The practices that we have adopted reflect requirements set out in all provincial and federal legislation. This includes the Personal Information Protection and Electronic Documents Act (PIPEDA), which applies to the collection, use, and disclosure of personal information in the course of commercial activities, including pharmacy services and retail stores.
The North West Company
- is accountable for the personal information that we collect and have in our custody and has entrusted to its authorized agents or third party service providers.
- will inform employees and customers, where practical, as to why we must collect any of their personal information before the information is collected.
- will obtain consent (implied or informed) before or when we collect, use, or disclose personal information an individual. When allowed by law or contract, individuals may withdraw their consent at any time.
- limits the amount and type of personal information we collect. We will collect personal information only for the purposes that we have identified or as otherwise permitted by law.
- will use or disclose personal information only for the reasons that such information was provided it to us. We will keep personal information only as long as is necessary to accomplish these purposes.
- will endeavor to maintain the accuracy of the personal information in our possession or control.
- protects personal information with safeguards deemed appropriate to the sensitivity of the information.
- will be open about the policies and practices used to manage personal information.
- will, at an individual's request, advise that individual of what personal information we have in our possession or control about, what it is being used for, and to whom and why it has been disclosed.
The North West Company is accountable for the personal information that is given to us.
The North West Company will inform individuals as to why we must collect any personal information before the information is collected.
How we use and disclose personal information
We may use personal information to provide individuals with services. We may use personal information to co-ordinate care or services with other service providers or organizations as we have always done in the past. Examples include filling a customer's prescription or speaking with past employers, or contacting financing institutions with which individuals do business with for clarification purposes.
We may use and disclose personal information in order to receive payment for the products or services provided.
North West Company staff, using their professional judgment, may disclose personal information to other service providers that is directly relevant to services rendered.
We may contact individuals to provide reminders or information about services that may be of interest to them. We may also contact individuals about store openings or closings in their area.
We may use and disclose personal information to tell customers about services that may be of interest to them.
In order to keep personal information up-to-date, North West Company staff at any of our locations could discuss with individuals the personal information we have in our records. They will also remind customers and employees why they require certain personal information and, if required, will ask for consent to collect and use it.
Other reasons that we may require personal information
From time to time, the North West Company and its affiliated banners may offer promotions, loyalty programs and other in which customers may want to participate. In order to provide our customers with the full benefit of these services, we may ask for certain personal information. At the time of collection, we will advise of the specific purpose for which the information is required and we will provide the option to consent to the collection, use and/or disclosure of that information. If individuals choose to withhold their consent, we may not be able to provide the service contemplated.
The North West Company will obtain consent before or when we collect, use or disclose personal information. An individual may withdraw their consent at any time.
Why does our staff need an individual's consent?
Under Canadian privacy legislation, staff must get express consent (informed) to collect, use and disclose certain personal information (such as personal health information). This may include information we currently have on record and have always collected, used and disclosed to provide pharmacy, credit, and other services. Legislation requires us to formally ask for consent to collect, use and disclose personal information as well as to document the consent provided to us. However, implied consent can be attained under certain, limited service agreements fulfilled between the individual and the North West Company.
How will we ask for an individual's consent?
When first visiting one of our banner stores and requesting service from us, our staff will provide a description of why personal information is required and to whom they must disclose it. Individuals may be asked to confirm their consent and this will be documented in our files. On occasion, individuals may be asked to update this consent to ensure that our records remain accurate.
There may be times when customers or employees want us to share personal information with a family member or authorized representative or, alternatively, to specifically restrict with whom we may share the information. We will comply with those specific requests upon receipt of written notification to one of our customer service representative or to the Chief Privacy Officer.
What happens if an individual chooses not to give their consent or withdraws consent at a later date?
If a customer or employee chooses not to provide us with their consent to collect and use the personal information, we will still be obliged to comply with all the federal and provincial laws that require us to keep a record of services or products we have provided to. If an individual does withdraw their consent, we may not be able to provide or continue to provide that individual with certain services or products.
Exceptions to requiring consent
The North West Company will collect, use or disclose personal information without consent of an individual only in limited circumstances as permitted by law.
There have always been, and may continue to be, instances where we may collect, use or disclose personal information without an individual's consent. These instances are permitted under privacy legislation in order to ensure that the consent requirement is not a hindrance to anyone's health and safety.
Personal information may be collected without consent where the collection is clearly in the interest of the individual and consent cannot be obtained in a timely way.
Personal information and non-personal information may be collected through the use of technology such as through video surveillance at our stores, warehouse, and office or through electronic means such as when individuals visit one of our social media sites.
