TELUS Consumer Health Privacy Commitment
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Our privacy commitment to you © 2017 TELUS. 17_01757 Our privacy commitment to you At TELUS Health1, we respect our customers’ privacy and take great care to Exception: safeguard personal information, which includes personal health information. As This Commitment does part of our ongoing commitment to putting customers first, we have a long- not apply to personal standing policy of protecting privacy. We believe that an important part of information provided by protecting privacy is to be clear about how we handle customers' personal or about customers of information, and to make information about our approach easily accessible. TELUS Communications While the TELUS Privacy Code sets out the general principles that govern the Inc. Our commitments collection, use and disclosure of our customers’ personal information2, we have governing the collection, also developed this TELUS Health Privacy Commitment to provide you with use and disclosure more specific details about our privacy practices supporting our health related of such personal products and services.3 information are included in the TELUS Privacy We have learned from our customers that sometimes you just want the big Commitment. picture, while other times you may want more details or examples of how a policy or process works. For this reason, we have structured this Privacy Commitment in layers. Importantly, both our Privacy Code and Privacy Commitment reflect the requirements of Canada’s applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, and applicable provincial health legislation4 along with our own continuing commitment to customer privacy. The bottom line is that we want you to understand the purposes for which we collect, use and disclose personal information and about our customers. The following is a summary of our privacy practices. Why we collect personal information When we share personal information Some of the ways we respect your privacy Choices we offer you Questions? TELUS Consumer Health 2 | Privacy Commitment Why we collect personal information If you are a TELUS Health customer, TELUS Health collects certain personal information from or about you. We collect personal information only for the following purposes: To establish and maintain We may require certain technical recommendations and special • information from you, such as offers from TELUS Health a responsible commercial your wireless device information, and others that we think will relationship with you and to telephone number, email, and interest you; provide ongoing service. operating system in order to set up To recommend a new feature of some of our services or to assist you Here are some examples of what we • the applications you use; in troubleshooting service issues. mean by this: • To better understand your When you apply for a service, we preferences, and to help us To understand your needs and • may set up an account and collect develop or enhance our products personal information such as name, preferences. and services; address, date of birth, preferred Here are some examples of what we To recommend a new service or language, TELUS Health account mean by this: • TELUS app that we think you’ll number(s), any other authorized enjoy based on your existing We maintain a record of the products users, unique account security PIN(s) services with us or the apps • and services you receive from and email address; you use. us, and we may collect additional • In order to confirm your identity and/ information about the usage and • We may note that you have certain or conduct a credit check, we may patterns associated with those TELUS products and services ask for acceptable identification or products and services so that we and offer you a discount if you identifying information; can better meet your needs and bundle services; • We collect and use some personal preferences; • We may de-identify personal information to confirm your identity We may collect or infer information information to conduct research when you contact us. For example, • about you or your preferences for or analytics to derive insights or to when you contact us, we will ask to particular products, services or share that de-identified information confirm some personal information lifestyle activities from information or insights with our partners to assist to verify it’s actually you and not you provide us about yourself when in research, planning, or product and 5 someone trying to access your you tell us your preferences, or when service development . account without authorization; your usage activities indicate what We note that our customers who do For billing purposes, we collect your preferences are. not wish to receive these types of • records of the services you use; we recommendations or offers may choose also collect payment information to To develop, enhance, market or to be removed from our marketing lists set up pre-authorized payments, if at any time. you choose to do so; provide products and services. Some of our products and services Here are some examples of what we • invite you to provide personal mean by this: information in order to allow you From time to time, we review and to use and access that personal • analyze personal information and information as part of the functionality your use of our products and of the product or service. For services: example, for you to take advantage To help us provide tailored of our TELUS Baby Health service, • content and services, such you will be invited to enter personal as personalized product information about your baby; TELUS Consumer Health 3 | Privacy Commitment To manage and develop our To meet legal and regulatory business and operations. requirements. Here are some examples of what we Here are some examples of what we mean by this: mean by this: We may collect personal information We may collect or preserve personal • to help us manage our day-to-day • information in response to a court operations efficiently, and to plan, order; manage and secure our systems; We need to collect certain personal We analyze how many customers • information to comply with statutory • use our systems and customer obligations, including our tax usage patterns to help us make our reporting obligations.. systems more efficient. We may use video surveillance to monitor and/ or record the activity that occurs around TELUS stores, premises or infrastructure; We monitor activity on our networks • to detect and prevent fraud to protect both our customers and our business; We record interactions, such as chats • with or telephone calls to or from TELUS Health service representatives for quality assurance and training purposes; our systems may also conduct real-time analytics on such interactions to identify trends and patterns to help us serve you better; We collect information about visits • to our websites (such as www.telus. com and telushealth.com) to optimize our TELUS Health web properties, and for security purposes. TELUS Consumer Health 4 | Privacy Commitment When we share personal information We take great care with what information we share, and why. There are circumstances where we share some personal information about our customers: To facilitate and improve the Examples of what we mean by For emergency purposes. service providers or partners include provision of products and organizations that: We may share personal information services to you. with a public authority, agent of a Conduct research on our behalf, public authority or other party if, in the Here are examples of what we mean • such as customer satisfaction reasonable judgment of TELUS Health, it by this. We may share personal surveys; appears that there is imminent danger to information with: • Perform data processing on our the life, health or security of an individual • A person seeking information as behalf, such as printing customer which could be avoided or minimized by an agent of a customer, such as a statements; disclosure of the personal information. customer’s legal representative, or as Administer special TELUS Health an authorized user under his or her • programs with partners, such as a Where required by law or account, if we are satisfied that the rewards program or special contests; person is authorized to receive the applicable regulation. To provide you with an enhanced information; We share personal information with law • service as part of some of our Other TELUS business units to help enforcement, other government agencies service offerings, with your express • us serve our customers better and or other parties if we are required to consent, we may share your personal to provide them with services from do so to meet legal and regulatory information with your electronic different parts of our company. requirements; for example, if TELUS health record or with other parties, Health is required to provide records to such as your health care providers or law enforcement in response to a valid To enable our service your pharmacy. court order. providers and partners to Personal information collected by TELUS help us serve you better. For credit-related purposes. Health may be stored and processed in We may share personal information We may share personal information with Canada or another country. In either case, with our suppliers, agents or other credit bureaus: the personal information is protected organizations or individuals contracted with appropriate security safeguards, but To evaluate a customer’s to TELUS Health to perform services may be available to foreign government • creditworthiness; or functions on our behalf where they agencies under applicable law. When we require the information to assist us in • For the purposes of monthly do transfer data outside the country, we serving you. We strive to minimize the reporting on the status of your strive to minimize the amount of personal amount of personal information that payment history with TELUS Health. information that we transfer, using we share with our service providers We may share your personal information de-identification or other means where and partners; we share the information with collection agencies to collect an appropriate.