIPLE - CHALLENGING COMPLIANCE
An individual can address a challenge concerning compliance with the above principles to the designated person accountable for PTM's compliance with the policy.
| 10.1 | PTM will investigate all complaints. If a complaint is found to be justified, PTM will take appropriate measures, including, if necessary, amending its policies and practices. | |
PTM Privacy Principles
We may amend this Policy at any time. We will take reasonable steps to inform interested parties of relevant changes. We will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.
How to Contact the Privacy Officer
Access request, inquiries or complaints should be addressed in writing to:
Privacy Officer
Professional Targeted Marketing
20 Torbay Road
Markham, Ontario
L3R 1G6
