This version in effect since April 4, 2005
Our Privacy Commitment to You
Genuine Health recognizes the importance of an individual’s right to keep personal information private. We have made a commitment to ensuring that personal information in our custody remains secure and is not used in a manner that is inconsistent with this Policy and with Canadian privacy legislation. We do this by adhering to the principles that relate to the collection, use, retention and disclosure of your personal information. These principles are based on Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), in effect since January 1, 2004.
Canadian Privacy Legislation (PIPEDA)
PIPEDA governs the rights of individuals with respect to the collection, use and disclosure of their personal information by any private sector organization that engages in commercial activities. It states that information must be: gathered with consent of the individual to whom the information relates; collected for a reasonable purpose; used only for the purposes for which it was collected; disclosed only with consent of the individual to whom the information relates; kept accurate and up-to-date; accessible for the owner’s inspection and correction; and stored securely.
Genuine Health has always maintained a high level of security with respect to the confidentiality of any personal records, but we are now obligated by law to advise and obtain consent to the terms of the collection, use and disclosure of your personal information.
What is Personal Information?
“Personal information” means information about an identifiable individual; it is information by which the identity of an individual can be deduced. However, personal information does not include the name, position or title, business address or business telephone number of an employee of an organization. It also excludes publicly-available information, such as information listed in a public telephone directory.
Genuine Health is accountable for all personal information in its control. This includes information under the direct control of Genuine Health, as well as personal information that Genuine Health may transfer to its affiliates or to third party service providers for processing, storage or other purposes that facilitate Genuine Health’s business operations or that have been consented to by the individuals to whom the information relates. We will use contractual or other measures to require third parties that process information on our behalf to maintain a level of privacy protection comparable to our own practices.
To ensure accountability for all personal information collected, used and disclosed by Genuine Health, we have developed appropriate policies and practices and have trained those individuals within our organization that deal with personal information.
Our Collection, Use and Disclosure of Personal Information
Whenever Genuine Health collects personal information, we always disclose the purposes for which we are collecting the information, the manner in which we plan to use the information and the entities to whom the information will be disclosed. We may use and disclose the personal information we collect from our customers, consumers, subscribers and other individuals to manage our relationship with such individuals, to administer accounts, to provide business services and to otherwise carry on our business operations.
If we choose to use personal information already in our custody for a purpose that was not identified at the time we initially collected the information, unless the new purpose is required or authorized by law, we will seek the consent of the affected individuals before using this information for these new purposes.
In addition to identifying the purposes for which personal information will be used and to whom it may be disclosed, we will obtain the consent of the individual to whom the information relates before we collect, use or disclose this personal information. Individuals may withdraw consent at any time by contacting our Privacy Officer at the contact information listed below.
We will not refuse to provide a service to an individual if they choose not to provide us with their personal information, unless their failure to provide the information makes us unable to provide the service.
If you are or will become a customer of Genuine Health, you were asked or will be asked to complete the Credit Application form used by Genuine Health (and modified from time to time) so that we may open an account for you and establish a business relationship. If you are an individual, sole proprietor or the principle of a corporation, the personal information you are required to provide includes:
- telephone number;
- banking information, including the name, branch, address, contact name, telephone number, and fax number of your bank;
- credit card information where payments are to be made by credit card; and
- trade references for three of your current suppliers/creditors, including their name, phone number, and fax number.
The Credit Application information you provide is maintained on file for as long as you continue to keep an active account with Genuine Health and for a period of six (6) years after you cease to be an active customer, as prescribed by statute.
Genuine Health is a member of Equifax Canada, a credit reporting service. We check the credit history of all potential new customers prior to opening an account. In addition, we share payment history information about our customers with Equifax.
When a consumer contacts Genuine Health with a concern regarding one of our products, we record the following information:
- name of the consumer;
- telephone number;
- address of the consumer;
- product and lot number;
- nature of the complaint; and
- store where the product was purchased.
The information we collect is summarized and used to determine the need for further investigation so that we can more effectively manage our business relationship with our consumers.
Genuine Health solicits input from recipients of Health & Happiness, our online newsletter, as well as from readers of our product brochures. When a consumer sends comments to Genuine Health, these comments may be incorporated into future newsletters or displayed on our website. A respondent’s full name will never be used and the comments may be edited for clarity and length.
In addition, Genuine Health collects certain personal information from consumers through contest entry forms and e-mails. Contest participants are asked to provide their name, address, telephone number, e-mail address and whether they would like to receive our Health & Happiness on-line newsletter. The ballots are securely destroyed once the contest has been completed.
Our use of your personal information will be limited to the purposes for which it was collected, and disposed of in a secure manner when it is no longer needed. The specific details will be disclosed to you, the consumer, at the time of the collection and your consent to use the information collected will be obtained at that time.
If you apply for employment with Genuine Health, we will need to consider your personal information as part of our review process. The information collected in the context of the application process will be used solely to assist Genuine Health in making employment decisions in the course of operating our business, or other business decisions we deem necessary based on your anticipated association with us. The information provided by you will not be otherwise disclosed to external parties except as required or permitted by law or with your prior consent. We may retain information from non-hired candidates after a decision has been made, unless we are requested in writing to destroy this information. Should you accept a position with Genuine Health, the information will be retained in accordance with our procedures for employee records.
Access and Correction of Personal Information
We are committed to open and fair privacy practices. Any individual may inquire about the personal information that Genuine Health has in its custody by contacting our Privacy Officer at the contact information listed below. After receiving a request, our Privacy Officer will inform the individual of the existence, use and disclosure of their personal information and will allow the individual to access the information. Your rights to access your personal information are not absolute. In certain circumstances, access may be denied. If we deny an access request, we will advise you in writing of the reason for the refusal. You may then challenge our decision.
Where personal information that is used on an on-going basis is not accurate, complete, and up-to-date, upon being advised of the inaccuracy, the Privacy Officer will takes steps to ensure that this information is amended. Genuine Health does not routinely update personal information unless it is necessary to fulfilll the purposes for which the information is collected.
Inquiries, Requests or Complaints
Numerous individuals within our organization are responsible for the day-to-day collection and processing of personal information. However, Genuine Health has a designated Privacy Officer who is ultimately accountable for the handling of all personal information under our control and for ensuring that the principles set out in this Policy are being complied with. Any inquiries, requests or complaints with regard to the way that Genuine Health handles or manages personal information should be directed to our Privacy Officer who can be reached as follows:
317 Adelaide Street West
Toronto, ON M5V 1P9