Protecting Your Privacy
Benefits By Design Inc. (“BBD”, “we”, “our” or “us”) is committed to protecting your privacy and the confidentiality of your personal information. This policy sets out our responsibilities regarding the collection, use and disclosure of your personal information.
Personal information is information about you as an identifiable individual and may include such information as your age, contact information, marital status, citizenship, employment history, identification numbers and similar information for your dependents and beneficiaries under your employment benefits. Protecting this information is one of our highest priorities and we have instituted this Policy and its underlying procedures to protect your privacy and the confidentiality of your personal information.
Our ability to administer your benefits requires us to keep comprehensive knowledge about your personal information. Managing this information in a professional and secure manner is key to the successful operation of your benefits.
What personal information do we collect?
We obtain most of your personal information directly from you. However, we may need to collect information from other sources. We will only collect information pertinent to the appropriate purpose. The personal information we collect includes:
- Name, address, email address and telephone number
- Birth date, gender, marital status
- Citizenship status
- Medical and health information
- Employment information
- Previous or additional insurance and claims history
- Banking information
- Identification numbers
- Similar information regarding your dependents and beneficiaries under your employee benefits
- Such other information we may collect with your consent or as permitted or required by law
We may also collect non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as statistical or aggregated information, for example, to calculate industry trends.
How do we collect your information?
a) Directly from you: We primarily collect information directly from you when you complete an employee enrollment form and other forms filled out in person or through email or online.
b) Other sources: We may also collect information from you from the following sources:
- Your continued interaction with us, such as payment history or claims processing
- Your employer
- Your employer’s insurance advisor
- Insurers and other insurance and employee benefit intermediaries and service providers that provide services to us
- Government, industry and other entities authorized by law that have information on your claims history
- Consumer reporting agencies
- Reputable, third party market research agencies who conduct customer and claims satisfaction surveys on our behalf
c) Automated information collection: We collect some information automatically when you visit our websites. This may include information such as the type of Internet browser or computer operating system you are using, your IP address, and the domain name of the website from which you linked to our website.
How do we use your information?
Collecting personal information about you is essential to our ability to administer your benefit programs and to provide you with ongoing service. We use personal information and other information we collect from you for the following purposes:
- Establish your identity
- Communicate with you
- Administer your benefit coverage
- Substantiate and adjudicate claims under your benefit coverage
- Assist with the paperwork to process claims under your benefits coverage
- Understand and assess your eligibility for products and services
- Offer personal benefit options
- Facilitate payment of your premiums through credit card or through bank, payroll, or pension deductions
- Protect you and us from error, fraud, and illegal activity
- Ensure quality assurance
- Develop, enhance, market and provide products and services
- Analyze business results
- Meet regulatory and contractual requirements relating to your benefits coverage and related services provided to you
- Compile statistics and conduct market research
- Comply with the law or requests of regulators
- We also use automatically-collected information to improve our website
- Your personal information may also be collected, used or disclosed for other purposes with your consent or as permitted or required by law
With whom do we share information about you?
We may share information with the following:
- Insurance Advisors
- Insurers and other insurance and employee benefit intermediaries and service providers, actuaries and agents who perform services on our behalf
- Any person authorized by you
- Any person required or permitted by law to have access to your personal information
- Any person as is necessary to meet our legal, regulatory, insurance, audit, processing and security requirements or to protect our reasonable business interests
- Professionals, such as lawyers, doctors or adjusters working with or retained by us
- Industry data collection agencies for the purpose of analyzing business results
When we share personal information with third parties, we provide only that information that is required in the circumstances and we take reasonable contractual or other measures to protect your personal information. We also attempt to eliminate any references that allow identification of individuals.
If you ask, we will let you know the names of third parties who we have shared personal information with in order to administer your benefits coverage.
We may transfer personal information to insurers and other insurance and employee benefit intermediaries and service providers who perform services on our behalf. Such insurers, intermediaries and service providers may process and/or store some or all of your personal information in jurisdictions outside of Canada, including the United States. Personal information processed and/or stored outside of Canada will be subject to the laws of the country in which it is stored. We take reasonable contractual or other measures to protect your personal information while processed or handled by our service providers.
How may you give your consent?
We obtain your express consent in writing to the use of your information at the time when you complete your employee enrollment form.
In addition, where permitted by law, your consent may be implied through an action you’ve taken or when you continue to use a product or service after we’ve notified you of a change with respect to your personal information and you have not withdrawn your consent, such as by using an “opt out” option provided, if any.
We will seek your express consent if it is needed for a specific purpose, such as direct marketing for personal benefits. Also, we will only offer personal benefits to you through direct marketing if your employer and its insurance advisor are agreeable to us doing so.
Finally, your consent may be given through your authorized representative such as your legal guardian, agent, or holder of power of attorney.
May you withdraw your consent for us to collect, use and disclose your information?
Of course, you can choose not to provide us with some or all of your personal information. However, this choice may hinder our ability and the ability of our service providers to adjudicate any claims you have for benefits to which you may be entitled.
We may contact you to offer other insurance and benefit products and services through direct mail, telephone, or other means. If you would rather not receive such information, please use the contact information below to let us know.
How can I change my online communication and advertising preferences?
You may request to receive marketing communications from us by email. You may also receive emails from us if you are an existing or former client, or have made a recent inquiry, including for direct marketing communications. You may opt out of such communications at any time. Please be aware that, even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes such as providing updates to your policy, customer service responses or other policy-related communications. To opt out of marketing communications any time, please contact us or use the “unsubscribe” function found in the footer of all email marketing communications, or contact our Privacy Officer at the address or telephone number listed below.
How long will we retain your personal information?
We will retain your personal information only as long as necessary to satisfy legal or business obligations, including reasonable business record-keeping obligations. The length of time we keep your information depends on the product or service and the nature of the personal information. We have retention standards that meet customer service, legal, and regulatory needs. Generally speaking, we retain your personal file for a period of seven (7) years after you cease being entitled to any benefits that we administer.
How do we keep your personal information accurate and secure?
We take reasonable steps to ensure the information in our records is correct and up to date, however we rely on you to tell us when your personal information changes.
As part of our effort to keep your personal information secure, we limit access to your personal information and store it securely using a variety of physical, technological, and organizational safeguards.
Authorized employees, agents and insurers who require access to your personal information in order to fulfil their job requirements will have access to your personal information.
Do you have the right to request access to your personal information?
Yes, you have the right to request access or correction of your personal information that we have. To request access or correction of your personal information, please make your request to our Privacy Officer at the contact information set out below. You can also have your plan administrator contact us to verify and correct your personal information. There is no charge for verifying or correcting your personal information, other than an administrative charge for retrieval of personal information.
Also, if a third party, such as an insurer, has given us personal information about you which you tell us is wrong, we will give you the name and address of that party so that you can correct the information.
What if you have a question or concern about your privacy?
The Office of the BBD Privacy Officer
402 – 5100 Orbitor Drive
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. If you are not satisfied with our response to a privacy-related inquiry or complaint, you may contact the Office of the Privacy Commissioner of Canada, or your provincial privacy commissioner, if applicable.
Effective Date: April 2019.