Privacy policy
In some cases, we can provide you with additional information about the processing of your Personal Information when collecting it.
We may also obtain your specific consent in certain circumstances to the collection, use, disclosure, and retention of your Personal Information.
This Policy applies to Personal Information collected by us in any manner, including in person, by telephone, by videoconference, or through our website.
By accepting this Policy or by providing us with Personal Information after having had the opportunity to review the Policy, or any additional notice, you consent to the processing of your Personal Information in accordance with the Policy and any additional notice, if applicable.
1. About Us
Below is our contact information:
Larivière et Massicotte, pharmaciennes inc.
8296 Pie-IX Blvd.
Montreal, Quebec, H1Z 4E8, Canada
You may contact our Privacy Officer with any questions or feedback you may have regarding this Policy, how we handle Personal Information, or to exercise your rights regarding your Personal Information.
You can reach our Privacy Team in two (2) ways:
By email: prp@expertiselmp.com; and
By mail: Christine Larivière – Privacy Officer, 8296, Boul. Pie IX, Mtl, PQ, H1Z 4E8
LMP is a pharmacy specializing in several therapeutic fields, notably oncology, cystic fibrosis, hepatitis, multiple sclerosis, and rheumatoid arthritis. The pharmacy also carries a range of specialty products. Pharmacists and pharmacy technicians work closely with the healthcare professionals of the community pharmacy or hospital to provide services for the delivery and administration of specialized therapeutic treatments. The pharmacy enables access to rare medications, offers personalized advice and planning for treatment, handles reimbursements with insurance companies and the Régie de l’Assurance Maladie du Quebec (RAMQ), coordinates pharmacological records with the family pharmacist, and monitors and interprets laboratory results as well as telephone follow-ups to monitor treatment efficacy and anticipate the management of possible side effects.
We also train and raise awareness among staff members and all healthcare professionals involved, particularly through activities and training, and by implementing practices and policies. We ensure that employees and other stakeholders are aware of these policies and practices. Furthermore, we ensure that they strictly adhere to these policies and practices in their duties and functions.
We are required to comply with the professional and ethical obligations of pharmacists regarding record keeping and disclosure of Personal Information.
All our employees who use Personal Information are bound by confidentiality agreements. In addition, they may only have access to Personal Information necessary for the execution of their respective duties. Our governance practices provide for sanctions in the event of non-compliance.
2. Definitions
For the purpose of the Policy and any other document resulting from or related to it, the following words and expressions have the meaning indicated below, unless otherwise indicated:
2.1 “Privacy Incident” means (i) unauthorized access by law to Personal Information; (ii) unauthorized use by law of Personal Information; (iii) unauthorized disclosure by law of Personal Information; or (iv) loss of or other breach of Personal Information;
2.2 “Personal Information” means information that can be used to identify a physical person, such as first name, last name, and address, as well as any information that may be stored in the computer systems used by LMP as a result of the functionalities offered by LMP.
3. Collection of Personal Information
Personal Information is collected only in cases of serious and legitimate purpose and when the purposes for collecting said information are justified prior to collection. The collection of Personal Information is limited to what is necessary for the purposes identified. When in doubt, Personal Information is deemed unnecessary. Information is collected through lawful and legitimate methods. With few exceptions, information is collected from the person concerned. LMP obtains the consent of the person concerned before collecting their personal information from a third party, unless otherwise stipulated by law.
Certain Personal Information may be collected by LMP through various verbal interactions with pharmacists and other LMP employees, over the phone or in person, as well as through the LMP website.
We also receive Personal Information from family pharmacies and patient laboratory test results, as described below. In all such cases, the transmission of such Personal Information and your consent to it is governed by the policies applicable to those transmitting it to us.
LMP uses UbikTM, a unified technological platform from TELUS HEALTH SOLUTIONS INC., to operate and manage its pharmacy (hereinafter the “Platform“), notably to collect, host, and process Personal Patient Information. In addition, the Platform makes it possible to access and transmit information to the Quebec Government’s Quebec Health Record and the RAMQ, as required by law.
