Privacy

IQVIA Canada (also referred to in this Policy as “IQVIA”, “we”, “us” or “our”) takes the protection of Personal Information very seriously and is committed to ensuring that its practices comply with all Canadian federal and provincial privacy laws.

This privacy policy (the “Policy") explains IQVIA’s general practices around how it collects, holds, uses and discloses Personal Information in carrying out its business and activities. 

WHAT PERSONAL INFORMATION MIGHT BE COLLECTED?

Depending on the circumstance, IQVIA might need to collect Personal Information about our personnel, job candidates, consumers, healthcare professionals, patients, medical research subjects, clinical investigators, customers, suppliers, vendors, business partners and investors. In this Policy, “Personal Information” refers to any information that identifies an individual or that can be used to identify an individual in combination with other information. Personal Information can include things like:

• first name or initial and last name; 
• home or other physical address;
• telephone number; or 
• email address or online identifier.

“Personal Information” can also contain “Sensitive Personal Information”, which includes things like: 

• government-issued identification numbers (e.g., social insurance numbers, driver’s license numbers, or passport numbers);
• financial information like bank account numbers, credit card numbers, and other banking information;
• information about an individual’s medical history, disabilities, medications they take or are interested in, and any other health information about them;
• the results of individual background checks;
• information about an individual’s race, ethnicity, national origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data, sex
• life, sexual orientation, and criminal record; or
• Personal Information about individuals under the age of fourteen (14).

However, in this Policy, “Personal Information” does not include types of information which are specifically excluded from the definition of “personal information” by applicable laws. 

HOW DO WE USE PERSONAL INFORMATION?

IQVIA will always make sure that its collection, processing, use, and disclosure of Personal Information is done for our legitimate interests, is reasonable, and is allowed by law. Where IQVIA collects Personal Information directly from an individual, our collection, processing, use and disclosure of that information is usually covered by this Policy. Where this Policy does not fully cover a given situation, we will provide individuals with an additional notice explaining why we are collecting their information, how we are going use and process it, and what types of third parties we might need to disclose that information to. In some circumstances, IQVIA may also provide individuals with an additional notice to give them specific options for limiting how we will use and disclose their Personal Information. Our notices will also include any additional information which is required by law for that specific circumstance or for the specific product or service in question. Unless we are otherwise allowed by law, we will not use, process, or disclose an individual’s Personal Information in a way that is inconsistent with how we have described in this Policy or in our notices, unless we get that individual’s consent to do so.

The specific way we will use Personal Information depends on the kind of relationship or interaction an individual has with IQVIA. Below is a description of the main types of Personal Information we collect, and the key details about how we process, use, and disclose it:

RESEARCH STUDIES AND PROJECTS:

IQVIA provides several types of services to its clients involving healthcare research where we will collect data from patients or about them. Our clients for these types of services are usually pharmaceutical manufacturers, but can also include other healthcare research stakeholders like government bodies, nongovernmental organizations (NGOs), universities, and hospitals.

Many of the studies IQVIA supports will involve the collection of Personal Information about patients or other data subjects who have agreed to directly participate in the study. Depending on the study, that information can be collected from the patients/subjects, as well as from their spouses/partners, caregivers, and relatives, and from their healthcare providers and other staff of the clinics and hospitals where they receive medical services. Study data can be collected in a number of ways, including paper questionnaires, as well as electronic questionnaires provided in-office or by email. Study data can also be collected using online study questionnaires and platforms, and can include having data extracted from the patient’s electronic medical record.

For studies where a patient or subject has directly agreed to participate, they will also be provided with an informed consent form that explains additional details about the study, the data and Personal Information that will be collected, and how it will be used and disclosed. Throughout Canada, various laws also allow research organizations and companies like IQVIA to receive Personal Information about patients, including health-related Personal Information, directly from healthcare providers, clinics, hospitals, and government bodies, without needing to directly enroll patients in the study or have them sign an informed consent form. When IQVIA provides services or receives patient Personal Information in connection with those kinds of studies, we will always use and process that information strictly as necessary and authorized for the specific studies in question, and only as allowed under the applicable laws.

As part of any study or research project, IQVIA may need to transfer or disclose study data, including Personal Information about participants, to the study sponsor or its corporate affiliates, business partners and third-party service providers performing services related to the study. As well, if we receive reports during a study or other research project about any issues which an identified patient is having with a pharmaceutical drug, such as side effects or difficulty administering the drug, we will also need to report that information to the manufacturer, so that they can follow up with the patient and/or their healthcare provider.

