Lyceum CME Inc. (“Lyceum CME”) is committed to controlling the collection,
use and disclosure of personal information.
Lyceum CME collects, uses and discloses various types of personal information
in carrying on business, including information about health care professionals (including
physicians, pharmacists and other health care workers), patients, participants in clinical
studies, customers and employees.
Lyceum CME collects, uses and discloses personal information in accordance with
the following ten fair information principles.
Principle 1 - Accountability
The contact information for Lyceum CME’s Privacy Compliance Officer is:
1.2 Accountability for compliance by Lyceum CME with these policies and procedures rests with the Privacy Compliance Officer, even though other individuals within the company may be responsible for the day to day 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, including representatives from all areas of the business.
1.3 Lyceum CME is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. Lyceum CME transfers personal information to third parties for reasons such as data processing, data warehousing, administrative services, and conducting programs on our behalf, where the third parties do not make any independent use of the personal information. Lyceum CME uses contractual or other means to require third parties to commit to protecting personal information to a level comparable to that provided by Lyceum CME. Some of these third parties may be located outside of Canada and, as such, they are subject to foreign laws including laws that may require disclosure of personal information to foreign government authorities.
- procedures to protect personal information;
- procedures to receive and respond to complaints and inquiries;
- training and information for staff about Lyceum CME’s policies and practices; and
- information and tools to explain Lyceum CME’s policies and procedures.
Principle 2 - Identifying Purposes
2.1 Lyceum CME collects, uses and discloses personal information for a range of purposes.
2.2 Lyceum CME may from time to time collect, use and disclose personal information about health care professionals for legitimate business purposes that include satisfying regulatory requirements, conducting clinical studies in which health care professionals have agreed to participate, establishing and managing a customer relationship profile, marketing Lyceum CME products and services, responding to requests about Lyceum CME products, recommending particular products to meet health care professional needs, providing health care professionals with clinical evaluation packages, and establishing and sponsoring educational or other programs. To carry out these legitimate business purposes, Lyceum CME may from time to time disclose the personal information of health care professionals to regulatory agencies (e.g., Health Canada), companies affiliated with Lyceum CME, and other third parties to perform services on behalf of Lyceum CME for the purposes explained in this section.
2.3 Lyceum CME may from time to time collect, use and disclose personal information about individuals that use or may use Lyceum CME products for legitimate business purposes that include receiving and/or responding to requests, complaints or adverse event reports about Lyceum CME products or services, administering health condition awareness/management or similar programs sponsored by Lyceum CME, satisfying regulatory requirements, notifying individuals about product-related matters where prudent to do so, and marketing Lyceum CME products and services. To carry out these legitimate business purposes, Lyceum CME may from time to time disclose the personal information of these individuals to regulatory agencies (e.g., Health Canada), companies affiliated with Lyceum CME, and other third parties to perform services on behalf of Lyceum CME for the purposes explained in this section.
2.4 Lyceum CME may from time to time collect, use and disclose personal information about individuals that participate in clinical studies sponsored by Lyceum CME for legitimate research and business purposes that include research and development, satisfying regulatory requirements, notifying individuals about research-related matters where prudent to do so, and receiving and/or responding to requests, complaints or adverse event reports about Lyceum CME products. To carry out these legitimate research and business purposes, Lyceum CME may from time to time disclose the personal information of these individuals to regulatory agencies (e.g., Health Canada), companies affiliated with Lyceum CME, and other third parties to perform services on behalf of Lyceum CME for the purposes explained in this section.
2.5 Lyceum CME may from time to time collect, use and disclose personal information about employees and potential employees for legitimate business purposes that include evaluating employment applications, hiring, evaluating and managing performance and administering employment-related services such as payroll, benefits, making travel arrangements, satisfying regulatory requirements (including compliance with Health Canada Regulations on Good Manufacturing Practices (GMP)) and corporate compliance to policies. To carry out these legitimate business purposes, Lyceum CME may from time to time disclose employees’ personal information to benefits providers, regulatory agencies (e.g., Canada Revenue Agency), companies affiliated with Lyceum CME, and other third parties to perform services on behalf of Lyceum CME for the purposes explained in this section.
2.6 Lyceum CME 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. Depending upon the way in which the information is collected, Lyceum CME will identify these purposes verbally or in writing. For example, subjects participating in studies sponsored by Lyceum CME are presented with written consents specifying that their doctor will collect their personal information such as date of birth and gender for purposes relating to administering and conducting the study, research and statistical analysis.
2.7 When Lyceum CME uses or discloses personal information that has been collected for a purpose not previously identified, it will identify and obtain consent to the new purpose prior to use or disclosure, except as permitted or required by law.
2.8 People collecting personal information will explain to individuals the purposes for which the information is being collected, including any purposes that may not be immediately obvious to the individual. For example, Lyceum CME will make clear to individuals who provide testimonials regarding Lyceum CME products for distribution to the public that their personal information may be shared with other companies affiliated with Lyceum CME.