Personal information may be used or disclosed without consent where it's use or disclosure is needed for the purpose of acting in response to an emergency that threatens the life, health or security of an individual.
The collection, use and disclosure of information required by third party service providers essential for the provision of the services, or required by our regulators, including self-regulatory organizations, do not need specific consent from individuals. Some of our service providers are located outside of Canada. As a result, an individual's personal information may be accessible to regulatory authorities in accordance with the law of these jurisdictions.
The North West Company limits the amount and type of personal information we collect. We will collect personal information only for the purposes that we have identified or as otherwise permitted by law.
We will limit the collection of personal information to that which is required to accomplish the purposes for which it is being collected.
The North West Company will use or disclose personal information only for the reasons that the individual provided it to us. We will keep personal information only as long as is necessary to accomplish these purposes.
In order to provide customers and employees with quality products and service while complying with existing federal and provincial legislation, we keep a record of the transactions conducted with our customers and our employees for a prescribed period. We will retain personal information (including transactional information) for the period of time that is required by various legislations or by self-regulatory organizations.
We will not share personal information with any third parties, except as expressly consented by our customers or employees, through implied consent provided by individuals entering into an agreement or contract with us, or as may be required by law or self-regulatory organizations.
Where we have collected personal information in relation to a loyalty program, contest, promotion or some other purpose, we will use that personal information only for those purposes and for any other related purpose that we have disclosed to our customers and employees and to which we have received that individual's informed or implied consent. We will keep personal information only as long as is necessary to provide with those our services.
If we intend to use an individual's personal information for a new purpose, not previously identified, we will obtain consent prior to use for the purpose. When personal information is no longer required, it will be destroyed or depersonalized.
The North West Company will endeavor to maintain the accuracy of the personal information in our possession or control.
In order to provide our customers and employees with a high degree of professional service, we must ensure that the personal information that we collect about an individual is accurate, complete and current. From time to time, customers and individuals will be asked by our customer service representative, human resources or payroll, or our pharmacist to update certain personal information.
Individuals are encouraged to advise us of any changes to their personal information that may be relevant to the services we are providing. At any time, individuals can request in person to allow access to review their own personal information we have on hand about them and, where necessary, individuals will be able to immediately provide updated information so that personal information can be corrected and to ensure that it is accurate within our system.
The North West Company protects personal information with safeguards appropriate to the sensitivity of the information.
We protect personal information by using physically secure facilities, industry-standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to prevent the loss, misuse and alteration of the information under our control. To prevent unauthorized electronic access to personal information, we maintain information collected in password-protected environments.
The North West Company will be open about the procedures used to manage personal information.
At receipt of written request, The North West Company will confirm the authenticity of the requestor, advise of what personal information we have in our possession or control, what it is being used for, and to whom and why it has been disclosed.
Each person has the right to review and obtain a copy of his or her personal information on record with limited exceptions. This information can include applications for credit or employment, transactional information, loyalty programs, prescription and billing records. To find out what information The North West Company has in its records, contact them by writing to our Chief Privacy Officer. In most instances, they will respond to an individual's request within 30 days of receiving the request. The North West Company reserves the right to charge an administration fee to cover the cost of retrieving and providing copies personal information.
If an individual has any concerns about the access provided to their records, or if he or she wish to amend the information, they are encouraged to discuss it with our staff, who will be pleased to assist in any way they can.
The North West Company will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.
To challenge compliance with this Policy in relation to products or services or personal information collected, please bring any concerns in person to the attention of one of our customer service representative, by calling our toll free number (1-800-563-0002), or in writing to the Chief Privacy Officer who is responsible for investigating complaints and responding to the person making the request (or their authorized designate) in a timely fashion and will do so, in most instances, within 30 days of receiving the request.
Where it is believed that legitimate concerns have not been satisfactorily addressed, contact the Chief Privacy Officer directly (please see Contact Information, page 6). The Chief Privacy Officer will ensure that a complete investigation of any complaints have been undertaken and will report their findings to the originator of the complaint within 30 days of receiving the complaint.
Privacy and our employees
We have taken steps to help ensure that our employees govern themselves in accordance with this policy. In addition, our employees' own privacy rights are important to us, and we have taken steps to protect the information they provide to us in the employment environment, including:
- Limiting the information collected on employment and benefits applications to the information that is necessary to administer their employment and benefits.
- Safeguarding their employment information.
- Providing them with personal access to their employment files, with limited exceptions.
- Providing them with an opportunity to challenge our privacy practices.
Our Web site Privacy Statement
The North West Company
77 Main Street
Winnipeg, Manitoba R3C 2R1
Please feel free to visit the Privacy Commissioner of Canada's web site at www.privcom.gc.ca.