Health First Network
CONSUMER PRIVACY POLICY
Overview
At Health First Network respecting privacy is an important part of our commitment to our customers and the general public.
Whenever you interact with Health First Network you can be confident that any personal information that you may share with us, whether in person or by telephone or Internet, will stay with us. Your personal identifying information will never be sold to or shared with anyone.
Health First Network’s Privacy Policy is a statement of principles and guidelines describing the level of protection of personal information provided by Health first Network to customers and the general public. The objective of the Health First Network’s Privacy Policy is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).
Health First Network will continue to review its Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.
Health First Network is a member of The Canadian Health Food Association, which sets standards to which members must adhere, and which also protect your privacy.
If you have any concerns about how your privacy is protected at Health First Network please contact our Privacy Officer by e-mail at privacyofficer@healthfirst.ca , or by mail at Privacy Officer, Health First Network, 591 Brant Street, Suite A, Burlington, ON, Canada L7R 2G6.
Health First Network’s Corporate Privacy Policy
Scope and Application
Health First Network’s Privacy Policy is built around ten key principles. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in the HFN Privacy Policy has been drafted to reflect personal information issues specific to HFN.
The scope and application of the HFN Privacy Policy are as follows:
- The HFN Privacy Policy applies to personal information collected, used, or disclosed by HFN in the course of commercial activities.
- The HFN Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.
- The HFN Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by HFN:
(a) non-personally identifiable information;
(b) the name, title, business address and/or telephone number of an employee of an organization;
(c) other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
- The application of The HFN Privacy Policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted thereunder, and any other applicable legislation or regulation.
The Ten Principles of Privacy
Principle 1 - Accountability
Health First Network (HFN) is responsible for any personal information under its control and shall designate one or more persons who are accountable for HFN’s compliance with the following principles.
Responsibility for compliance with the provisions of the HFN Privacy Policy rests with the HFN Privacy Officer who can be reached by e-mail at privacyofficer@healthfirst.ca or by mail at Privacy Officer, Health First Network, 591 Brant Street, Suite A, Burlington, ON, Canada, L7R 2G6. Other individuals within HFN may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.
HFN is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection if information is being processed or used by a third party.
Principle 2 - Identifying Purposes for Collection of Personal Information
HFN shall identify the purposes for which personal information is collected at or before the time the information is collected.
HFN may collect personal information from customers or the public for the following purposes:
(a) to conduct marketing activities such as promotions and contests,
(b) to conduct quantitative or qualitative marketing research;
(c) to meet legal and regulatory requirements.
(d) to effectively provide the products and services you’ve requested.
(e) to communicate with you.
HFN shall specify the purpose of the information to the customer at or before the time it is collected, and will use the information only for the purpose for which it was intended.
When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.
HFN may provide third parties with information from any survey, in aggregate form wherein it is impossible to identify an individual respondent’s personal information
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual will be obtained prior to the collection, use, or disclosure of personal information, except where inappropriate.
In determining the appropriate form of consent, HFN shall take into account the sensitivity of the personal information and the reasonable expectations of its respondents.
In obtaining consent, HFN shall use reasonable efforts to ensure that a customer or research respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent or customer. Participation by customers or members of the general public in survey research is always voluntary. If an individual agrees to participate in a survey, he/she gives consent to the interview by participating.
While disclosing any information about a customer would be done only in extremely rare cases, HFN shall normally seek consent to use and disclose personal information at the same time it collects the information. However, HFN may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.
The participation of a respondent in a quantitative or qualitative marketing research study may constitute implied consent for HFN to collect, use and disclose personal information for the identified purposes.
Principle 4 - Limiting Collection of Personal Information
HFN shall limit the collection of personal information to that which is necessary for the purposes identified by HFN. HFN shall collect personal information by transparent, disclosed and lawful means.
If conducting a survey, HFN limits the amount and type of personal information it collects to only the information needed for the purposes identified to individuals.
Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
HFN shall 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 or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
If conducting a survey, HFN may disclose a respondent’s personal information to:
(a) a research supplier to HFN where the respondent has consented to such disclosure;
(b) a third party engaged by HFN to perform functions on its behalf;
(c) a public authority or agent of a public authority if, in the reasonable judgment of HFN, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
(d) a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.
Only HFN’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.
HFN shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, HFN shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.
HFN shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
HFN shall update personal information about customers as necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 - Security Safeguards
HFN shall protect personal information by security safeguards appropriate to the sensitivity of the information.
HFN shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.
HFN shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
All of HFN’s employees with access to personal information shall be required to respect the confidentiality of that information.
Principle 8 - Openness Concerning Policies and Procedures
HFN shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
HFN shall make information about its policies and procedures easy to understand, including:
(a) the title and address of the person or persons accountable for HFN’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;
(b) the means of gaining access to personal information held by HFN;
(c) a description of the type of personal information held by HFN, including a general account of its use; and
(d) a description of what personal information is made available to related organizations (e.g. members).
Principle 9 – Individual Access to Personal Information
Upon request, HFN shall provide access to any information we may retain about an individual to that individual. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Upon written request to the Privacy Officer, HFN will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information
In certain rare situations, HFN may not be able to provide access to all the personal information that it holds about a respondent. For example, HFN may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, HFN may not provide access to information if disclosure would reveal confidential commercial information.
In order to safeguard personal information, an individual may be required to provide sufficient identification information to permit HFN to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.
HFN shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file.
Individuals can obtain information or seek access to their individual files by contacting the HFN Privacy Officer.
Principle 10 - Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for HFN’s compliance with the HFN Privacy Policy.
HFN shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding HFN’s handling of personal information.
HFN shall, on written request, inform any individual about the existence of these procedures as well as the availability of complaint procedures.
The person or persons accountable for compliance with the HFN Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.
HFN shall investigate any complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, HFN shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The individual shall be informed of the outcome of the investigation regarding his or her complaint.
Additional Information
For more information regarding the Health First Network Privacy Policy, please contact the HFN Privacy Officer by e-mail at privacyofficer@healthfirst.ca, or by mail at Privacy Officer, Health First Network, 591 Brant Street, Suite A, Burlington, ON, Canada, L7R 2G6.
Please visit the Privacy Commissioner of Canada’s website at www.privcom.gc.ca.