Roche Canada Privacy Notice
General Privacy Statement
Hoffmann-La Roche Limited (“Roche Canada”) takes the privacy and security of your Personal Information very seriously. This Privacy Notice outlines the types of Personal Information Roche Canada may collect; the ways in which Roche Canada may collect, use, transfer or disclose your personal information; steps Roche Canada takes to protect your Personal Information; and choices you are provided with respect to the use of your Personal Information.
This Privacy Notice is for:
Users of Roche Canada products, services and applications;
Visitors to a Roche Canada owned website, system or tool;
Individuals who contact or indicate they want to be contacted by Roche Canada; and
Individuals who receive this notice about how we may collect, use, transfer or disclose your Personal Information.
For purposes of this Privacy Notice, “Personal Information” is any information about an identifiable person. This may include information that could identify you either directly (e.g. your name) or indirectly (e.g. unique ID).
This Privacy Notice governs the Personal Information collected, used, transferred and disclosed by Roche Canada. Roche Canada’s parent company (“Roche Global”) and affiliates may also collect, use, transfer and disclose Personal Information that you provide to them. As applicable, your Personal Information will be controlled by such entity and handled in accordance with their respective privacy policies and procedures.
How we collect your Personal Information
In the course of carrying on our business, we may collect Personal Information directly from you or through third party service providers or from third party sources.
Personal Information may be collected directly from you when you:
Engage with any Roche Canada employee, including attending any Roche Canada in person or virtual meetings such as adboards or consultancy meetings;
Create an account and/or profile in a Roche Canada customer portal;
Conduct business with Roche (for example, buying or selling products or services to or from Roche)
Visit one of our websites, use a Roche Canada app or other digital platform;
Get in touch with us, for example through email or through a Roche Canada website, for support, to ask a question, including a medical inquiry, or to provide us with feedback;
Share/report adverse events; and
Respond to a communication, such as a marketing communication or survey, sent by Roche Canada.
Personal Information may also be collected from other sources, where appropriate, including:
Roche Canada’s parent company or affiliates;
Publicly accessible sources;
Social media platforms, e.g. LinkedIn, Twitter;
Data companies providing information in the healthcare sector, including information about Healthcare Professionals’ practice profiles, areas of interest, and communication preferences, e.g. IQVIA;
Types of Personal Information we Collect
The Personal Information we collect from you will vary depending on our relationship and your interactions with us.
If you are a healthcare provider or a customer/client, we may collect the following information:
name, business address, business and mobile phone number(s) and email address;
professional experience (qualifications, credentials, education, training, publications, practice specialties, etc.);
financial information (where applicable to enable financial transactions);
treatment site and affiliation (healthcare institution);
practice and/or business information including, where applicable, interest in Roche products and/or services;
details of our interaction(s), including face to face or virtual meetings and calls, details of sponsorship or educational support provided to you and your involvement in patient support programs;
information relating to your patients, following adverse event reporting, product complaints or medical information enquiries;
information relating to your participation in Roche sponsored or supported clinical trials (or other research), conferences or other education events; and
information obtained when you access Roche websites and/or create an account in one of our apps or digital platforms.
If you are a user of our website, we may collect the following information:
names, titles, addresses, telephone numbers, email addresses and other contact information that you provide;
any message or comment that you submit to us through the website or email; and
website analytics data, as described in section the Cookies, Websites and Application Analytics section
If you are a patient or a customer purchasing a product directly from Roche such as blood glucose meters or test strips, we may collect the following information:
name, address, home and/or mobile telephone number(s) and email address;
age, gender and diagnosis;
financial information (where applicable to enable financial transactions)
the name of any Roche product you use and your healthcare providers contact information; and
in certain limited circumstances, personal health information and medical histories.
For patients participating in a patient support program, we may collect the above information and additional personal health information, medical history, financial and insurance information in order to provide the services offered. We use third party providers to administer these programs and the service provider will collect the personal information on our behalf. The patient program enrollment form provides further details.
For patients participating in a clinical trial, the collection, use and disclosure of Personal Information is described in the clinical trial Informed Consent Form.
We may collect other Personal Information from you, with your consent or as permitted or required by law.
