At Manion Wilkins & Associates Ltd. (“Manion”), your privacy is of great importance to us. Manion is dedicated to the protection and privacy of the personal information of all it’s clients and their plan participants, website visitors and other individuals whose personal information is entrusted to Manion. In recognition of privacy legislation, Manion has developed this Privacy Policy to ensure that all personal information is handled in a secure manner. This Privacy Policy will be strictly applied to the collection, use, storage, and disclosure, of personal information used in our administration of our clients programs.

 

1. Accountability for Your Privacy

 

Manion takes full responsibility for the management and confidentiality of personal information. Personal information is collected, used, shared and stored in accordance with the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 and any applicable provincial privacy laws that may apply to Manion from time to time. Manion also respects the privacy best practice principles contained in the Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96.

Manion has appointed a Chief Privacy Officer who oversees compliance with privacy laws and best practice. The Chief Privacy Officer’s duties include:

• Developing and, on a regular basis, reviewing Manion policies and practices to ensure consistent implementation and compliance;
• Ensuring all staff are trained on privacy best practices and are aware of the importance of safeguarding any personal information that they are privy to;
• Ensuring that all inquiries and complaints relating to privacy are appropriately handled; and
• Ensuring all third parties to whom Manion provides access to personal information adhere to appropriate standards of care in managing that information.

 

2. Personal Information and How We Collect It

 

‘Personal information’ is any factual or subjective information, recorded or not, about an identifiable individual. This includes your name, contact information, birthdate, any identifiers such as your social insurance number, and any identifiable on-line activity. It also includes information about your designated beneficiaries and covered dependants, if applicable. Any personal health information such as medical or dental history, and any financial information, such as banking details, is sensitive personal information that we treat with extra care.

Aggregate information that cannot be associated with a specific individual, such as the number of medical and dental claims made under a given Plan over a fixed period of time, is not personal information.

Personal information can be collected in several ways, including through application forms as well as any other documents you provide to Manion, or that is provided to us by a third party such as an employer or health professional. We collect limited personal information to offer and deliver our products or services and do so with your consent or as otherwise authorized by law. We identify when information may be provided optionally and when it is necessary in order to service you as your Plan Administrator.

 

3. Obtaining your Consent

 

For Plans governed by a Board of Trustees, registration to participate in the benefit or pension plans requires plan participant authorization to gather and apply personal information in specific ways. We obtain your express consent to use your information when you complete a Member Information Card. For all other Plans, we obtain your consent on an Application for Benefits, or we rely on your employer to obtain your consent to share information with Manion for the purpose of administering your benefits. We always obtain your express consent when you fill out a claim form. Your consent is implied when we can reasonably conclude that you’ve given consent by some action, or that you would consent if directly asked. For example, if your Plan offers a pay-direct drug card and if you use the drug card, we can conclude that you have given us your consent to release personal information about your eligibility for benefits to our pharmacy benefit manager and your pharmacist. Unless otherwise stated, your consent is effective on date on which you consent, expressly or by implication.

Note that there may be instances where the law permits the collection, use or disclosure of your personal information without your consent, for example in the context of fraud investigations, and where necessary to protect our legal interests or the safety of others. In other contexts, your consent can be withdrawn at any time, subject to legal or contractual restrictions, by providing us with written notice. Upon receipt of notice of withdrawal of consent, we will inform you of the likely consequences of withdrawing your consent before we process your request, which may include the inability of Manion to provide you with a particular benefit, product or service.

 

4. Using Your Information

 

We collect and use personal information for the following specific purposes:

• To arrange for insurance coverage where applicable;
• To administer your Welfare and Pension benefits where applicable;
• To verify your identity and your eligibility for benefits;
• To pay claims on behalf of you and your eligible dependents;
• For internal audits of benefits payouts and external audits of our management of trust monies;
• Where applicable, for income tax reporting purposes or to comply with other legal requirements;
• Where necessary, to prepare reports used by the Plan Sponsor in the financial management and oversight of the Plan(s);
• To understand your insurance needs and respond to your questions or concerns;
• To offer you additional insurance products or services that we believe you would benefit from knowing about. We may also tailor our offerings to you based on your demographics or other information, with the objective of meeting your specific needs;
• To assess and manage risk, including detecting and preventing fraud or error; and
• To meet legal and regulatory processes and requirements, as well as Manion’s contractual obligations.

We may verify some of the information you give us with your employer or your union in order to administer your Welfare and Pension benefits correctly. Depending on the Plan, we may also administer payments for industry funds, associations or union dues on behalf of your employer, such that you are personally identified, however, your personal health information is never collected, used or disclosed for such purposes.

 

5. Our Website Practices

 

When you use Manion’s website or mobile app, we automatically receive and record information on our server logs from your browser or mobile platform, including the date and time of your visit, your IP address, unique device identifier, browser type and other device information (such as your operating system version and mobile network provider). By setting cookies, Manion is able to enhance a user’s on-line experience (e.g. we may identify you as a return visitor in order to provide you with a more meaningful visit). You can disable cookies through your website browser, however some areas of the site, such as myManion, may not work properly with cookies disabled.