Some of our historical records are hosted on a local platform using Kroll software.
3.1 List of Personal Information That May Be Collected
- Your first and last name
- Your email address
- Your phone number
- Your home address
- Your health insurance number (RAMQ)
- Your private insurance policy number
- Your payment information
- Login indicator (see below)
- Medical and pharmacological information required to provide LMP services
- Names and contact information of resource persons and caregivers
3.2 Access to and Disclosure of Personal Information to Third Parties
- Health professionals involved
- LMP employees, provided they need to know such information
- Our suppliers and subcontractors, as described in section 6 of the Policy
Purposes of Collecting Personal Information
Patient file – We use Personal Information to share patient files between the various parties involved through a technological platform. A patient file contains, among other things, the Personal Information required to identify a patient, relevant data from laboratory tests, and an overview of the patient’s pharmacological profile and habits. This use of Personal Information enables LMP to provide effective medical follow-up. Healthcare professionals can also add medical notes to a patient file. Various laboratories also collect Personal Information needed to analyze tests and share related results with other stakeholders and with the patient. Personal information is used to file claims with insurance companies and the RAMQ.
Referral services – The referral process enables various treating professionals to recommend patients who require specialized treatment. These referrals may come from community pharmacists or from professionals on the patient’s hospital healthcare team. The latter must offer LMP’s services using the discussion tool available on the pharmacy’s website, and must obtain the patient’s consent to share their information with LMP. Information about the patient file, the prescription, and the referral form is sent online or by fax. Once the referral form and prescription have been received, the pharmacy contacts the patient to gather further personal information about their profile and habits (pillbox, treatment habits, etc.).
Medication delivery service – The delivery service ensures rapid access to rare and expensive medications in less than 24 hours through province-wide shipping. We use patients’ Personal Information to schedule medication deliveries, which can be sent to the address on file or another location of the patient’s choice by recognized carriers.
Phone assistance – The pharmacy has fifteen direct phone lines. This service may require sharing and exchanging Personal Information required to identify a patient and to ensure the authenticity of that identification.
Personalized assistance with claims – LMP’s Exceptional Patient and Medication Reimbursement Coordination Service is intended to facilitate the processing of patient claims with insurance companies and the RAMQ. To carry out these procedures, Personal Information is collected and exchanged in order to complete claim forms.
Therapy monitoring – LMP healthcare professionals may collect Personal Information in accordance with and for the purposes stipulated in their Code of Ethics as part of follow-ups to monitor treatment effectiveness and manage potential complications.
Ensuring patient identification – We also use Personal Information required to identify a patient during our interactions with that patient and to ensure the authenticity of the identification in order to consult and discuss the patient file.
Ensuring the quality of our services – We also reserve the right to use the Personal Information we collect to monitor the quality of our services and improve your experience.
Participation in research or studies – Patients must provide verbal consent in order to take part in a study. Potentially eligible patients who have been identified from the pharmaceutical database are contacted over the phone by a pharmacist. A description of the research project is provided, and consent is requested to use information from patients’ pharmaceutical files for research purposes.
4. Retention of Personal Information
Access to patients’ Personal Information is limited to authorized persons within the pharmacy when such information is necessary to perform their duties.
4.1 Duration of Personal Information Retention
We will destroy your Personal Information when the purpose for which it was collected or used has been achieved, subject to any retention periods required by law. To this end, we retain the Personal Information required to comply with applicable laws governing the retention of medical records, including the Act respecting the sharing of certain health information, the Regulation respecting the preservation, use, or destruction of the records, books, and registers of a pharmacist who ceases to practice, and the Regulation respecting the keeping of records, books, and registers by a pharmacist in the practice of their profession.
4.2 Retention and Storage of Personal Information
The Personal Information required to provide our services on the Platform is hosted on TELUS HEALTH INC. servers. Data that does not travel through the Platform is hosted on SOLUTIONS ITED INC. servers. In addition, the Platform enables access to, and transfer of, information required by the Quebec Government’s Quebec Health Record and the RAMQ.
