Privacy at BBD
Benefits by Design (BBD) Inc. defines personal information as any information, recorded or not, about an identifiable individual. Examples of personal information that are identifiable include names, age, gender, health status, health history, financial information, benefit claims data, etc. It also includes information that can be matched with other information in order to establish an individual’s identity.
What’s Our Commitment to You?
Protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business and is the responsibility of every employee of BBD. As Canada’s leading administered benefits agency, we strive to provide you with the best customer service. The range of products and services we offer our groups and benefit plan participants continues to expand and the technology we use continues to change. But, no matter how our business changes, we are committed to protecting and respecting your right to privacy and confidentiality.
Our Commitment to Your Privacy
BBD is committed to the protection of any personal information collected by it or in its custody, including any information transferred to a third party to fulfill the purposes for which the information was collected. Personal information includes any information, recorded or not, about an identifiable individual. Examples of personal information that are identifiable include: names, age, sex, social insurance numbers, health status, health history, financial information, benefit claims data, etc. It also includes information that can be matched with other information in order to establish an individual’s identity.
BBD’s Privacy Code
Our privacy code informs you of our policies and procedures on privacy and tells you about the ways we ensure that your privacy and the confidentiality of your personal information is protected. The code is based on the Model Code for the Protection of Personal Information, a nationally recognized standard developed by the Canadian Standards Association CSA. Our adoption of this code sends a powerful message to the general public that we have policies and procedures in place that control the collection, use and disclosure of personal information; it also reinforces our existing commitment to customer service.
Our privacy code balances the privacy rights of our groups and benefit plan participants, and our employees with the legitimate information requirements to provide customer service and to meet our human resource requirements. It consists of the following key principles:
We Ask for Your Personal Information for the Following Purposes:
- To establish your identification;
- To provide you and/or your dependents with the applicable benefit coverage;
- To protect you and us from error and fraud;
- To provide ongoing access to other services
We Obtain Your Consent before We:
- Provide benefit coverage;
- Offer you other BBD services;
- Obtain, use or disclose to other persons, information about you unless we are obliged to do so by law or to protect our interests;
- Use your personal information in any way we did not inform you about previously.
When you first become a group and benefit plan participant of Benefits by Design, your personal information is obtained and used only with your consent.
Your consent can be either express or implied. Express consent can be verbal or written. For example, when you sign an enrollment form you are giving us written consent to use your personal information to provide you and/or your dependents with benefits; when you submit a claim form, you are giving us written consent to use your personal information to reimburse you for benefit costs that you incur. Consent can be implied or inferred from certain actions. For example, if you present your benefit identification card to a pharmacist/dentist in lieu of paying for a prescription/dental procedure, it can be implied as consent for the pharmacist/dentist to provide your personal information to the insurer to obtain payment for the service rendered, and for the insurer to process the related claim for payment and provide other services.
For our existing groups and benefit plan participants, we will continue to use and disclose your personal information previously collected in accordance with our current privacy code, unless you inform us otherwise. We will infer that consent has been obtained for the continued use or disclosure of your personal information by the processing of any existing or future benefit claims that you submit for reimbursement or access to other services.
Withdrawl of Consent
You can withdraw your consent any time after you’ve given it to us, provided there are no legal or regulatory requirements to prevent this. If you do not consent to certain uses of personal information, or if you withdraw your consent, we will not be able to administer your benefit coverage. If so, we will explain the situation to you to help you with your decision.
Exceptions to Consent
We may collect, use, or disclose personal information without your consent in the following situations:
- for an emergency that threatens your life, health, or security. We will subsequently inform you of this disclosure;
- for legal reasons. We may be compelled to release this information by a court of law or other legal or regulatory authority. If so, our policy is to disclose the information only to the extent required;
- for the purposes of investigating a breach of an agreement or a contravention of the laws of Canada or a province that has been, is being, or is about to be committed and it is reasonable to expect that disclosure with your knowledge or consent would compromise the investigation;
- where collection is required to investigate inappropriate activity, such as the submission of fraudulent information, and the knowledge and consent of the individual would compromise the availability or accuracy of the information.