Principle 3 - Consent
3.1 Generally, Lyceum CME will seek consent for the collection, use or disclosure of personal information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Lyceum CME wants to use information for a purpose not previously identified).
3.2 The form of the consent sought by Lyceum CME, including whether this consent is express or implied, may vary depending upon the circumstances and the type of information. In determining the form of consent to use, Lyceum CME will take into account the sensitivity of the information and the reasonable expectations of the individual. For example:
An employee filing an application for Lyceum CME’s dental, health, life insurance and long-term disability coverage plan would reasonably expect that the relevant information (employee identification number, name, date of birth) would be collected, used and communicated to third parties in accordance with the dental, health, life insurance, long-term disability coverage, and for as long as the coverage was in effect.
When submitting a resume or application for employment with Lyceum CME, an individual may implicitly be consenting to the collection of the information he or she discloses on the form. Lyceum CME may also bring to the applicant’s attention the use that will be made of the information on the form. Consent in such cases is indicated by the applicant completing and signing the relevant forms.
3.3 An individual may withdraw consent at any time, subject to legal or other contractual obligations and restrictions. Lyceum CME must also be provided with reasonable notice that an individual wishes to withdraw consent. The period of reasonable notice will vary depending on the nature of the information and the uses to which it is being put by Lyceum CME. Lyceum CME will inform the individual of the implications of withdrawing consent.
3.4 Lyceum CME 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 fulfil the explicitly specified and legitimate purposes. For example, employee contact information is required for employment purposes, Lyceum CME’s customers’ contact information is required for billing purposes and consent to the collection, use and disclosure of certain information will be required from participants in clinical studies in order to facilitate the research purposes for which the study is being conducted.
3.5 There may be some circumstances where Lyceum CME will collect, use or disclose personal information without consent where permitted or required by law. For example, when information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill or mentally incapacitated, in which case consent must be obtained from parents, guardians or legal representatives of such individuals.
Principle 4 - Limiting Collection
4.1 Lyceum CME will limit the amount and the type of information it collects to that which is necessary to fulfill the purposes identified.
4.2 When possible, Lyceum CME will collect personal information from the individual directly. However, with your consent or where permitted or required by law, Lyceum CME may also collect personal information from outside sources such as companies that sell health care professionals’ personal information, credit bureaux, professional references, marketing agencies and public relations agencies.
Principle 5 - Limiting Use, Disclosure and Retention
5.1 Lyceum CME 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 Lyceum CME 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 Lyceum CME will destroy, erase or make anonymous personal information that is no longer required to fulfill the identified purposes, legislative requirements or legitimate business purposes.
Principle 6 - Accuracy
6.1 Lyceum CME will take reasonable steps to ensure the accuracy and completeness of the personal information it uses or discloses. Please make a written request to the Lyceum CME Privacy Compliance Officer if you wish to request correction of any of your personal information.
Principle 7 - Safeguards
7.1 Lyceum CME 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 these safeguards vary depending on the sensitivity of the information that has been collected; the amount, distribution and format of the information; and the method of storage. More sensitive information is safeguarded by a higher level of protection.
7.3 The methods of protection include
a. physical measures (e.g., locked filing cabinets and restricted access to desks);
b. organizational measures (e.g., security clearances and limiting access on a “need to know” basis); and
c. technological measures (e.g., the use of passwords and encryption).
7.4 Lyceum CME has made its employees aware of the importance of maintaining the confidentiality of personal information.
Principle 8 - Openness
8.2 Individuals are able to acquire further information about Lyceum CME’s policies and practices without unreasonable effort by contacting Lyceum CME’s Privacy Compliance Officer. The information that Lyceum CME will make available upon request includes:
a. the name or title and the address of the Privacy Compliance Officer;
b. the means of gaining access to personal information held by Lyceum CME;
c. a description of the type of personal information held by Lyceum CME, including a general account of its use;
e. a description of what personal information is made available to related organizations (e.g., subsidiaries) or other third parties.
Principle 9 - Individual Access
9.1 Lyceum CME may establish a file of personal information for individuals, for the purposes described above, which will be accessible at 1004 Middlegate Road, Mississauga, Ontario, Canada L4Y 1M4. If an individual wishes to request access to, or correction of, his/her personal information in our custody or control, he/she must write to the above address, attention: Privacy Compliance Officer. We will provide an individual with access to his/her personal information in accordance with applicable law, except where permitted or required by law not to disclose personal information to the individual.
Principle 10 - Challenging Compliance
10.1 Lyceum CME has put simple and easily accessible procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information.
10.2 Lyceum CME will inform individuals who make inquiries or lodge complaints about its complaint procedures.
10.3 Lyceum CME will investigate all complaints. If a complaint is found to be justified, Lyceum CME will take appropriate measures, including, if necessary, amending its policies and practices.
If an individual is not satisfied with the response from the Privacy Compliance Officer, he or she may have recourse to the Office of the Privacy Commissioner at:
Federal Privacy Commissioner
112 Kent Street
Phone: (613) 995-8210
Toll-Free: (800) 282-1376
Fax: (613) 947-6850