Personal information is information about an identifiable individual, including personal health and financial information. It does not include the name and business contact information of individuals.
What does Morneau Shepell use your personal information for?
Typically, Morneau Shepell receives your personal information directly from you or your authorized representatives, or from your employer or benefits plan sponsor.
We limit the collection, use, and disclosure of personal information to information that is necessary for the purposes disclosed to you, including:
- To perform services that we have been hired to do by your employer or benefits plan sponsor or by you. These services include:
- Health & Productivity Solutions
- Administrative Solutions
- Retirement Solutions
- To provide our plan sponsors clients and their employees/members with information about our services and products and enhance our overall service delivery.
- To create anonymous and aggregate statistics and reports about Morneau Shepell’s services, service standards, and trends. These statistics and reports do not contain any information that could identify you personally.
- For audit, quality control, and the protection of our interests in civil or criminal proceedings.
We will retain personal information for as long as necessary for the purpose for which it has been collected, or as required or permitted by law.
We will collect, use, and disclose your personal information with your consent and only for the purposes we disclose to you, or as otherwise required or permitted by law. Consent may be express or implied. For example, by participating in the benefits plan your employer/plan sponsor offers, you consent to our collection and use of your confidential information for the purposes of providing services related to such plan. Further, your consent may be obtained directly by us or through your employer/benefits provider.
We will employ safeguards to protect personal information from unauthorized access, disclosure, copying, or use by using various methods of protection, appropriate to the sensitivity of the information. The methods of protection include:
- physical measures (locked filing cabinets, and restricted access to files and offices);
- technological measures (passwords, encryptions, firewalls, and audits);
- organizational controls (security clearances, limiting access on a "need-to-know" basis, staff training, confidentiality agreements, and policies and procedures); and
- contractual confidentiality covenants.
Morneau Shepell will also employ care in the disposal or destruction of personal information to protect against unauthorized parties from gaining access to the information.
Personal health information: Employee and Family Assistance Program (EFAP) and Attendance and Disability Management Services
For clients using EFAP and Attendance and Disability Management Services, the personal health information collected for the purpose of providing one service will not be used or disclosed for the purpose of providing any other service. Separate files are created for each service used by a client, and the personal health information from one file is not shared or combined with any other file. Internal access to the personal health information is granted on a role-based “need to know” basis.
Accuracy and access
We will employ measures to keep personal information collected by us accurate and complete in order to minimize the possibility of using or disclosing incorrect personal information.
Upon request, we will inform you of the existence, use, and disclosure of your personal information. You may also have access to your personal information at a cost intended to cover actual expenses and subject to the exceptions noted below.
We may deny access to certain personal information it holds about an individual if the information is prohibitively costly to provide; if it contains references to other individuals; if it cannot be disclosed for legal, security, or commercial proprietary reasons; if it is subject to solicitor-client or litigation privilege; or as may otherwise be required by law. We will advise you of the reason for denying the access request.
You may challenge the accuracy and completeness of the information and we will update or correct any factually inaccurate information.
If you have any concerns related to privacy issues or our handling of your personal information, or would like to withdraw a consent that you have previously provided to us, please do not hesitate to communicate in writing with our privacy officer by:
895 Don Mills Road, Suite 700
Toronto, Ontario M3C 1W3