- To a government institution, a part of a government institution, or your next of kin or authorized representative and:
- There are reasonable grounds to believe that you have been, are, or may be the victim of financial abuse,
- The disclosure is solely made for the purposes related to preventing or investigating the above, and
- It is reasonable to expect that disclosure with your knowledge or consent would compromise the ability to prevent or investigate the abuse.
- In accordance with other provisions as provided for in the Personal Information Protection and Electronic Documents Act.
We Protect Your Personal Information from Error, Loss, and Unauthorized Access
Our employees who have access to your personal information are made aware of how to keep it confidential. As a condition of employment with Benefits by Design Inc., each employee signs an Agreement requiring all information that they have access to be treated confidentially. We have security standards to protect our systems and your personal information against unauthorized access and use. This protects your personal information at all times when it is stored in data files or handled by our employees.
Your Personal Information Is Destroyed When It Is No Longer Needed
We keep your personal information only so long as we need it for the products and services you are using, to offer you products and services when you are a group and benefit plan participant, and for a reasonable time thereafter, or to meet any legal, regulatory, or tax requirements. We have retention standards, which meet these requirements. We destroy your personal information when it is no longer needed, or we remove your name from the information.
You Can Obtain and Verify the Accuracy of Your Personal Information
You can check your personal information to verify its accuracy. To update and correct it, and to have any incorrect information removed, plan members must have their plan administrator inform BBD of any changes. You can ask our Customer Service Representatives by phone at 1-888-272-0413 to obtain the personal information we hold about you, or do so in person by visiting our offices in Port Coquitlam, British Columbia or Kingston and Toronto, Ontario.
There is no charge for verifying or correcting your personal information. Depending on the circumstances, there may be a minimal charge for the retrieval of personal information that you request. We will inform you if there is a charge. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to BBD, or cannot be disclosed for other legal reasons. If we have obtained information about you from other people, upon your request, we will let you know the person or organization we got it from.
We Correct Your Personal Information
Whenever possible, we will correct any personal information which we may have given to an outside organization. If a third party, such as an insurer has given us personal information which you tell us is wrong, we will give you the name and address of that party so that you can correct the information.
You Can Find out to Whom We Have Given Information about You
If you ask, we will let you know the names of outside companies or organizations we’ve given personal information to, or direct you to the appropriate individual to ask for such information.
We Respond to Your Request Promptly
We will deal quickly with your request to see your personal information and always respond to you
We Protect Other People’s Privacy When We Make Personal Information Available to You
There may be files that include information about you and other benefit plan participants, or that have information confidential to BBD or are the property of BBD. Because we must protect everyone s confidentiality and legal rights, we cannot make these files available to persons outside of BBD. However, we will make available to you any factual information about you contained in such files.
We Monitor Our Compliance with the Bbd Privacy Code and Are Committed to Upholding This Code
We have policies and procedures in place to assist our employees in adhering to the BBD Privacy Code. BBD reviews our policies and procedures on a regular basis and updates them as needed to maintain relevance. Our internal audit department monitors the adherence to this Code on a regular basis. If you have any questions or complaints about our Privacy Code, or about how we are living up to them, let us know right away.
Resolving Your Concern Is Important to Us:
BBD is committed to treating you with the greatest respect and consideration, and providing the highest level of service. If you have any concerns or questions about privacy and confidentiality – or any other concerns about the way a request for personal information was handled, please contact:
The Office of the BBD Privacy Officer
402 – 5100 Orbitor Dr.
Mississauga, ON, L4W 4K4
Phone: (905) 238-7518
Toll Free: 1-877-909-6811
The BBD Privacy Officer’s office will acknowledge your complaint. Within two weeks of receiving your enquiry, the BBD Privacy Officer will write or call to tell you the problem has been resolved, or, in more complex cases, advise you what further steps are being taken and when you may expect a resolution.
If Your Concern Remains Unresolved:
If your concern remains unresolved, please contact the Office of the Privacy Commissioner of Canada. Details to do so are included below:
Office of the Privacy Commissioner of Canada
30 Victoria Street, 1st floor
Gatineau, QC, K1A 1H3
Phone: (819) 994-5444
Toll Free: 1-800-282-1376
Fax: (819) 994-5424
Date Modified: 2018-06-18