Consent to the collection, use, transfer and disclosure of Personal Information may be given in various ways. In some cases we will ask for your express consent to collect the information, for example in oral, electronic or written form, and in some cases it is collected based on implied consent, for example when you provide us with your Personal Information to provide you with a service you have requested. In some circumstances, we may provide you with a notice indicating how we collect, use, transfer and disclose your Personal Information and also provide you with an “opt out” option, should you choose to withdraw your consent.
The type and form of consent will be identified based on the sensitivity of the Personal Information and the reasonable expectations of the individual. You can withdraw your consent at any time, subject to any legal/contractual requirements. Reasonable notice of withdrawal must be provided. If you choose to withdraw consent, we may no longer be able to provide certain services and/or products.
In some cases, we may be permitted or required by law to collect, use, transfer and disclose Personal Information without consent, for example to comply with a court order or comply with local, provincial or federal regulations.
Using Personal Information
We use and/or process Personal Information for the reasons outlined below and for reasons reasonably related to those described below:
To manage and maintain relationships with healthcare providers, customers and any individual we interact with in the course of our business;
To provide healthcare providers and other customers with information about our products and/or services, as needed;
To identify individuals that we believe may be interested in participating in research, collaborations, partnerships, consulting or other business transactions;
To respond to requests or inquiries;
To provide information that we believe may be of interest to an individual based on their professional expertise and/or prior interactions with Roche Canada;
To complete a transaction and/or fulfill a service that has been requested, including payment of any service provided;
To track and monitor adverse events and other activities related to pharmacovigilance;
To meet legal, regulatory and security processing requirements;
To personalize and improve any interaction with us, including through use of emails, website(s), apps and systems;
To perform website analytics and measure website performance, to understand an individual’s preferences and improve our products and services; and
To maintain our website(s), including for security purposes.
Pharmacovigilance and Medical Inquiries
Any Personal Information provided to Roche Canada related to adverse events or other activities related to pharmacovigilance will be used solely for these purposes. This information is very important for public health and will be used for the detection, assessment, understanding and prevention of adverse effects or any other medicine-related problem. We collect and process your data for these purposes in accordance with specific GVP (Pharmacovigilance) legislation and in order to comply with our legal obligations. Any Personal Information provided to Roche Canada related to a medical inquiry may be used to answer the inquiry, follow up on such requests and maintain the information in a Medical Information database for reference. Where required by law (such as for pharmacovigilance), we may also be required to report the data to regulatory authorities. Your Personal Information relating to pharmacovigilance and medical inquiries will not be used for any other purpose.
Disclosure of your Personal Information
We may share your Personal Information with Roche Canada’s parent company, Roche Global, and affiliates around the world. In such cases, Roche Global and our affiliates will use your Personal Information for the same purposes as we do. A list of our affiliates is available in the current annual report, which can be found in the Investors section of www.roche.com.
We may also share your Personal Information with service providers or outside third parties, including our data processors, for the following purposes:
To help fulfill Roche Canada business transactions including technology vendors who work with us to provide you solutions such as apps or web sites;
To help conduct programs or administrative services;
To cloud providers or to conduct technical maintenance of our websites and other web platforms;
To facilitate a merger, consolidation, transfer of control or other corporate reorganization in which Roche Canada participates, or pursuant to a financial arrangement undertaken by Roche Canada;
To respond to appropriate requests of legitimate government authorities, or where required by applicable laws, court orders, or government regulations; and
Where needed for corporate audits or to investigate or respond to a complaint or security threat.
Services providers and outside third parties are required to handle Personal Information in accordance with our instructions. Roche does not share Personal Information with third parties for their own marketing purposes.
International Transfers of Your Personal Data
Any Personal Information you provide to us may be transferred to or stored in a geographic region which imposes different privacy obligations than your country of origin. This may mean that your Personal Information may be sent to a country with less restrictive data protection laws than your own. Any such transfer will be conducted in compliance with applicable law and Personal Information may be subject to the local laws of the jurisdictions within which it is collected, used, transferred, disclosed and/or stored, and may be accessed by governmental and law enforcement authorities in those jurisdictions.
