Last Updated: October 2011
Janssen Pharmaceuticals, Inc. (“Janssen”, “we”, “us” or “our”) recognizes our responsibility to protect personal information in our custody or control. “Personal information” is information about an identifiable individual, such as your name, address, email address, phone number, health information, and comments or inquires you have made about our products or services when such comments or inquiries are linked to you.
Personal Information Collection
Janssen and its agents and representatives collect personal information in a number of circumstances, including when you provide it to us voluntarily or in other circumstances with your consent or as permitted or required by law. For example, we may collect your personal information when you:
- request information;
- inquire or provide comments about our products and services;
- participate in advisory boards;
- participate in clinical trials;
- participate in contests or other promotions;
- fill out questionnaires or surveys;
- participate in social media, or post information on bulletins or on our websites;
- submit your resume or other personal information in connection with employment possibilities with us; or
- otherwise provide your personal information to us, including by telephone, mail, email, facsimile or through any of our websites.
The information we may collect includes:
- personal and business contact information, such as name, title, address, telephone number and email address;
- information that our sales representatives may collect during their visits with physicians and other health care professionals with whom they deal, for instance title, qualifications, areas of practice or specialization, their questions or comments about our products, and related information about health care professionals and their administrators relevant to maintaining and managing our relationship with such persons;
- names and other contact details of patients who use our products and their physicians and, in certain circumstances, sensitive health information, and patient medical history, for example, where we have received a report of an adverse event, where we are providing patient-specific assistance with respect to the use or reimbursement of our products, or where we are assisting in or co-coordinating product recalls;
- information collected in connection with inquiries or comments made by individuals who contact our Medical Information representatives;
- names and other contact details of physicians participating in advisory boards and the opinions or comments expressed by those physicians during advisory board meetings;
- names and other contact details of physicians involved in running clinical trials, together with their professional information such as curriculum vitae and other information that is required to be reported to Health Canada and other regulatory bodies;
- information such as name, age, and gender of patients participating in clinical trials together with the clinical data collected in the course of the clinical trials. Janssen generally receives patients' clinical data that has been recorded using identifiers other than the patients' full name, such as the patients' initials. More comprehensive patient data, including full names, may be reviewed by our clinical site managers when they attend at the trial site for compliance monitoring;
- information from individuals visiting our premises such as their name and the name of the organization for which they work or which they represent. We may also post video cameras in public-access areas on our premises; and
- other information with your consent or as permitted or required by law
Calls to and from Janssen may be recorded and/or monitored for quality and training purposes. Recordings may also be used to help us develop and improve our products and services. Information may also be actively and passively collected by our websites. See Our Websites below for details.
Janssen collects personal information for a variety of purposes relating to the operation of our business and the delivery of services to you, including to:
- provide our products and services and generally manage and administer our business including maintaining business records for reasonable periods and defending and bringing legal actions;
- develop and improve our products;
- provide you with health and product-related information;
- reply to your requests, inquiries and comments;
- receive and assess product inquiries, reports of adverse events, and product complaints;
- assist in or co-ordinate product recalls;
- establish and maintain our relationship with health care professionals and administrators and other individuals with whom we have contact in the course of our business;
- provide assistance and advice to health care professionals and institutions with respect to our products;
- test and analyze our products for efficacy and safety;
- meet legal, regulatory, insurance, security, ethical and processing requirements such as adverse event and clinical reporting to Health Canada and regulatory bodies;
- monitor compliance with informed consent requirements when patients participate in clinical trials, and verify that clinical data collected by Janssen in the course of the clinical trial conforms to the source data available at the site of the clinical trial;
- use feedback provided to us in the course of advisory board meetings to develop the strategic positioning of our products;
- manage, administer, collect and enforce accounts;
- provide remuneration to individuals who have performed services for Janssen;
- enable us to act responsibly in the event of a health or other crisis or emergency and to enhance workplace security;
- evaluate resumes or other personal information submitted to us in connection with employment possibilities. For candidates who are not offered or do not accept a position, we may retain their information in the event that an appropriate position becomes available or that they re-apply to Janssen;
- offer and administer contests, promotions, surveys and websites including social media;
- ensure the security and integrity of our websites and operations.
We may also use your personal information for other purposes with your consent or as permitted or required by law.
Use of Service Providers
Janssen may disclose your personal information in the following circumstances:
We may disclose personal information when required in order to meet legal, regulatory, industry self-regulatory, insurance, audit, security or ethical requirements, including obligations to health and drug regulatory and self-regulatory bodies, physicians, hospitals, or other health care facilities.
We also may disclose your personal information to third parties, located in Canada and/or any other country, where required or permitted by applicable laws, court orders, or government regulations (including as required by Canadian and foreign laws applicable to Janssen or our agents and service providers).
We may also disclose your personal information with your consent.
There are instances where we may be permitted or required by law to collect, use or disclose your personal information without your consent including, for example, to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information. Janssen will take appropriate steps to ensure that personal information about you is protected from loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
Access, Correction and Contacting Us
You may contact us as described below in order to:
- request to withdraw your consent to our retention, use or disclosure of your personal information; and/or
- request access to or correction of your personal information.
Requests regarding items 3 and 4 above must be made in writing. We will take reasonable steps to verify your identity before granting access or making corrections.
You may contact us by:
writing to us at the following address:
Attention: Chief Privacy Officer
19 Green Belt Drive
Toronto, Ontario M3C 1L9
- faxing us at 416-449-2658, attention Chief Privacy Officer, Janssen Inc.; or
- emailing us at email@example.com.
NOTE: If you are a physician or other health care professional and have questions or comments regarding our products, please contact our Medical Information Group at 1-800-567-3331.
Active Information Collection
Our websites may actively collect information from visitors both by asking you specific questions and by permitting you to communicate directly with us via email and/or feedback forms. Some of the information that you submit on our web sites may be personal information.
Passive Information Collection
Our websites may use and combine such passively collected anonymous information to provide better service to site visitors, customize the sites based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the sites for your use. Such information is not combined with personal information actively collected on our web sites unless you have consented.
The following is a description of cookies and other passive tracking methods.
A “cookie” is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences.
“Session” cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate and collect aggregate statistical information on the site. They are erased once you exit your web browser or otherwise turn off your computer.
“Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the website visitors find most valuable, and customizing the website based on your preferences on an ongoing basis.
IP Addresses and Tags
A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider. In most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.
“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the website server information such as the IP address and browser type related to the visitor’s computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted.
“Navigational data” (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, for market research purposes, and to communicate information to visitors.