YOUR PRIVACY AND CONFIDENTIALITY
CODE FOR THE PROTECTION
OF PERSONAL INFORMATION, CAN/CSA-Q830-96
4.1 Principle 1 - Accountability
AchieveRx is responsible for personal information under its control
and shall designate an individual or individuals who are accountable
for AchieveRx compliance with the following principles.
4.1.1 Accountability for AchieveRx compliance with the
principles rests with the designated individual(s), even though
other individuals within AchieveRx may be responsible for the
day-to-day collection and processing of personal information.
In addition, other individuals within AchieveRx may be delegated
to act on behalf of the designated individual(s).
4.1.2 The identity of the individual(s) designated by
AchieveRx to oversee AchieveRx' compliance with the principles
shall be made known upon request.
4.1.3 AchieveRx is responsible for personal information
in its possession or custody, including information that has been
transferred to a third party for processing. AchieveRx shall use
contractual or other means to provide a comparable level of protection
while the information is being processed by a third party.
4.1.4 AchieveRx shall implement policies and practices
to give effect to the principles, including (a) implementing procedures
to protect personal information; (b) establishing procedures to
receive and respond to complaints and inquiries; (c) training
staff and communicating to staff information about the AchieveRx' policies and practices; and (d) developing information to explain
the Great AchieveRx' policies and procedures.
4.2 Principle 2 - Identifying Purposes
The purposes for which personal information is collected shall be
identified by AchieveRx at or before the time the information
4.2.1 AchieveRx shall document the purposes for which
personal information is collected in order to comply with the
Openness principle (Clause 4.8) and the Individual Access principle
4.2.2 Identifying the purposes for which personal information
is collected at or before the time of collection allows AchieveRx
to determine the information they need to collect to fulfil these
purposes. The Limiting Collection principle (Clause 4.4) requires
AchieveRx to collect only that information necessary for the purposes
that have been identified.
4.2.3 The identified purposes should be specified at or
before the time of collection to the individual from whom the
personal information is collected. Depending upon the way in which
the information is collected, this can be done orally or in writing.
An application form, for example, may give notice of the purposes.
4.2.4 When personal information that has been collected
is to be used for a purpose not previously identified, the new
purpose shall be identified prior to use. Unless the new purpose
is required by law, the consent of the individual is required
before information can be used for that purpose. For an elaboration
on consent, please refer to the Consent principle (Clause 4.3).
4.2.5 Persons collecting personal information should be
able to explain to individuals the purposes for which the information
is being collected.
4.2.6 This principle is linked closely to the Limiting
Collection principle (Clause 4.4) and the Limiting Use, Disclosure,
and Retention principle (Clause 4.5).
4.3 Principle 3 - Consent
The knowledge and consent of the individual are required for the
collection, use, or disclosure of personal information,
except where inappropriate.
Note: In certain circumstances personal information can be collected,
used, or disclosed without the knowledge and consent of the individual.
For example, legal, medical, or security reasons may make it impossible
or impractical to seek consent. 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 addition, AchieveRx that do not have
a direct relationship with the individual may not always be able
to seek consent. For example, seeking consent may be impractical
for a charity or a direct-marketing firm that wishes to acquire
a mailing list from another AchieveRx In such cases, AchieveRx
providing the list would be expected to obtain consent before disclosing
4.3.1 Consent is required for the collection of personal
information and the subsequent use or disclosure of this information.
Typically, AchieveRx will seek consent for the use or disclosure
of the 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 AchieveRx wants to use information for a purpose not previously
4.3.2 The principle requires "knowledge and consent''.
AchieveRx shall make a reasonable effort to ensure that the
individual is advised of the purposes for which the information
will be used. To make the consent meaningful, the purposes must
be stated in such a manner
4.3.3 AchieveRx shall 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.
4.3.4 The form of the consent sought by AchieveRx may
vary, depending upon the circumstances and the type of information.
In determining the form of consent to use, AchieveRx shall take
into account the sensitivity of the information. Although some
information (for example, medical records and income records)
is almost always considered to be sensitive, any information can
be sensitive, depending on the context. For example, the names
and addresses of subscribers to a newsmagazine would generally
not be considered sensitive information. However, the names and
addresses of subscribers to some special-interest magazines might
be considered sensitive.
