of Privacy Principles
is committed to compliance with Canada’s Personal Information Protection and
Electronic Documents Act (“PIPEDA”) as outlined in the following Statement of
Statement of Privacy Principles describes the purposes for which Medtronic is
processing your personal information, how Medtronic processes and protects
personal information, and how you may access personal information that Medtronic
may have about you. Preservation of, and respect for, our customers’, business
colleagues’ and vendors’, and patients’ trust is critical to our continued
success. We will always process personal information:
Confidentially and fairly
Appropriately, according to the statements we make
Lawfully, in accordance with applicable privacy laws, regulations and principles
name we use to refer to our whole business, including Medtronic, Inc., a
corporation based in the United States of America, and any of the companies that
it controls such as its subsidiaries and affiliates. When we use the words we
or our, we mean Medtronic.
these Privacy Principles apply?
Privacy Principles apply when we process any personal information. These
Privacy Principles apply to data when we collect it directly from the person who
the data identifies, and also when we collect data from one person (or company)
that identifies another person. Therefore, when we use the word
in this Statement of Privacy Principles, we mean the individual whose personal
information we are processing, whether we collect that information directly from
the individual or indirectly from someone else.
Statement of Privacy Principles does not apply when we process information:
our employees in the scope of their employment relationship with us
indicating that this Statement of Privacy Principles does not apply, or that a
different policy or notice does apply that does not identify you as an
individual person, including to personal information (which we define below)
that we have de-identified, so that it no longer can be used to identify you.
is any set of operations involving personal information, whether or not by
automatic means, including collecting, using, disclosing, adapting, altering,
correcting, retrieving, combining, blocking, erasing, transferring, destroying,
recording, organizing, storing, and using personal information. When we use the
word “process” or “processing” in this Statement of Privacy Principles, we mean
any of these types of operations.
is information about an identifiable individual such as your:
insurance number or other national identifier
other information that identifies or could identify you and relates to you
how does Medtronic collect personal information?
Medtronic may collect personal information in a variety of ways. For example:
collect personal information about you in compliance with laws and regulations.
some places on our web sites you have the opportunity to send us personal
information about yourself. For example, you may fill out a registration form,
a survey or an e-mail form. You also may choose to allow us to personalize your
visits to the web sites, in which case we will ask you for certain personal
information to make your visits to our web sites more helpful to you. When this
information is combined with the non-personal information that we collect
through cookies, we will be able to tell that you have visited our web sites
collect personal information from you when you contact us for information,
products, or services.
collect personal information about you in the course of engaging in commercial
transactions with our customers, vendors, and other business contacts.
purposes does Medtronic collect and process personal information?
process your personal information for the following purposes:
provide patients with therapy or technical support for our products or services
respond to your requests and enquiries
perform a contract or for contract negotiations with or about you
develop records, including records of your personal information
contact you by mail (or in other ways with your permission) with information
that might be of interest to you, including information about clinical trials
and about products and services of ours and of others
analytical purposes and to research, develop and improve programs, products,
therapies, services and content
remove your personal identifiers (your name, e-mail address, social insurance
number, etc). In this case, you would no longer be identified as a single
unique individual. Once we have de-identified information, it is non-personal
information and is not subject to this Statement of Privacy Principles
personalize your access to our web sites, for example, by telling you about new
features that may be of interest to you
enforce this Statement of Privacy Principles and otherwise protect our rights or
protect your vital interests or someone else’s health, safety or welfare
comply with a law or regulation, court order or other legal obligation (for
example as required by Health Canada, the U.S. Food and Drug Administration,
European, and other governmental authorities to assure safe and effective use of
our products and services)
our other legitimate interests, unless such processing will unfairly prejudice
your rights or freedoms
other ways to which you consent
Medtronic ever use personal information to contact me with marketing messages?
contact you periodically in person, by e-mail, by fax, by mail, or by telephone
to provide information regarding programs, products, services and content that
may be of interest to you, unless you advise us that you do not wish to receive
marketing or market research communications from us. If applicable law requires
that we receive your explicit consent to send you certain types of marketing
communications, we will only send you those types of communications after
receiving your explicit consent.
What if I
no longer wish to receive marketing messages from Medtronic?
wish to stop receiving marketing or market research communications from us, or
would like us to stop processing your personal information in any other way, you
can contact us as described at the bottom of this Statement to let us know what
types of communications you wish to stop receiving. In addition, if you have
received, or in the future receive, an email from us, each email we send
includes an easy, automated way for you to cease receiving emails from us.
Medtronic ever share personal information with third parties?
