DATE OF STATEMENT: January 2015
Eli Lilly Canada Inc. (“Lilly” or “we”) is committed to managing its collection, use and disclosure of personal information in compliance with the Personal Information Protection and Electronic Documents Act (Canada) and other applicable federal and provincial laws governing privacy and the protection of personal information. Generally speaking, “personal information” is information about an identifiable individual. It includes, for example, an individual’s name, address, birth date, social insurance number, and other types of information as defined under applicable laws. This Privacy Statement (“Statement”) applies to various types of personal information collected, used and disclosed by Lilly in the course of our business, including information about health care professionals, patients, participants in clinical studies, customers, and other individuals with whom we interact (“you” or “your”). This Statement describes how we will protect your personal information and your rights in relation to the information held by us, as well as the choices you can make about your personal information. This Statement applies irrespective of how that information may be collected, whether face to face, over the phone, via a website, in any other interaction we might have with you, or from publically available sources.
Collection and Use of Personal Information
Lilly’s business focuses on the delivery of innovative pharmaceutical products and services to health care professionals and to the community generally. In carrying out its business, Lilly collects and uses a variety of personal information.
The personal information that Lilly collects varies depending on our interaction with you; however, we will take reasonable care to ensure we only collect personal information that is necessary to appropriately process, record, and manage your interaction with us, or for the purposes described below. For example, if you are a health care professional, we may collect and record your personal information, including your professional details (qualifications, education and training, publications with which you have been involved, specialties, areas of interest), your business details and details of the interaction we have with you.
When possible, Lilly will collect personal information directly from you. However, in some circumstances, we may collect personal information from a third party source where that third party is authorized to disclose your information. We may also collect information from publically available sources. When personal information that has been collected is to be used for a purpose not previously identified, Lilly will inform you of that new purpose prior to that use of the information.
The purposes for which we may collect and use personal information include, but are not limited to, the following:
- To manage your role in Lilly-sponsored activities including clinical trials, patient support programs, observational research, questionnaires, education programs, professional development, disease management programs, research grants, expert panels, contracting and audits.
- To respond, report or discuss information in response to product queries or suggestions for improving our products.
- To facilitate meetings with sales representatives or other staff.
- To detect and prevent fraud, and to help safeguard the financial interests of Lilly and its customers.
- To meet legal and regulatory requirements (for example, by notifying the relevant health authorities of important new safety information or details of special access to medicines).
- To monitor the safety and efficacy of our products.
- To respond to a medical information query or to understand your interests, concerns and needs when you contact us to use customer or product information services.
- To establish and maintain communications with you.
- To determine your eligibility for Lilly’s products or services.
- If you apply for a job, to consider you for employment.
- For everyday business purposes, such as website management, research, and product development.
Lilly may also use your personal information to create aggregated information that does not allow you to be personally identified or contacted. Rather than showing individual activity, aggregated information shows users’ collective behaviour.
Collection of Information through a Lilly Website
In addition to the types and uses of personal information listed above, we may collect personal information from you via a Lilly website, for our business use.
If we collect personal information from you when you visit a Lilly website, you will be informed of how the information will be used, the purpose of its use, and whom it may be disclosed to, via the privacy statement available on the website (the “Website Privacy Statement”). You should review the Website Privacy Statement before providing any of your personal information on that website. If you do not agree to these terms, please do not submit information. A copy of the Website Privacy Statement may be viewed by clicking here.
Lilly websites use Internet Protocol (IP) addresses. If you have a broadband connection, depending on your individual circumstance, it is possible that the IP address that we collect, or a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP address does not change (it is "static") and could be associated with your personal computer.
Personal information of users is also collected on a Lilly website when you respond to specific questions and when you communicate directly with Lilly via e-mail, feedback forms, and chat rooms. We use aggregated information about our website users, including IP address information, to analyze and report on website use and help improve our websites. Lilly websites may also contain links to other websites. The Website Privacy Statement on our websites does not apply to those websites. Lilly is not responsible for the privacy practices of other website operators. When looking at other websites we advise you to review their privacy policies before providing any personal information.
Disclosure of your Personal Information
To carry out the research and business purposes identified above, Lilly may disclose personal information to regulatory agencies (for example, Health Canada), companies affiliated with Lilly, and other third parties which perform services on behalf of Lilly. Lilly may disclose your personal information as follows:
- To those of its affiliates and related companies that agree to treat it in accordance with this Statement.
- To third party service providers for purposes related to supporting our business (e.g., fulfillment services, technical support, delivery services) and providing you with information (if you have agreed to receiving such information as described above), in which case we will require such third parties to agree to treat your information in accordance with this Statement.
