Bermuda Pharmacy Group Ltd Privacy Notice
Bermuda Pharmacy Group LTD (BPG) is committed to maintaining the accuracy, confidentiality and security of your personal information. BPG complies with Bermuda’s privacy law, the “Personal Information Protection Act,2016 (PIPA)”.
This notice sets out the basis on which we process any personal information that we collect from you, or that you provide to us. It describes how it is used, shared, and protected. It also describes the rights that you have under the PIPA.
1. WHO WE ARE AND CONTACT DETAILS
Bermuda Pharmacy Group LTD three pharmacy locations
- Par-La-Ville Pharmacy, 2 Church Street, Hamilton HM 11, 441-296-5510
- City Pharmacy, Cumberland House, Victoria Street, HM 11, 441-296-5511
- Point Finger Road Pharmacy, 16 Point Finger Road, DV 02, 441-236-2859
Email contact for all locations: bpg@pharmacy.bm
The Registered Office is located at:
Quorum, Thistle House, 4 Burnaby Street, Hamilton HM11
295-9671
2. PRIVACY OFFICER CONTACT INFORMATION:
Our Privacy Officer is here to assist with any personal information inquiries or concerns. They may be contacted at: bpg@pharmacy.bm
3. WHAT ARE YOUR RIGHTS?
We will do all we reasonably can to assist you with any issue arising from our use of your
personal information. When the PIPA comes into force on January 1, 2025, your full legal rights will consist of the following. The right:
- to information about the use of personal information
- of access to personal information
- to the rectification, blocking, erasure, and destruction of personal information
- to prevent or stop the use of personal information for advertising, marketing, and public relations.
- to prevent or stop the use of personal information that is causing or likely to cause substantial damage or distress.
In the meantime, you may contact our Privacy Officer for assistance at bpg@pharmacy.bm.
Please note that not all privacy rights are absolute rights. They may be subject to specific conditions and exemptions. You will also be required to provide proof of identity to access these rights.
We encourage you to come to us in the first instance but, to the extent that these rights apply to you from January 1, 2025, you are entitled to complain directly to the Privacy Commissioner for Bermuda at PrivCom@privacy.bm or call 1-441-543-PRIV [-7748]
4. WHAT PERSONAL INFORMATION DO WE USE?
This information may be collected from yourself, your physician, your insurance provider or a third party. We may collect and use:
- Name, DOB, address, phone number, and email address;
- Prescription information, history and allergies, prescription number, doctor’s contact information;
- Prescribed medication, refill information;
- Insurance number, insurance details and claim number, payment history;
- Credit card information, billing information and account information;
- When accessing our public website our web provider uses Google Analytics cookies that collect visitors IP addresses.
5. WE USE YOUR PERSONAL INFORMATION FOR THE FOLLOWING PURPOSES
We may collect and use your personal information in the following manner:
- To provide you with safe and accurate pharmacy services;
- To fill and refill medication requests, identify drug interactions and for other aspects associated with providing prescriptions;
- To procure specialty medication;
- To process insurance claims;
- For general administrative and business activities necessary to operate the pharmacy;
- To monitor staff performance;
- To comply with regulations and legal/compliance obligations;
- To conduct audits;
- To answer questions, resolve complaints, or grievances;
- To receive and process payment.
6. LEGAL CONDITIONS FOR USING YOUR PERSONAL INFORMATION
Under the PIPA, the lawful conditions Bermuda Pharmacy Group LTD has for using your personal information are:
- The individual has knowingly consented to the use;
- Except in relation to sensitive personal information, a reasonable person giving due weight to the sensitivity of the personal information would consider that the individual would not reasonably be expected to request that the use of his personal information should not begin or cease; and that the use does not prejudice the rights of the individual;
- An individual will be deemed to have consented to the use of his personal information for the purpose of coverage or enrollment under an insurance, trust, or similar plan if the individual has an interest in or derives a benefit from a plan;
- The use must be necessary for the performance of a contract to which the individual is a party, or with a view to entering into such a contract;
- When an individual consents to the disclosure of his personal information by an intermediary for a specified purpose, that individual will be deemed to have consented to the use of that personal information by the receiving organisation for the specified purpose;
- The use must be necessary to com ply with a provision of law that authorizes or requires such use;
- The use of the personal information is for the purpose of complying with an order made by a court, individual or body having jurisdiction over the organisation;
- The personal information was collected from, or is disclosed to a public authority which is authorized or required by a statutory provision to provide the personal information to, or collect it from, the organisation;
- The use of the personal information is necessary in order to collect a debt owed to the organisation or for the organisation to repay to the individual money owed by the organisation;
- The use of the personal information is necessary to respond to an emergency that threatens the life, health or security of an individual or the public; and
- The use of the personal information is reasonable to protect or defend the organisation in any legal proceeding.
There are additional conditions that may apply. If you have any questions regarding the personal information we collect and use, or our legal conditions for doing so, please contact our Privacy Officer at bpg@pharmacy.bm
7.SHARING OF YOUR PERSONAL INFORMATION
To provide services and meet our obligations, we may provide personal information to the following categories of individuals or organisations:
a) Our Staff
We may share your personal information with members of our staff who understand their obligation to maintain customer privacy subject to conditions of confidence. Only relevant staff are allowed access to customer personal information. We disclose only the personal information that is necessary to deliver the services you require to those staff members pertinent to the task.
b) Medical and Insurance Providers
We may share your personal information with physicians, pharmacists and others involved with the issuing of prescriptions. This can include hospitals, pharmacies and insurance providers.
c) Public Authorities, Government and Governing Bodies
We may share your personal information with public authorities to help prevent disease, assist with product recalls, report adverse reactions and suspected abuse, react to threats to health and safety, and other instances as required by public authorities and governing bodies.
d) Service Providers
We may transfer your personal information to third parties in Bermuda for the purposes of completing tasks relating to the delivery of our services, such as our IT network provider, our accountant and auditors, and banks and insurance companies. When we use third party service providers in Bermuda, we disclose only the personal information that is necessary to those organisations and individuals relevant to the task. We do not sell or rent your personal information.
e) Overseas Transfers of Personal Information
We may transfer your personal information to third parties outside Bermuda for the purposes of completing tasks relating to the delivery of our services, such as software vendors and support, or producers of specialty medication. When we use third party service providers overseas, we disclose only the personal information that is necessary to those organisations and individuals relevant to the task. When your personal information is transferred to third parties overseas, we do so with security in mind and the systems that these providers have in place to protect and secure the personal information that has been sent. We do not sell or rent your personal information.
8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We are legally required to hold some types of personal information to fulfil our statutory
obligations. We will hold your personal information only for so long as it is necessary for
the relevant activity, or for internal audit and quality control purposes. We review our retention periods for personal information on a regular basis.
9. SECURITY
The nature of our business requires the use of ‘sensitive personal information’ as defined in the PIPA. As a result, we seek to use appropriate organizational, technical, and administrative measures to protect the personal information. We monitor the security of our systems and premises, and we review our policies and procedures on a regular basis.
10. QUESTIONS
If you have any questions concerning our privacy notice or our use of your personal information, including exercising your rights detailed in Section 3, please contact the Privacy Officer at bpg@pharmacy.bm
11. CHANGES TO OUR PRIVACY NOTICE
We may revise this privacy notice at any time. Any amended privacy notice becomes effective once published.
Effective Date: January 1st 2025