Prescriptions and patient file elements in paper format are kept at LMP or stored at IRON MOUNTAIN INC.
5. Disclosure of Personal Information
LMP does not sell its patients’ Personal Information to any other organization or individual. In some cases, the pharmacy may disclose and communicate a patient’s Personal Information to third parties or to specific suppliers and partners, without the patient’s knowledge or consent, where permitted by law.
5.1 Disclosure of Personal Information to Insurers
At a patient’s request or with their consent, LMP may communicate the Personal Information required to allow reimbursements by insurance companies and the RAMQ.
5.2 Disclosure of Personal Information to Family Pharmacists
At a patient’s request or with their consent, LMP may communicate the Personal Information required to coordinate pharmacological records with a patient’s family pharmacist.
5.3 Disclosure of Personal Information for Public Safety or Law Enforcement Purposes
When there is a grave risk of death or serious injury – We may disclose Personal Information we hold in order to protect a person or group of people when there is reasonable cause to believe there is a grave risk of death or serious injury to that person or group, for example as a result of a disappearance or an act of violence, including an attempted suicide, and the nature of the threat inspires a sense of urgency.
The information may then be communicated to the person or persons at risk, to their representative, or to any person likely to come to their help. Only the information necessary for the purposes of the communication will be disclosed.
Law enforcement – We may also disclose information to the Directeur des poursuites criminelles et pénales or to a person or group responsible for preventing, detecting, or punishing crime or statutory offences when the information is necessary for the purposes of prosecuting an offence under a law applicable in Quebec.
Finally, we may disclose information to a police force in accordance with the law.
5.4 Disclosure of Personal Information for Research Purposes
We may also collect, use, and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your Personal Information, but is not considered personal data legally, as such data does not directly or indirectly reveal your identity. For example, we may aggregate your data to carry out a study as described in article 3 of the Policy. However, if we combine or match the aggregated data with your personal data in such a way that it can identify you directly or indirectly, we will treat the combined data as Personal Information, which will be used in accordance with this Privacy Policy.
6. Suppliers and Technological Products Used
Various third parties are used to operate the Platform (collectively the “Platform Third-Party Contractors“).
6.1 LMP Suppliers
TELUS HEALTH SOLUTIONS INC. – Platform services
The Platform is the technological tool used by LMP to operate and manage the pharmacy. Your Personal Information as a patient of our pharmacy is transferred and processed by this company through the Platform.
LOGIENT INC. – computer services and web development
LMP employs the services of this company to develop and support our company’s technological tools, as well as the development and operation of the LMP website.
SOLUTIONS ITED INC. – IT management service
LMP uses the services of this company to manage and host its servers.
IRON MOUNTAIN INC. – prescription storage service
LMP contracts this company to store information relating to patients’ paper prescriptions.
GLOBAL PAYMENTS INC. (“GLOBALPAYMENTS“) – payment and financial services
GLOBALPAYMENTS services are used during transactions carried out in the LMP pharmacy (physical terminals). The Personal Information collected consists of the last four (4) digits of the card used for payment, the card brand and/or issuing bank, and the cardholder’s name. The employees who have access to this information are limited to LMP’s technical assistants, members of the management team, and external accountants.
6.2 Other Services Used by LMP
Transporting medications between the pharmacy and patients – A number of medications are delivered from the LMP pharmacy to patients. The information used to identify orders includes the patient’s first and last name, telephone number, and home address.
Fax – LMP may transmit and receive faxes, particularly in order to get laboratory results for tests performed on an LMP patient, and as part of the referral process. LMP employees may receive the information transferred by fax, which includes last name, first name, Quebec health insurance number, and test results.
7. Governance, Security Measures, and Inherent Risks
We have implemented various measures to protect the sensitivity of Personal Information and its use. We follow industry security standards to protect the Personal Information we collect and receive.
More specifically, we have put in place appropriate physical, technical, IT, and administrative safeguards to protect your Personal Information against a Privacy Incident.