- In the context of certain business transactions, such as financing, insuring, or selling all or part of our business or assets, in which case we will require that such third parties treat your personal information in accordance with this Statement.
- If a law, regulation, search warrant, subpoena, court order or order of an administrative tribunal or other body authorized to compel the disclosure of such information legally requires Lilly to do so.
In addition, Lilly may disclose aggregated information which does not allow you to be personally identified to third parties.
Sharing Personal Information Outside of Canada
Some of the third parties, service providers, affiliates or related companies (including Lilly’s parent company, Eli Lilly and Company) that may collect, use, store or process your information may be located outside of Canada, including in the United States. As a result, your personal information may be transferred, stored, and/or processed outside Canada in connection with the purposes described in this Statement. Contractual or other measures Lilly may use to protect your personal information are subject to the legal requirements of the foreign jurisdictions where your personal information may be transferred, stored, or processed (for example, lawful requirements to disclose personal information to government authorities in those countries).
Emails from Lilly
Lilly is committed to complying with applicable provisions of federal and provincial laws relating to anti-spam, such as An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act; the Competition Act; the Personal Information Protection and Electronic Documents Act; and the Telecommunications Act (Canada). Your choice is important to us. If you wish to stop receiving any e-mails or other commercial electronic messages from Lilly which are being sent to you based on a previous request or consent you submitted to us, please notify our Chief Privacy Officer at the address below. Please note that you may continue to receive communications while we are updating our lists.
We collect, use and disclose your personal information with your consent or as permitted or required by law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question.
If you choose to provide personal information to Lilly or its service providers and agents, we either collect your express consent or assume that you consent to the collection, use and disclosure of your personal information as outlined in this Statement.
If you provide personal information about another person to us, we assume that that individual consents to the collection, use and disclosure of their personal information as outlined in this Statement, or that you have the authority to consent on their behalf.
There may be circumstances where legal, medical, or security reasons make it impossible or impractical for Lilly to seek consent, and in such circumstances personal information might be collected, used, or disclosed without the knowledge or consent of the individual.
If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered. Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information or you may withdraw your consent to our further collection, use and disclosure of your personal information by sending a written request to Lilly’s Chief Privacy Officer at the address below. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide you with certain information, products, or services. Also, under some circumstances, you will not be permitted to withdraw consent to certain necessary uses and disclosures of personal information that you have originally consented to.
Security and Disposal of your Personal Information
Your privacy is important to you and to us. Lilly employs reasonable physical, organization and technological security measures to protect your personal information. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, use, copying, modification, disclosure or disposal. Personal information is protected by security safeguards appropriate to the sensitivity of the information.
Lilly may use third parties to store or dispose of personal information it retains. Any third parties used for these purposes will protect your personal information to at least the same standard as described in this Statement.
Lilly 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. Any personal information that is no longer needed is securely destroyed after specific retention periods have been met.
Any area of a Lilly website that collects your personal information uses industry standard secure socket layer (SSL) encryption; however, to take advantage of this, your browser must support encryption protection (found in all Internet Explorer releases since version 3.0 and other popular browsers). If a Lilly website is hosted by Lilly (rather than a third party), it will be hosted in a website hosting centre which may be located outside Canada. Such centres will place your information in databases that are protected by security firewalls and intrusion detection software, and have security precautions that provide for industry standard protection of your information.
No transmission of personal information, including transmission over the internet, can be guaranteed to be completely secure. Consequently, Lilly, its affiliates, related companies, third party service providers 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 or for your or third parties' use or misuse of personal information. Moreover, where you use passwords, ID numbers, or other special access features, it is your responsibility to safeguard them.
Access, Correction, Inquiries and Complaints
Lilly strives to ensure that any personal information it maintains is sufficiently accurate, complete and up to date, but we do not routinely update personal information unless it is necessary to fulfill the purposes for which the information was collected.
If you wish to request access to, or correction of, your personal information that we have in our custody or control, please make your request in writing to our Chief Privacy Officer at the address below. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, if it is protected by solicitor-client privilege, or if it is otherwise not properly the subject of an access request.
If you have any questions, requests or complaints about our personal information practices, please contact our Chief Privacy Officer at the address below.
If you have any questions, comments or concerns about this Statement, please contact our Chief Privacy Officer at:
Eli Lilly Canada Inc.
3650 Danforth Avenue
Toronto, Ontario M1N 2E8
Or call 1-888-545-5972.
Lilly reserves the right to change this Statement at any time. We will always handle your personal information in accordance with the Privacy Statement in effect at the time it was collected. You can access the current version of this Statement online at www.lilly.ca or by contacting our Chief Privacy Officer.