HUMAN RESOURCES INFORMATION

For the purposes of this Policy, “Personnel” includes, but is not limited to, any employee (permanent or temporary), director, officer, contractor, worker, temporary worker, job applicant, or retiree of IQVIA, and any and all of their respective dependents.

We will collect, process, store, and use Personal Information about Personnel in order to carry out and support our human resources functions and activities, including but not limited to (i) evaluation of qualifications for an employment position; (ii) provision of employment benefits; (iii) administration and management of employees, compensation, stock options, grants and purchase plans, bonuses, retirement, training, and career planning; (iv) utilizing employee skills and ongoing employee resource allocation; (v) communicating with employees or their emergency contacts; (vi) administration of the company's business including budgeting, manpower planning, and organizational design; (vii) authentication of the individual's identity when gaining access to computer system applications; (viii) information data changes; (ix) employment status changes; (x) travel and expense planning and reimbursement; (xi) evaluation of employee performance and time management; and (xii) management of Personnel performance, including implementation, investigation, and reporting on compliance and discipline procedures and matters. In addition, for job applicants, their information will be used for the evaluation of suitability of the applicant for a position, or to assess and contact them in connection with future positions. We may use automated decision-making processes in connection with these evaluations and assessments, including for pre-screening of applicants. IQVIA may, at its discretion and with the consent of the candidate where required by law or otherwise obtained, perform such background checks as deemed appropriate to evaluate this suitability.

Further information concerning how IQVIA collects, uses, shares and safeguards the information of any employee (permanent or temporary), director, or officer is available to such Personnel in IQVIA’s internal privacy and information technology policies, and those of the global IQVIA organization.

BUSINESS CONTACTS

IQVIA collects business contact information about individuals who we might need to contact for business or professional purposes. This information is usually collected directly from the individuals concerned, but can also be obtained from public sources or from the employers, affiliates, vendors, service providers, or other business associates of the individuals in question. For example, in order to carry out research studies and projects, we will collect contact information on clinical investigators or other study personnel, and on consultants, contractors, managers, employees, and agents of the study sponsor and its corporate affiliates, business partners and third-party service providers. Similarly, we will also collect the contact information of the employees and representatives of IQVIA’s actual or potential vendors and service providers, of our actual or potential clients, and of actual or potential attendees at IQVIA-sponsored conferences and events. We will use this contact information to contact and interact with these individuals in the context of the business or professional relationship in which we received the information and to manage and pursue that relationship, and for other consistent purposes such as marketing activities relating to our various products and services, requests to participate in studies, projects, and research activities, and invitations to IQVIA conferences and events. In most cases, business contact information is not considered protected personal information under applicable Canadian laws.

HEALTHCARE PROFESSIONALS

IQVIA collects information about healthcare professionals directly from the healthcare professionals, from public sources, and from business partners. We use this information in connection with various healthcare activities, including clinical trials, real world studies of patient treatment, healthcare outcomes analysis, market research activities, and other situations where primary intelligence from healthcare professionals is applicable. Similarly, we may also use Personal Information provided from or about healthcare professionals in connection with the administration of patient support programs, or as part of verification processes we manage for access by healthcare professionals to various online sites, services, or programs. We will also use available information about healthcare professionals and their practices in order to help our clients streamline their outreach activities and trade coverage with those individuals. In situations where the information in question would be Personal Information, we collect, use, process, and disclose that information strictly as permitted by law and in accordance with any written authorizations issued by the relevant government privacy authority. With respect to certain information about prescribers, IQVIA has enacted its own detailed codes of conduct (see our Code for the Management of Protected Information Respecting Health Professionals (Excluding Quebec) and our Code for the Management of Personal Information Respecting Health Professionals in the Province of Quebec) to ensure that our collection, use, processing, and disclosure of that information meets the highest standards of ethical and responsible data management.

CUSTOMERS AND PROGRAM PARTICIPANT INFORMATION

Individuals may share their Personal Information with IQVIA in order to ask about, purchase, or use our products or services, or to ask us for information about healthcare products and services, opportunities to participate in clinical research, healthcare education, and patient support programs which may be available through IQVIA. We will use such Personal Information in connection with providing the requested information, products, and/or services, and for related legitimate business uses, such as processing requested transactions, improving the quality of our products and services, sending communications about the products and services available through IQVIA, and enabling our business partners, service providers, and representatives to perform certain activities on our behalf. We may also provide our clients with Personal Information about the use of our products and services by their employees and representatives, in connection with helping clients monitor, understand, and/or optimize their use of our products and services.

