Privacy notice - Pharmaceutical activities

GENERAL INFORMATION

This Pharmaceutical activities Privacy Notice ("Notice") complements and forms an integral part of the Privacy Policy of Metro ("Policy"). In the event of any conflict or inconsistency between this Notice and the Policy, and subject to compliance with legal requirements relating to the protection of Personal Health Information, the Policy shall prevail. Terms used in this Notice have the same meaning as in the Policy unless the context clearly indicates otherwise.

This Notice should be read in conjunction with any other privacy notices or statements made available to Customers of pharmaceutical establishments (the "Pharmaceutical Establishments") in the Metro Inc. pharmacy division network (the "Pharmacy Division") where pharmacy services are offered.

With this Notice, the Pharmacy Division provides Customers of the Pharmaceutical Establishments with additional details on how their Personal Health Information is collected, used, disclosed, retained and protected in connection with the services that are offered by the Pharmaceutical Establishments or, as the case may be, by the Pharmacy Division, including when Customers consult or use the Sites developed by the Pharmacy Division (including the MaSanté and Health Record applications, which are services offered to Customers by owner-pharmacist affiliated with the Pharmacy Division and in Metro Ontario Pharmacies Limited's pharmacies operating in Ontario).

This Notice applies to the network of Pharmaceutical Establishments affiliated with the Pharmacy Division located in Quebec, Ontario and New Brunswick.

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This Notice applies to Pharmaceutical Establishments affiliated with the Pharmacy Division located in Quebec, Ontario and New Brunswick:

McMahon Distributeur Pharmaceutique Inc. a subsidiary of Metro Richelieu Inc. and franchisor of a network of Pharmaceutical Establishments in Quebec operating under the Brunet, Brunet plus, Brunet clinique and Clini plus banners;
The Jean Coutu Group (PJC) Inc. a subsidiary of Metro Inc. and franchisor of a network of Pharmaceutical Establishments located in Quebec, Ontario and New Brunswick, operating under the Jean Coutu, PJC Santé and PJC Santé Beauté banners;
Metro Ontario Pharmacies Limited ("MOPL"), a subsidiary of Metro Ontario Inc. which operates pharmacies in Ontario under the names of Metro Pharmacy and Drug Basics Pharmacy in certain Metro and Food Basics stores.

Activities in Quebec:

In Quebec, Pharmaceutical Establishments are operated by owner-pharmacists affiliated with the Pharmacy Division.

Each affiliated owner-pharmacist collects Personal Health Information of Customers in the course of the practice of his or her profession when Customers request pharmaceutical services or health care. This information is collected, orally or in writing, directly from Customers, health professionals or by consulting various registers under the responsibility of the Health and Social Services network, such as the vaccination register. The Personal Health Information collected is only that required to provide pharmaceutical and health care services to Customers.

Each affiliated owner-pharmacist must establish a policy for the protection of Personal Information. They may, however, adopt the Policy of which this Notice forms a part. In that case, this Notice will apply, with the necessary adaptations, to Personal Health Information collected by owner-pharmacists affiliated with the Pharmacy Division.

The Pharmacy Division acts as operator of the MaSanté and Health Record applications and of the laboratory computer system of Pharmaceutical Establishments operated under The Jean Coutu, Brunet or any other related banners. However, the content of a Customer's profile and pharmaceutical record remain the responsibility of the affiliated owner-pharmacists who provide the pharmaceutical service to the Customer. Please note that these applications are also subject to their own terms of use.

To find out more about the conditions of use of the MaSanté and the Health Record please consult the Terms of use - MaSanté and the Terms and conditions of use of the Health Record.

APPLICABLE LAWS

This Notice is governed by the laws to the protection of Personal Information applicable in the provinces of Quebec, Ontario and New Brunswick:

Quebec: the Act respecting the protection of personal information in the private sector and its regulations, and the Act respecting health and social services information and amending various legislative provisions and its regulations.

Ontario: Personal Information Protection and Electronic Documents Act (PIPEDA) and regulations and Personal Health Information Protection Act (for personal health information).

New Brunswick: Personal Information Protection and Electronic Documents Act (PIPEDA) and Personal Health Information Privacy and Access Act.

COLLECTION OF PERSONAL INFORMATION

When a Customer uses the pharmaceutical or health care services offered by a Pharmaceutical Establishment affiliated with the Pharmacy Division, the following Personal Information about the Customer may be collected, used, disclosed, retained and protected, in accordance with applicable laws, by the Pharmaceutical Establishment and by various stakeholders, including the Pharmacy Division, through the Pharmaceutical Establishment's laboratory computer system:

the Customer's name, postal address, telephone number, date of birth and e-mail address if the Customer wishes to be contacted by e-mail;
the Customer's Personal Health Information contained in his or her health record and that relating to pharmaceutical services received or requested;
additional Personal Information required to meet the Customer's health needs, such as information on his drug insurance coverage, information on his health care professionals, etc.