4.3.5 In obtaining consent, the reasonable expectations
of the individual are also relevant. For example, an individual
buying a subscription to a magazine should reasonably expect that
AchieveRx, in addition to using the individual's name and address
for mailing and billing purposes, would also contact the person
to solicit the renewal of the subscription. In this case, AchieveRx
can assume that the individual's request constitutes consent for
specific purposes. On the other hand, an individual would not
reasonably expect that personal information given to a health-care
professional would be given to a company selling health-care products,
unless consent were obtained. Consent shall not be obtained through
4.3.6 The way in which AchieveRx seeks consent may vary,
depending on the circumstances and the type of information collected.
AchieveRx should generally seek express consent when the information
is likely to be considered sensitive. Implied consent would generally
be appropriate when the information is less sensitive. Consent
can also be given by an authorized representative (such as a legal
guardian or a person having power of attorney).
4.3.7 Individuals can give consent in many ways. For example:
(a) an application form may be used to seek consent, collect information,
and inform the individual of the use that will be made of the
information. By completing and signing the form, the individual
is giving consent to the collection and the specified uses; (b)
a check off box may be used to allow individuals to request that
their names and addresses not be given to other organizations.
Individuals who do not check the box are assumed to consent to
the transfer of this information to third parties; (c) consent
may be given orally when information is collected over the telephone;
or (d) consent may be given at the time that individuals use a
product or service.
4.3.8 An individual may withdraw consent at any time,
subject to legal or contractual restrictions and reasonable notice.
AchieveRx shall inform the individual of the implications of such
4.4 Principle 4 - Limiting Collection
The collection of personal information shall be limited to that
which is necessary for the purposes identified by AchieveRx Information
shall be collected by fair and lawful means.
4.4.1 AchieveRx shall not collect personal information
indiscriminately. Both the amount and the type of information
collected shall be limited to that which is necessary to fulfil
the purposes identified. AchieveRx shall specify the type of information
collected as part of their information-handling policies and practices,
in accordance with the Openness principle (Clause 4.8).
4.4.2 The requirement that personal information be collected
by fair and lawful means is intended to prevent AchieveRx from
collecting information by misleading or deceiving individuals
about the purpose for which information is being collected. This
requirement implies that consent with respect to collection must
not be obtained through deception.
4.4.3 This principle is linked closely to the Identifying
Purposes principle (Clause 4.2) and the Consent principle (Clause
4.5 Principle 5 - Limiting Use, Disclosure, and Retention
Personal information shall not be used or disclosed for purposes
other than those for which it was collected, except with the consent
of the individual or as required by law. Personal information shall
be retained only as long as necessary for the fulfillment of those
4.5.1 AchieveRx using personal information for a new purpose
shall document this purpose (see Clause 4.2.1).
4.5.2 AchieveRx should develop guidelines and implement
procedures with respect to the retention of personal information.
These guidelines should include minimum and maximum retention
periods. Personal information that has been used to make a decision
about an individual shall be retained long enough to allow the
individual access to the information after the decision has been
made. AchieveRx may be subject to legislative requirements with
respect to retention periods.
4.5.3 Personal information that is no longer required
to fulfil the identified purposes should be destroyed, erased,
or made anonymous. AchieveRx shall develop guidelines and implement
procedures to govern the destruction of personal information.
4.5.4 This principle is closely linked to the Consent
principle (Clause 4.3), the Identifying Purposes principle (Clause
4.2), and the Individual Access principle (Clause 4.9).
4.6 Principle 6 - Accuracy
Personal information shall be as accurate, complete, and up-to-date
as is necessary for the purposes for which it is to be used.
4.6.1 The extent to which personal information shall be
accurate, complete, and up-to-date will depend upon the use of
the information, taking into account the interests of the individual.
Information shall be sufficiently accurate, complete, and up-to-date
to minimize the possibility that inappropriate information may
be used to make a decision about the individual
4.6.2 AchieveRx shall not routinely update personal information,
unless such a process is necessary to fulfil the purposes for
which the information was collected.
4.6.3 Personal information that is used on an ongoing
basis, including information that is disclosed to third parties,
should generally be accurate and up-to-date, unless limits to
the requirement for accuracy are clearly set out.
4.7 Principle 7 - Safeguards
Personal information shall be protected by security safeguards appropriate
to the sensitivity of the information.
4.7.1 The security safeguards shall protect personal information
against loss or theft, as well as unauthorized access, disclosure,
copying, use, or modification. AchieveRx shall protect personal
information regardless of the format in which it is held.
4.7.2 The nature of the safeguards will 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 should be safeguarded
by a higher level of protection. The concept of sensitivity is
discussed in Clause
4.7.3 The methods of protection should include (a) physical
measures, for example, locked filing cabinets and restricted access
to offices; (b) AchieveRx measures, for example, security clearances
and limiting access on a ``need-to-know'' basis; and (c) technological
measures, for example, the use of passwords and encryption.