DATA ANALYTICS

As part of its products and services, IQVIA provides statistics and data analytics on healthcare in Canada to various types of clients like biotech, medical device and pharmaceutical companies, medical researchers, government agencies, payers, professional bodies, and other healthcare stakeholders. However, IQVIA never collects or uses Personal Information about patients in order to create our statistics and data analytics offerings. When sourcing the raw data for these products and services, IQVIA always requires its data suppliers to anonymize the data before it is sent to us, so that it does not identify any individual patient.

In other situations, IQVIA will provide services to clients where we help them analyze and understand their own data. In those cases, the data we receive from them can contain Personal Information about patients, or about the client’s own interactions with healthcare providers. However, we will only process that data to provide our analytics services to the specific client who has hired us, and we will not use the data for any other purpose unless required by law. For example, a client might hire IQVIA to help them anonymize their own data so that they can use it more safely in their own internal business analytics, or a client might hire us to help administer a patient support program or to analyze the performance and effectiveness of a patient support program. For all of these situations, the collection of the Personal Information in question would first be covered by our client’s own privacy policies, consent forms, or other privacy notifications, and our contracts with our clients would also require them to ensure that they are fully authorized, either under those policies, forms, or notifications, and/or by law, to provide that information to IQVIA so that we can analyze or process it on their behalf.

HOW DO WE TRANSFER PERSONAL INFORMATION?

Any Personal Information which we collect in conducting our business activities can be transferred between the various provinces and territories of Canada, and to other countries, as it is transferred between different key points in our information processing network. That can include our own proprietary data storage facilities, as well as data storage facilities of our global IQVIA affiliates or the facilities of third-party storage providers where we have contracted IQVIA-dedicated space. Depending on the circumstance and the purpose for which Personal Information was collected, we may need to share it with certain third parties mentioned above in this Policy, across provincial or territorial borders and outside of Canada, such as to research or program sponsors, clinical research staff, and healthcare providers.

IQVIA may also share an individual's Personal Information with our own external service providers or agents who provide services to us in connection with our collection, processing, use, storage, disclosure, or destruction of that information. That sharing can require the data to be transferred across provincial or territorial borders or to other countries. When we hire those third parties to help us collect, process, use, store, disclose, or destroy Personal Information, we will ensure that we have a contract or formal arrangement in place with that third party that requires them to handle the information strictly for the purpose of providing their specific services to IQVIA, and for no other purpose. We will also require those third parties to commit to protecting the Personal Information and handling it in a manner that complies with this Policy.

When IQVIA obtains Personal Information as a service provider for its clients or affiliates, IQVIA’s clients or affiliates are responsible for i) protecting individual rights with respect to how that information is disclosed or transferred, ii) for determining the purpose, limits, and instructions IQVIA will follow in handling the information, and iii) for providing any necessary or appropriate notices to individuals about the handling, disclosure, or transfer of their information. That being said, IQVIA will never knowingly handle Personal Information provided in those circumstances in a way that does not comply with applicable laws.

IQVIA does not sell or otherwise disclose Personal Information, except as described in this Policy or in a notice provided to individuals at the time that we collect their Personal Information, unless those individuals otherwise consent.

ONLINE SERVICES

Whether you are a patient, consumer, client representative, healthcare provider, clinical research staff member, employee, or employment candidate, you may use IQVIA websites, online portals, and web-based services (including our software-as-a-service solutions) to interact with IQVIA, learn about IQVIA and our products and services, or use our online tools. While most of the Personal Information you provide us in the process of using those online tools is covered by this Policy, there are also certain specific types of information that we collect during your use of those tools in order to facilitate and manage your interaction with those tools. In order to learn more about that kind of information, and how we collect and use it, please consult the Global IQVIA organization’s Online Privacy Policy. That is also where you will find information about our use of Cookies in our online tools.

SECURITY

IQVIA takes reasonable and appropriate steps to protect the Personal Information in its possession or control from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved and the nature of the Personal Information in question. Those steps include technical, administrative, and physical safeguards around privacy and information security. We also have a privacy incident response program designed to quickly respond to all privacy-related questions, complaints, and concerns, including any potential privacy or security incident.

Personal Information is only available within IQVIA to the IQVIA employees who need access to it in order to perform the activities described in this Policy. Any Personnel that IQVIA determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment, where applicable, in accordance with IQVIA’s disciplinary procedures.