8. Your Consent
By using the LMP website, you consent to the collection, use, disclosure, and retention of your Personal Information in accordance with this policy.
If you do not consent, please discontinue use of the website. Except where otherwise provided by law, you may withdraw your consent at any time upon reasonable notice.
Please note that if you choose to withdraw your consent to the collection, use, or disclosure of your Personal Information, certain features of the website or services provided by LMP may no longer be available to you. In addition, your Personal Information will be retained despite the withdrawal of your consent to the extent required to comply with our professional record-keeping obligations.
9. Transfer of Personal Information Outside Quebec
Your Personal Information is stored and processed in Quebec, Canada. Our practices regarding your personal information remain at all times governed by this policy and applicable Quebec laws.
10. Your Rights Regarding Your Personal Information
By law, you have various rights regarding your Personal Information. In particular, you are entitled to:
- Access: The right to ask whether we hold any Personal Information about you and, if so, to request access to it.
- Transferability: The right to request access to your Personal Information in a structured technological format and request that it be communicated to a third party, with certain exceptions.
- Correction: The right to request correction of any incomplete or inaccurate Personal Information in our possession.
- Withdrawal of consent: The right to withdraw your consent to the disclosure or use of Personal Information in our possession.
- Restrict or deny access: The right to request that a specific stakeholder or stakeholder category not have access to one or more pieces of information you have indicated.
- Complaint: The right to file a complaint with our Privacy Officer as identified in article 1 of the Policy in relation to this Policy, or to file a complaint with the Commission de l’accès à l’information du Quebec if you believe that a breach of privacy laws has been committed. To file a complaint with the Commission d’accès à l’information (Quebec), please use the appropriate form available at the following address: For citizens | Commission d’accès à l’information du Quebec (gouv.qc.ca)
- Transferability: The right to request that your Personal Information be communicated to you, or that it be transferred to another organization in a structured and commonly used technological format.
To exercise any of these rights, please contact our Privacy Officer as indicated in article 1 of the Policy.
11. Use of Navigation Cookies
We do not use any information provided by your server on the Platform, nor do we collect any unless you subscribe to our newsletter or send a message via the contact form.
The cookies we use include the following file types:
- Essential cookies: These cookies are necessary for the operation and navigation of our website and cannot be deactivated. Cookies may be used to ensure the smooth operation of our website, to improve the security of our website, or to comply with our legal obligations.
- Analytical cookies: These cookies enable us to monitor how you use our website. Information collected through cookies may include, but is not limited to, the pages you view, open and exit, time and date, number of clicks, page scrolling, and the type of computer system you are using. The search terms you use and your device’s IP address may also be collected. If you disable these cookies, you may not be able to navigate certain parts of the website or access certain features.
- Preference cookies: These cookies are used to improve and personalize the functionalities of a website and the content provided to you, based on your previous navigation and choices. If you disable these cookies, you may not be able to navigate certain parts of the website or use certain features. In addition, our website will not be able to track your preferences, such as language preference, from one visit to the next.
- Advertising cookies: These cookies may be used both by our advertising partners and ourselves to profile your interests. These cookies collect information about your browsing habits and interests. They may be used to limit the number of times you see an ad, to help us evaluate the effectiveness of our advertising campaigns, to conduct market research, and to tailor ads to your interests.
When you access our website or mobile application, you will see a banner notifying you of the cookies we use. You will be able to disable certain types of cookies at this point, but you will not be able to disable essential cookies.
You can change your cookie choices at any time by configuring your device preferences or by redisplaying the consent banner: Cookie settings.
12. Third-party Websites (External Websites)
Our website contains references to external websites which are operated by third parties. This Policy does not apply to third-party websites, pages, or applications that may be accessed through our services. We are not responsible for such third-party services.
If you follow any such links, these third-party websites or services will presumably have their own privacy policies, which you should review before submitting any Personal Information.
13. Policy Update
We may modify the Policy as required to reflect changes in our business practices or in the law.
Date of last update: November 20th, 2023.