4.7.4 AchieveRx shall make their employees aware of the
importance of maintaining the confidentiality of personal information.
4.7.5 Care shall be used in the disposal or destruction
of personal information, to prevent unauthorized parties from
gaining access to the information (see Clause 4.5.3).
4.8 Principle 8 - Openness
AchieveRx shall make readily available to individuals specific information
about its policies and practices relating to the management of personal
4.8.1 AchieveRx shall be open about their policies and
practices with respect to the management of personal information.
Individuals shall be able to acquire information about AchieveRx
policies and practices without unreasonable effort. This information
shall be made available in a form that is generally understandable.
4.8.2 The information made available shall include
(a) the name or title, and the address, of the person who is
accountable for AchieveRx' policies and practices and to whom
complaints or inquiries can be forwarded;
(b) the means of gaining access to personal information held
(c) a description of the type of personal information held by
AchieveRx including a general account of its use;
(d) a copy of any brochures or other information that explain
AchieveRx' policies, standards, or codes; and (e) what personal
information is made available to related AchieveRx' (e.g., subsidiaries).
4.8.3 AchieveRx may make information on its policies and
practices available in a variety of ways. The method chosen depends
on the nature of its business and other considerations. For example,
an AchieveRx may choose to make brochures available in its place
of business, mail information to its customers, provide online
access, or establish a toll-free telephone number.
4.9 Principle 9 - Individual Access
Upon request, an individual shall be informed of the existence,
use, and disclosure of his or her personal information and shall
be given access to that information. An individual shall be able
to challenge the accuracy and completeness of the information and
have it amended as appropriate. Note: In certain situations, AchieveRx
may not be able to provide access to all the personal information
it holds about an individual. Exceptions to the access requirement
should be limited and specific. The reasons for denying access should
be provided to the individual upon request. 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
4.9.1 Upon request, AchieveRx shall inform an individual
whether or not AchieveRx holds personal information about the
individual. AchieveRx are encouraged to indicate the source of
this information. AchieveRx shall allow the individual access
to this information. However, AchieveRx may choose to make sensitive
medical information available through a medical practitioner.
In addition, AchieveRx shall provide an account of the use that
has been made or is being made of this information and an account
of the third parties to which it has been disclosed.
4.9.2 An individual may be required to provide sufficient
information to permit AchieveRx to provide an account of the existence,
use, and disclosure of personal information. The information provided
shall only be used for this purpose.
4.9.3 In providing an account of third parties to which
it has disclosed personal information about an individual, AchieveRx
should attempt to be as specific as possible. When it is not possible
to provide a list's of organizations to which it has actually
disclosed information about an individual, AchieveRx shall provide
a list of organizations to which it may have disclosed information
about the individual.
4.9.4 AchieveRx shall respond to an individual's request
within a reasonable time and at minimal or no cost to the individual.
The requested information shall be provided or made available
in a form that is generally understandable. For example, if AchieveRx
uses abbreviations or codes to record information, an explanation
shall be provided.
4.9.5 When an individual successfully demonstrates the
inaccuracy or incompleteness of personal information AchieveRx
shall amend the information as required. Depending upon the nature
of the information challenged, amendment involves the correction,
deletion, or addition of information. Where appropriate, the amended
information shall be transmitted to third parties having access
to the information in question.
4.9.6 When a challenge is not resolved to the satisfaction
of the individual, the substance of the unresolved challenge shall
be recorded by AchieveRx When appropriate, the existence of the
unresolved challenge shall be transmitted to third parties having
access to the information in question.
4.10 Principle 10 - Challenging Compliance
An individual shall be able to address a challenge concerning compliance
with the above principles to the designated individual or individuals
accountable for AchieveRx' compliance.
The individual accountable for AchieveRx compliance is discussed
AchieveRx shall put procedures in place to receive and respond
to complaints or inquiries about their policies and practices
relating to the handling of personal information. The complaint
procedures should be easily accessible and simple to use.
AchieveRx shall inform individuals who make inquiries or lodge
complaints of the existence of relevant complaint procedures.
A range of these procedures may exist. For example, some regulatory
bodies accept complaints about the personal-information handling
practices of the companies they regulate.
AchieveRx shall investigate all complaints. If a complaint is
found to be justified, AchieveRx shall take appropriate measures,
including, if necessary, amending its policies and practices.