DATA RETENTION

The Personal Information we collect may be archived or stored periodically by us according to backup processes and will only be kept for as long as required in connection with the purposes for which it was collected to run our business and to provide our products and services, including to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our rights and agreements, and comply with applicable laws.

DATA INTEGRITY AND PURPOSE LIMITATION

IQVIA aims to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individuals in question, and/or as allowed by law. IQVIA takes reasonable steps designed to ensure that we only collect and handle the type and amount of Personal Information that is relevant to its intended use. We also aim to ensure that such information is kept accurate, complete, current, and otherwise reliable in relation to the purposes for which the information is obtained or processed. Where IQVIA collects or processes Personal Information for a research study or project, or otherwise acting under the direction of its customers, IQVIA works with such customers so that the customers can provide a way for the individuals concerned to correct or update their Personal Information to the extent required by law.

YOUR RIGHTS

Under various privacy-related laws throughout Canada, individuals have certain rights with respect to Personal Information which others collect or use about them, such as the right to access, amend, correct or delete Personal Information that is inaccurate, incomplete or outdated. Depending on the circumstance, those individuals may have additional rights including the right to file a complaint with their local data protection authority, the right to object to their data being collected or processed, the right to request additional information about how we collect, process, and protect their Personal Information, the right to obtain a copy of their Personal Information, as well as certain rights related to our use of their Personal Information in any automated-decision making processes. IQVIA will take reasonable steps to comply with any rights requests which individuals make to us about their Personal Information, unless we have a legal right to refuse. In order to comply with certain rights requests, it may be necessary for IQVIA to transfer an individual’s Personal Information to or from another province, territory, or country. Please bear in mind that when IQVIA is processing Personal Information as part of a research study or project, or in the context of processing Personal Information provided to us by a client for that client’s own direct use, IQVIA does not usually have a direct relationship with the individuals who are the subject of that information. In that situation, those individuals may need to direct their rights requests directly to the responsible party, such as the study sponsor, study investigator, or relevant IQVIA client. We will of course provide reasonable assistance in helping individuals direct their rights requests to the appropriate party.

If IQVIA determines that it is not required to agree with any individual rights request, we will provide the individual in question with an explanation of why that determination has been made, and with a contact point for any further inquiries. To protect the privacy of data subjects, IQVIA must take commercially reasonable steps to verify an individual’s identity before processing or granting any rights request about their Personal Information.

IQVIA encourages individuals covered by this Policy to raise questions about the processing of their Personal Information by contacting IQVIA through the contact information provided below.

RESERVATION OF RIGHTS

As mentioned elsewhere in this policy, IQVIA reserves the right to collect, use, process, and disclose Personal Information for the purposes, and in the ways, allowed by law or regulation. This can include, without limitation, secondary purposes that are consistent with the initial purposes for which the information was collected, and uses that are otherwise clearly for the benefit of the individuals concerned. We may also use the Personal Information to develop internal research and statistics, but only once we have de-identified the information so that it no longer directly identifies the individuals concerned.

IQVIA may also use or disclose Personal Information in order to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes. Similarly, we reserve the right to use or disclose Personal Information as necessary and appropriate (i) in response to lawful requests by a court or public authorities, including to meet national security or law enforcement requirements, (ii) under the discovery process in litigation, (iii) to enforce IQVIA policies or contracts, (iv) to collect amounts owed to IQVIA, (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity, or (vi) in order to protect or enforce our legal rights.

IQVIA may also need to transfer Personal Information in the context of an actual or potential sale of all or part of our business, to the purchaser or its service providers. In that situation, IQVIA will aim to require the purchaser to use the Personal Information in a way that is consistent with this Policy.

CONTACTING IQVIA:

Questions, comments, concerns, or complaints regarding this Policy or IQVIA’s collection or processing of Personal Information should be submitted to the IQVIA Chief Privacy Officer at PrivacyOfficer@IQVIA.com.

CHANGES TO THE PRIVACY POLICY:

This Policy may be updated from time to time. The current version of this Policy will always be posted on our website. We reserve the right to change our privacy practices to the extent allowed by law and to apply the changed practices to all information we have about you. By using our services or participating in our studies, programs, and activities, you agree to be bound by the terms of the most up-to-date version of this Policy, as located on our website at any given time.

IQVIA CANADA PRIVACY POLICY EFFECTIVE DATE: October 2, 2023