All Personal Information collected in this way shall be included in the definition of Personal Health Information as defined in the Policy.

PURPOSES OF PERSONAL INFORMATION COLLECTION

Customers' Personal Health Information is collected for the following purposes:

provide the Customer with any pharmaceutical service or health care required by the Customer's health condition, as provided for by applicable laws and regulations and which may be offered in a pharmacy, such as filling a prescription, recommending products to the Customer in connection with the Customer's health needs, responding to the Customer's health needs, assisting physicians and other health professionals in managing the Customer's pharmacological treatment;
offer Quebec customers, through the MaSanté or Health Record application, personalized services such as consulting their pharmacological records and other health-related documentation, renewing their prescriptions, tracking their medication reminders, providing pharmaceutical or healthcare information and services, as well as to better understand customer needs and improve the product and service offering;
offer Ontario customers, through MOPL's online service, personalized services such as access to their prescription history, prescription refills, medication reminder follow-up, consultation of documentation, pharmaceutical or health care information and services;
maintain an up-to-date database of Customers' health information to assist other health professionals, as required;
give third-party payers in private and public drug insurance networks access to the information they need to reimburse products and services, and transmit this information to them;
recall or modify pharmacological treatment: the personnel of the Pharmaceutical Establishment may contact the Customer after filling a prescription to follow up on the pharmacological treatment;
develop new services related to pharmaceutical services and health care to better serve customers, using only de-identified information; and/or
contact Customers or their healthcare professionals in the event of a product recall.

The Personal Health Information collected may also be used for statistical or research purposes in accordance with the law. This information will then be de-identified (the Customer's name or other identifying information will be removed so that it will no longer be possible to identify or associate the information with the Customer) and aggregated (this information will be combined with a set of de-identified information from other Customers).

PERSONAL INFORMATION SHARING

In the course of the activities of the Pharmaceutical Establishments and those of the Pharmacy Division, Personal Information concerning a Customer may be disclosed and communicated to Third Parties, to certain service providers and partners and to employees and officers of the Pharmaceutical Establishments, where permitted by law.

Only Personal Information related to the Customer's health that is necessary to provide these services will be disclosed.

In addition, employees and officers of a Pharmaceutical Establishment may access, use or disclose a Customer's Personal Health Information when necessary to render pharmaceutical or health care services to the Customer.

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For example, Information may be disclosed, when necessary, with the following parties:

Service providers (IT, data hosting, pharmacy technologies, prescription preparation center);
Other health professionals;
Insurers (RAMQ and other public or private insurers);
Delivery service;
Any other party, if permitted by law.

All such parties are committed or bound by legal or contractual requirements to protect the confidentiality and security of Customer Personal Health Information and receive only the information necessary to perform these services. They may not store, analyze or use Customer Personal Health Information for any other purpose.

Access to Customer Personal Health Information is restricted to a limited group of employees and officers of the Pharmaceutical Establishments and Pharmacy Division who will use and disclose such information only for the purposes set forth in this Notice. It is strictly forbidden for any employee or officer of a Pharmaceutical Establishment or the Pharmacy Division to access, use or disclose Customer Personal Health Information without authorization or as otherwise permitted by law. All employees and officers of the Pharmaceutical Establishments and the Pharmacy Division are required to maintain the confidentiality of Customers' Personal Information at all times.

PERSONAL INFORMATION RETENTION

The Pharmacy Division and the Pharmaceutical Establishments retain Personal Information only as long as necessary for the achievement of the purposes for which it was collected or as required by law to ensure compliance with their legal and regulatory obligations.

For more information on this subject, please consult the "Personal Information Retention" section of the Policy.

QUESTIONS, COMMENTS AND COMPLAINTS - PHARMACY NETWORK

In certain circumstances, the law allows the Customer to restrict or refuse access to all or part of their Personal Information. In such cases, please notify the Privacy Officer of the Pharmaceutical Establishment concerned to obtain the necessary information and the implications of this decision.

For all comments, questions, concerns or complaints regarding your Personal Health Information, including requests for access to information collected through the MaSanté and Health Record application, please contact the privacy officer of the Pharmaceutical Establishment concerned.

If you have any questions about this Notice or the Policy, please or contact the Chief Privacy Officer of the Pharmacy Division at:

For Pharmaceutical Establishments operated under The Jean Coutu, Brunet or any other related banners in Quebec, Ontario and New Brunswick:

by mail:

Metro Inc. (Pharmacy Division)
Attention: Chief Privacy Officer
245 Jean Coutu Street
Varennes, Quebec
J3X 0E1

-or-

by e-mail: [email protected]

For Metro Pharmacy and Drug Basics pharmacies in Ontario: