GenCAN protects the privacy of all
patients who use Gen-Clozapine and other brands of
clozapine medication. This Privacy Policy outlines how
the Gen-Clozapine Access Network (GenCAN) safeguards
your privacy and manages your personal health
information.
Your Privacy Rights
All persons or entities that have access to
personal health information in Canada, including GenCAN,
must comply with the federal Personal Information Protection
and Electronic Documents Act (“PIPEDA”) in respect of
certain personal information it collects, uses and
discloses. If they operate in certain Canadian provinces,
these persons or entities, including GenCAN, may also be
subject to provincial privacy legislation. These acts give
you rights in respect of your personal information.
GenCAN is responsible for protecting the
personal health information it collects, uses and
discloses. To ensure this accountability, we have named a
GenCAN Privacy Officer and developed this Policy, as well as
other guidelines, practices and policies. We have also
trained our personnel, formally and informally, about our
policies and practices. This Privacy Policy governs
GenCAN’s collection, use, disclosure and retention of your
personal health information, subject to applicable laws and
the Health Canada’s requirements for Gen-Clozapine.
“Personal health information” is defined in
the acts cited before. Put simply, it includes all
information relating to your physical or mental health,
including information about your health history. It also
includes your health insurance number.
Why Does GenCAN Need Your Personal Health Information?
Gen-Clozapine was approved by Health Canada
as a safe and effective drug in the treatment of certain
illnesses. The illnesses for which Gen-Clozapine may be
used, and the conditions of this use, are described in a
“product monograph” for Gen-Clozapine. Under the terms of
this document approved by Health Canada, your physician may
only prescribe Gen-Clozapine for you if GenCAN and he or she
can monitor your white blood cell counts and absolute
neutrophils counts (also known as your “haematological
status”). For this reason, GenCAN is required by the Gen-Clozapine
product monograph and by law to collect, monitor and store
information about your haematological status (namely, blood
test results).
Under the Gen-Clozapine product monograph,
GenCAN must also be able to share this safety-related
information with the clozapine databases of other approved
clozapine manufacturers in Canada, so that your physician,
GenCAN and these other databases can ensure that you are
using a clozapine drug safely. For this reason, GenCAN is
also required by the Gen-Clozapine product monograph and by
law to disclose some of your personal health information to
your physicians and other clozapine databases.
What Personal Health Information Does GenCAN Collect?
GenCAN collects the following personal health information about you, for the purpose described above: initials of your name (first and last), date of birth, gender, province and health insurance number, as well as information about your haematological status. Because GenCAN must monitor your status continuously, GenCAN will continue to collect information about your haematological status for as long as you use Gen-Clozapine. GenCAN collects this information through your physician.
GenCAN may also collect other relevant personal health information from your physician for the only purpose of ensuring that you can safely use Gen-Clozapine.
How Does GenCAN Use Your Personal Health Information?
GenCAN reviews all new information about your haematological status (blood test results) to ensure that you can continue to use Gen-Clozapine safely.
Only GenCAN employees that need to access your personal health information have access to it. GenCAN also takes all reasonable precautions to ensure that your information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are: premises security; technological safeguards like security software and firewalls to prevent unauthorized computer access; internal password and security policies; and restricted file access to your personal information.
During the course of its operations, GenCAN may retain other entities to provide certain administrative or contracting services, such as computer or archival file storage. Certain of these entities may be located outside of your province and not subject to either PIPEDA or provincial privacy legislation. But GenCAN monitors all of these third parties to ensure that they comply with this Privacy Policy and that they adopt measures to safeguard your privacy, consistent with PIPEDA and other applicable legislation.
How Does GenCAN Disclose Your Personal Health Information?
GenCAN only discloses your personal health information to other clozapine databases, in accordance with the GenCAN product monograph, and only for the purpose of ensuring that you may continue to use a clozapine drug safely. For the same purpose, GenCAN may also disclose the personal health information we hold to your physician and other health care providers.
We Need Your Consent
GenCAN cannot collect, use or disclose your personal information unless you expressly consent to GenCAN doing so. When you register as a patient in GenCAN, your physician asks you to provide certain identifying information, and informs you that this information and information about your haematological status will be released and stored by GenCAN and other clozapine databases. Your physician also asks whether you consent to this information being collected, used or disclosed by GenCAN.
It is your right to revoke, modify or condition this consent at any point in time, and you may contact GenCAN’s Privacy Officer to do so. You may choose to revoke, modify or condition your consent, however, it may no longer be lawful for the manufacturers of Gen-Clozapine and other clozapine drugs to supply you with any clozapine drug in Canada.
Accessing, Updating And Correcting Your Personal Health Information
You may ask GenCAN to access the personal health information it holds by contacting the GenCAN Privacy Officer. In most instances, GenCAN will respond to your request within 30 days.
You may also contact the GenCAN Privacy Officer, in writing, to request that we correct any information we hold that you believe is inaccurate. In most instances, GenCAN will inform you within 30 days whether it has made the correction requested, or why it has not made the correction requested.
Contacting The GenCAN Privacy Officer
If you have any questions about this GenCAN Privacy Policy, or wish to access or correct the personal health information GenCAN holds, please write to the GenCAN Privacy Officer at:
The Gen-Clozapine Access Network
Attn: GenCAN Privacy Officer
85 Advance Road
Etobicoke ON M8Z 2S9
Tel: (800) 668-3174 ext. 272
Fax: (416) 236-9878
If after contacting GenCAN you are not satisfied with our response, you may also contact the Privacy Commissioner of Canada or the Information and Privacy Commissioner for Ontario:
Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B, 3rd Floor
Ottawa ON K1A 1H3
Tel.: (800) 282-1376
Fax: (613) 947-6850
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Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto ON M4W 1A8
Tel.: (800) 387-0073
Fax: (416) 325-9195
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Please keep this GenCAN Privacy Policy for future reference.
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