Retention / Storage Period of Your Personal Data
The length of time in which we will store your Personal Information will differ depending on the purpose for which we have collected and are processing your Personal Information. In most cases, we will keep Personal Information for three (3) years following our last interaction with you. We may, however, maintain your Personal Information for a longer period of time if we are required by law to maintain your Personal Information. For example, reports related to pharmacovigilance are kept for a minimum of 10 years after the withdrawal of the product in the last country where the product is marketed.
Cookies, Websites and Application Analytics
We use information to secure our websites, network systems, and other assets. This may include information concerning your IP Address, geographic location, resources you have accessed, and similar information, we may also collect certain information that does not directly identify you by name, but could be used to identify that a specific computer or device has accessed our website. To the extent that this information is considered Personal Information, it will be managed in accordance with this notice.
Our websites and digital platforms, such as our customer portals, may use technology such as cookies, web beacons and other tracking technologies that enable us to deliver content that is tailored to your interests and preferences based on your past activity on the site and/or through the portal. Where appropriate, our websites may use a cookie banner that will inform you about the cookies and trackers the site uses and ask for your consent to the data processing.
What are cookies?
Cookies save you the trouble of reentering certain information in some registration areas, help to deliver content-specific information to you, and track which sections of the site are most popular. A ‘cookie’ is actually a file that our web server or the web server of one of our service providers or third-party partners may send to your computer when you access one of our sites. This file is then stored on your computer.
What types of cookies and other tracking technologies do we use and for what purposes?
Our site(s) may use the following types of cookies and tracking technologies, for the following purposes:
Strictly Necessary Cookies. Strictly necessary cookies are necessary for the website to function and cannot be switched off in our systems. These cookies are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but blocking these cookies will prevent the site from working. These cookies typically do not store personal data.
Functional Cookies. Functional cookies enable our websites to provide enhanced functionality and personalisation. They may be set by us or by third party service providers whose services we have added to our pages. If you reject these cookies then some or all of these services may not function properly.
Performance Cookies. Performance cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. These cookies help us understand how our sites are being used, such as which sites are the most and least popular and how people navigate around the site. Opting out of these cookies will prevent us from knowing when you have visited our site and will prevent us from monitoring site performance. In some cases, these cookies may be sent to our third party service providers to help us manage these analytics.
Social Media Cookies. Social media cookies are set by a range of social media services that we have added to the site (such as Facebook, Twitter, LinkedIn) to enable you to share our content with your friends, colleagues, and networks. These cookies are capable of tracking our browser across other sites and building up a profile of your interests. This may impact the content and messages you see on the other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.
Targeting Cookies. Targeting cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. These cookies do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Web Beacons. A web beacon is a piece of software code on a web page or in an e-mail message that is used to track pages viewed or messages opened. Web beacons tell the web site server information such as the IP address and browser type related to the visitor's computer. Web beacons may be placed in online advertisements that bring people to our site and on different pages of our site. Web beacons provide us with information on how many times a page is opened and which information is consulted. Web beacons are also known as internet tags, single-pixel GIFs, clear GIFs, and invisible GIFs.
What choices do you have regarding the delivery of targeted advertisements on third-party sites?
Most internet browsers allow you to change your browser settings to notify you when you receive a cookie, which lets you choose whether to accept the cookies, or to automatically refuse all cookies. Note that doing so may impact the functionality of some parts of our websites. If you have previously accepted cookies, you can use these same browser settings to reject such cookies if you change your mind.
Additionally, some of our websites may use third party analytics tools to collect and manage Performance Cookies on our behalf. Some specific tools we use include Adobe Analytics and Google Analytics, as described below:
Adobe Analytics: We use Adobe Analytics on our websites, which collects information through cookies. If you would like to opt out of having your data used by these cookies, please use Adobe’s opt-out tool, available here: http://www.adobe.com/privacy/opt-out.html.
Google Analytics. Our websites may use certain Google Analytics Advertising Display Features, which collect information through cookies, including Remarketing with Google Analytics and Demographics and Interests reporting. If you would like to opt out of having your data used by these cookies, please use Google’s opt-out tool, available here: https://tools.google.com/dlpage/gaoptout/.
