What is Privacy?
Privacy is generally defined as an individual’s right to maintain control over the collection, use and disclosure of his or her Personal Information.
What is Personal Information?
Personal Information is information (data), whether it is oral, written or electronic, about an identifiable individual, or which allows the individual to be identified. Personal Information includes, but is not limited to, the following:
- A person’s name
- Their age, gender, family and marital status
- Identification numbers, such as a Social Insurance Number
- A person’s financial and employment information
- A person’s educational and employment history
- A person’s credit rating and payment records
- A person’s prior insurance and claims records
- Medical and health information
What is Not Personal Information?
The name, title, business address or business telephone number of an employee of an organization (“Business Card Information”) is not considered Personal Information. Any data that we have collected in which all the personal identifiers have been removed, which either anonymizes or aggregates Personal Information rendering it impossible to determine the identity of the person to whom it relates, is also not Personal Information.
We collect Personal Information to establish and service your needs. The types of Personal Information we collect, use or disclose vary with the products or services provided. All products and services provided by Global Benefits and its Affiliates require that we collect and use your SIN, name and home address, at a minimum, for identification purposes. Other forms of Personal Information, which may include an individual’s birth or marriage certificate, may be required to verify the individual’s identity and for account administration purposes.
When you first become a member of a group benefit plan, we collect certain of your Personal Information for the following purposes, namely to:
- Enable us to create and maintain an account for eligibility status for you;
- Assess and pay claims and pension benefits;
- Track your benefits history;
- Keep your information accurate and up-to-date; and
- Protect us both against error or fraud.
In the course of processing claims and or paying benefits we may disclose Personal Information, about you and your dependants to Drug Card Companies, Insurance Carriers or your Union, including relationship to insured, family name and date of birth.
Following is a sampling of Personal Information and the purposes for our collection, use or disclosure:
We collect your birth date to confirm your identity and your eligibility for certain products or services administered by Global Benefits.
SOCIAL INSURANCE NUMBER (SIN)
Our administration of certain benefits, such as life insurance, pension plans, and short and long term disability plans, requires that we collect and use your SIN to comply with Canada Revenue Agency’s income reporting requirements. In other circumstances, our use of your SIN is purely for administration and identification purposes. You may decline to provide us with your SIN for this latter purpose, in which case you will be assigned a member identification number. This number must be provided to your employer so that your contributions can be properly matched to your benefits. You will also be required to provide your ID number to your health care providers, including your dentist and pharmacist, in order to confirm your eligibility for coverage and to process your claims.
We collect and use certain of your financial information to assess and to confirm your employer’s remittances on your behalf and your benefit levels. We may disclose certain of your financial information to Insurance Carriers and Financial Institutions for purposes relating to insurance coverage and your participation in a plan.
Collection of certain of your health information will be required when we provide certain products and services, including, processing claims for short or long term disability and applications for additional life insurance.
We are required to disclose beneficiary information, including a beneficiary’s name and date of birth, in the case of pension plans and to disclose similar information to Insurance carriers upon payment of death benefits to a beneficiary.
Our Commitment to You
At GLOBAL BENEFITS our commitment to protecting the confidentiality and security of our clients’ Personal Information has been, and always will be, the most integral part of our corporate values.
OUR COMPLIANCE WITH THE TEN PRIVACY PRINCIPLES
2. IDENTIFYING PURPOSES
We identify the purposes for which your Personal information is collected, used or disclosed at or before the time of collection. Personal Information may be collected, used or disclosed for the following purposes:
- Providing products or services, communications and answering your inquiries.
- Processing and adjudicating your claims.
- Confirming your identity and eligibility for benefits, as well as the identity and eligibility of your beneficiaries, where applicable.
- Providing you with information for your review and confirmation, as may be legally required.
- Providing your Personal Information to third parties to process claims and services and for account administration purposes; and
- As otherwise required or prescribed by law.
Your Personal Information may be disclosed to Affiliates, other plan administrators, insurance companies, actuaries, consultants and other persons, corporations or enterprises with whom Global Benefits enters into agreements for the purposes of determining eligibility, entitlement to pension benefits and entitlement to claims.
We will obtain your consent before disclosing your Personal Information, unless otherwise required or prescribed by law. Your medical and health information will only be disclosed with your consent for the purposes of determining your:
(i) eligibility status,
(ii) entitlement to benefits, and (iii) considering appeals.
Global Benefits does not sell, trade or rent its clients’ Personal Information to any organization for any purpose.
In order to provide you with benefits as plan participant/member, you may be required to provide us with additional personal information from time to time. Your informed consent to such collection, use or disclosure will always be obtained in accordance with this Policy.Â You always have the right to choose whether to provide us with some or all of your Personal Information. However, by withholding or withdrawing your consent you may, in certain circumstances, prevent us, in whole or in part, from processing your benefits or otherwise continuing to provide you with products and services. Please contact the individual identified at the end of this Policy if you have questions or comments or wish to withdraw your consent to our collection, use or disclosure of your Personal Information.
4. LIMITING COLLECTION
We limit the collection of your Personal Information to that which is necessary for the purposes identified. In certain circumstances, we may obtain Personal Information either from you, insurance companies, financial institutions, medical professionals, employers and local unions.
5. LIMITING USE, DISCLOSURE AND RETENTION
We will only use your Personal Information for the purposes for which it was collected, or as otherwise required or permitted by law. Your Personal Information will only be retained for the time necessary to fulfill the purposes for which it was collected and to meet any applicable legal or regulatory requirements.
We will keep your Personal Information as accurate, complete and up-to-date as possible to fulfill the purposes for which it is collected and used. You can assist us in ensuring your records are current by providing us with any changes to your Personal Information. You have the right to challenge the accuracy and completeness of your Personal Information and amend it as necessary. You may do so by contacting the Privacy Officer at the address provided below.
We protect the Personal Information we collect from you with security safeguards that meet or exceed industry standards. Unencrypted, electronically transmitted information is not 100% secure. Therefore, we cannot guarantee the security of any information you transmit to us electronically or that you request us to transmit to you via the public Internet.
Our security systems and procedures are designed to prevent loss, misuse, unauthorized access, disclosure, alteration or destruction of your Personal Information. Only authorized Global Benefits employees and our trusted service providers have access to your Personal Information. Our external suppliers and service providers are contractually required to protect your personal information with appropriate security safeguards.
Information about our policies and practices relating to our management of your Personal Information is available by contacting our Privacy Officer at the address noted below.
9. ACCESSING YOUR PERSONAL INFORMATION
Global Benefits will provide you with access to your Personal Information upon request, subject to applicable legal and business restrictions. For more information on how to access Personal Information collected about you by Global Benefits please contact the Privacy Officer at the address below.
10. CHALLENGING COMPLIANCE
88 St Regis Crescent South, Toronto, ON M3J 1Y8