Medtronic will not share your personal information with an unrelated third party
without your permission, except as otherwise provided in this Statement of
ordinary course of business, we will share some personal information with
companies that we hire to perform services or functions on our behalf. For
example, we may use different vendors or suppliers to ship our products.In these
cases, we provide the vendor or supplier with information to process your order
such as your name and mailing address. In all cases in which we share your
personal information with a third party, we will not authorize them to keep,
disclose or use your information with others except for the purpose of providing
the services we asked them to provide. We will obligate third parties receiving
personal information to comply with the privacy principles of this document.
will not sell, exchange or publish your personal information, except in
conjunction with a corporate sale, merger, dissolution, or acquisition.
be legally compelled to release your personal information in response to a court
order, subpoena, search warrant, law or regulation. We may cooperate with law
enforcement authorities in investigating and prosecuting web sites visitors who
violate our rules or engage in behavior, which is harmful to other visitors (or
disclose your personal information to third parties if we feel that the
disclosure is necessary to:
enforce this Statement of Privacy Principles
protect our rights or property
protect someone’s health, safety or welfare
with a law or regulation, court order or other legal process
Medtronic ever transfer personal information about me to countries other than
the country where I am located?
Medtronic may transfer information out of the province or country in which it
was collected. However, Medtronic will only transfer such information in the
transfer is necessary for the performance of a contract between you and
Medtronic or for pre-contractual measures taken in response to your request; or
consent to the transfer; or
data will be adequately protected in the other province or country, by contract
or other protection
Medtronic has arrangements with all of its offices and affiliates that assure
that personal information transferred among Medtronic companies is adequately
protected, including transfers of personal information (which may include
sensitive information) to Medtronic companies in the United States of America.
privacy legislation and changes to this Statement of Privacy Principles
Currently, there are a number of provincial privacy laws which may apply to
information held by Medtronic, in addition to PIPEDA. Other provinces may enact
legislation in the near future. Medtronic is committed to meeting the highest
standards of information privacy required by these provincial statutes, codes
and policies. As a result of legislative changes, or for other reasons,
Medtronic may need to make significant changes to this Statement of Privacy
Principles. If such a change is made, Medtronic will post a notice on the
homepage of our web sites for a period of time after the change is made. We will
also describe any major changes in this section of the Statement.
the security of personal information?
Medtronic takes full responsibility for the management and confidentiality of
the personal information under its control, whether this personal information is
held within the Medtronic organization or transferred to a third party for
processing. Medtronic has appointed a Privacy Officer that is accountable for
Medtronic’s compliance with PIPEDA and other applicable privacy legislation. We
use reasonable physical, administrative, and technical safeguards to protect
your personal information from loss, misuse, and unauthorized access,
disclosure, alteration, or destruction. We also restrict access to your
personal information to those employees and contractors who need to know that
information to do their jobs. You should keep in mind that no Internet
transmission is ever 100% secure or error-free. In particular, e-mail sent to
or from us may not be secure, and you should therefore take special care in
deciding what information you send to us via e-mail.
will Medtronic maintain my personal information?
will not keep information for any longer than is required. In many cases,
personal information must be kept for considerable periods of time in order to
make it available as and when questions or disputes arise. Retention periods
will be determined for each personal information that is collected, bearing in
mind the requirements applicable to the situation and the need to destroy
outdated, unused information at the earliest reasonable opportunity. We will
continue to treat your personal information in accordance with this Statement of
Privacy Principles so long as we retain it.
any additional privacy principles relating to Medtronic web sites?
Our web sites may contain links to other web sites. Some of those web sites may
be operated by Medtronic, and some may be operated by third parties. We provide
the links for your convenience, but we do not review, control, or monitor the
privacy practices of web sites operated by others. This Statement of Privacy
Principles does not apply to any other web sites, even the other Medtronic web
sites. We are not responsible for the performance of web sites operated by
third parties or for your business dealings with them. Therefore, whenever you
leave our web sites we recommend that you review each web site’s privacy
practices and make your own conclusions regarding the adequacy of these
the browser files of your computer when you visit. The cookies may be stored on
your computer’s hard drive. The information that we collect using cookies is
non-personal information. You are always free to decline our cookies if your
browser permits, but some parts of our web sites may not work properly for you
if you do so. We will not allow third parties to place cookies on our web
strive to keep our records of your information accurate. If you want access to
your personal information that Medtronic maintains, notice that your information
is not complete, accurate or current, or if you have questions or comments about
this Statement of Privacy Principles, please contact us:
Medtronic of Canada Ltd.
Kitimat Road, Mississauga, Ontario L5N 1W3
Telephone #(905) 826-6020 or 1-800-268-5346