Several places on our website require Personal Information if you choose to use them, including surveys, registration, and content sharing features (i.e., “E-mail to a Friend” links). Roche Canada and its business partners collect this information about you only if you voluntarily provide it to us. Please be aware that certain features of a site may not be available to you if you elect not to provide certain Personal Information. Any Personal Information you provide to us will be used in accordance with this Privacy Notice.
Where permitted by law, we may combine Personal Information you provide with other information you have provided to Roche Canada through our websites. Where permitted by law, we may also combine Personal Information collected through our websites and digital channels and other online resources with Roche Canada’s offline records and information provided to us by third parties.
Websites We Do Not Own or Control
Our websites also may contain links to third-party websites. We do not endorse and are not responsible for the content of third-party websites or resources, and our Privacy Notice does not apply to any sites that are not affiliated with Roche Canada, even if you access them via a link on our site. You should review the privacy policies of any third-party site before providing any information.
We do not knowingly collect any Personal Information from anyone under the age of 16 without the prior, verifiable consent of a legal representative. Such legal representative may have the right, upon request, to view the information provided by the child and require that it be deleted. Moreover, all minors should seek their parent’s or guardian’s (legal representative) permission prior to using or disclosing any Personal Information on our website or online resource. This website is not designed or intended for use by children under the age of 16.
Roche Canada uses technology and security precautions, rules and other procedures to protect your personal information from unauthorized access, improper use, disclosure, loss or destruction. In an effort to protect your Personal Information, Roche Canada uses also industry standard firewalls and password protection. It is, however, your personal responsibility to ensure that the computer you are using is adequately secured and protected against malicious software, such as trojans, computer viruses and worm programs. You are aware of the fact that without adequate security measures (e.g. secure web browser configuration, up-to-date antivirus software, personal firewall software, no usage of software from dubious sources) there is a risk that the data and passwords you use to protect access to your data, could be disclosed to unauthorized third parties.
Please note that confidentiality and security can never be 100% assured when information is transmitted or stored electronically.
You have a right to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. In the event that you believe that your Personal Information is not accurate or you wish access to your Personal Information, you may make a request using the contact information provided below.
We endeavor to provide timely access to your Personal Data. However, we may require you to verify your identity to our satisfaction prior to doing so. Further, there may be circumstances where access cannot be granted. For example, we will not grant access where doing so would lead to the disclosure of Personal Information of another individual and that individual refuses to provide consent to the disclosure, or where the information is subject to privilege or other legal restrictions. In such cases you will be notified of the reason why it is not possible to grant access to your Personal Information.
Depending on how you interact with us, you may have the following choices:
Cookies Settings and Preferences. You may disable cookies and other tracking technologies through the settings in your browser. While doing so may negatively affect your experience with the use of our websites, it will not prevent us from transacting with you.
Marketing emails. You may withdraw your consent to us processing your personal information in order to receive promotional and other materials that may be of interest to you. If you no longer wish to receive marketing emails from us, you may choose to unsubscribe at any time by clicking on the “unsubscribe” link in our emails or by contacting us directly.
Opt-Outs. You may contact us to opt out of the use or sharing of your Personal Information, including for marketing or advertising purposes, and/or the provision of your Personal Information to our business partners or third party marketing service providers for such purposes.
Online behavioural advertising. We use Google Analytics on our website. For more information on how Google Analytics collects and processes information, as well as how you can control the information sent to Google, please review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You may control your advertising preferences or opt-out of certain Google advertising products (i.e. the Google Analytics cookies) by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or visiting Google’s opt-out tool, available here: https://tools.google.com/dlpage/gaoptout/.
Complaint. If we are unable to resolve your concerns related to our privacy practices, you may have the right to complain to the Office of the Privacy Commissioner of Canada or the appropriate provincial Information and Privacy Commissioner.
Updates to This Privacy Notice
From time to time, we may revise this Privacy Notice. Any such changes to this Privacy Notice will be reflected on this page. Roche Canada recommends that you review this Privacy Notice regularly for any changes. The date on which this notice was last revised is located at the top of this notice.
How to Contact Roche Canada
For questions or if you wish Roche Canada to amend or delete your Personal Information, please contact us in writing (by post), as follows:
7070 Mississauga Road,
Email: [email protected]
Diagnostics and Diabetes Care Divisions
201 Armand-Frappier Blvd
Email: [email protected]