The information we collect when you visit Manion on-line help us analyze and improve the performance of our digital services. Manion uses Google Analytics for web statistical analysis. We make no effort to personally identify you based on your visit to our site if you are not logged into your account. If you wish, you may opt out of being tracked by Google Analytics by disabling or refusing the cookies; by disabling JavaScript within your browser; or by using the Google Analytics Opt-Out Browser Add-On.

 

6. Sharing Your Information

 

Your personal information is shared with the following parties only to the extent required to administer your benefits: your Plan Sponsor; your union (if applicable); the coverage provider(s); and the financial institution(s) involved in caring for the Plan. In the case of a claim for Welfare benefits, we may also share information, but only as necessary, with your hospital, doctor, dentist or other professionals to protect ourselves and coverage providers against fraud, and in order to properly assess your claim. We obtain your authorization on claim forms to allow such limited release of personal health information.

Manion will release plan participant your personal information when we believe such release is appropriate in order to comply with the law, for example, if we receive a subpoena, court order or request from government authorities.

Only authorized persons have access to your file as required for coverage or claim purposes. The information in your file is not shared with anyone other than yourself, unless you authorize us to release it to them. Note however, that Manion’s third party service providers may obtain your personal information in order to assist us in providing you with our services. In working with our service providers, insurers and reinsurers, your personal information may be transferred to a foreign jurisdiction to be processed or stored. You can contact our Chief Privacy Officer for more information about our practices and policies regarding transferring personal information outside of Canada. Such information may be provided to law enforcement or national security authorities of that jurisdiction upon request, in order to comply with foreign laws. We take reasonable steps to ensure that any such third parties who we entrust with your personal information are reputable and have safeguards in place to protect this information.

 

7. Keeping Your Information Safe

 

Manion has implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful access to the personal information we manage and store. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by Manion significantly reduce the likelihood of a data security breach.

Here are some examples of the security controls we have in place:

• Secure office premises with key card access;
• Locked filing cabinets and a secure shredding practice for paper records;
• The use of encryption, firewalls, anti-virus programs and robust authentication processes, including complex passwords, for electronic records; which are regularly upgraded;
• Hardcopy files are treated with similar security measures;
• Limited access to personal information by employees on a “need-to-know” basis;
• The use of data centers with effective physical and logical data security controls;
• Staff that are keenly aware of their data protection responsibilities; and
• Regular reviews of privacy compliance and best practice initiatives.

In addition, we recommend that you do your part in protecting yourself from unauthorized access to your personal information. For example, choose a strong password, do not share it with anyone, and ensure no one else uses your computer or device when you are logged in to myManion. Manion is not liable for any unauthorized access to your personal information that is beyond our reasonable control.

 

8. Accessing Your Information

 

We make every effort to ensure that the personal information we hold is accurate, complete and up-to-date for the purposes for which we collect it. You can make a written request for access to your personal information at any time, and also request that it be corrected if there are any inaccuracies. You will need to provide as much information as you can to help us process your request and locate the information you require.

If you need assistance in preparing your request, please contact use and we would be pleased to help you. Upon your written request, Manion will also inform you of how your personal information has been or is being used, and who your personal information has been shared with. If we have obtained information about you from other people, we will let you know who we got it from upon your request. For example, we may obtain your initiation date from your local union office. We also obtain confirmation that you worked for a particular employer from the employer’s contribution remittance forms.

Manion responds to access requests within 30 days, unless an extension of time is required. We may charge a fee to cover any expenses related to responding to your access request. Note that there may be contexts where access is refused or only partial information is provided, for example, in the context of an on-going investigation or where another individual’s personal information or identity must be protected.

 

9. How Long We Keep Your Information

 

Manion retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with our retention schedules. Personal information that has been used to make a decision about a Plan participant shall be retained long enough to allow the individual access to the information after the decision has been made. Manion is subject to specific legal requirements with respect to retention periods as well, for example, as outlined in income tax and pension legislation.

Once your information is no longer required by Manion to administer products or services and meet legal or regulatory requirements, it is securely destroyed, erased or made anonymous. Keep in mind however that residual information may remain in back-ups for a period of time after its destruction date.

 

10. Our Privacy Complaint and Breach Management Process

 

Manion takes privacy complaints very seriously and has a procedure in place for escalating and managing any privacy related concerns to ensure that they are responded to in a timely and effective manner. Any suspected privacy breach must be escalated internally to Manion’s Chief Privacy Officer who oversees the containment, investigation and corrective actions for the breach situation.

In the event that you are not satisfied with Manion’s resolution of a complaint or privacy breach, you may contact the Office of the Privacy Commissioner of Canada. Visit www.priv.gc.ca.

 

11. External Links and Social Media

 

We may offer links from our websites to the sites of third parties, such as affiliated organizations, that may be of interest to you. Manion makes no representations as to such third parties’ privacy practices and we recommend that you review their privacy policies before providing your personal information to any such third parties.

Manion’s use of social media serves as an extension of our presence on the Internet and help us build a positive brand image as well as offer our customers personalized service. Manion maintains several social media accounts that are not hosted on Manion’s servers. Users who choose to interact with Manion via social media, such as Facebook, should read the terms of service and privacy policies of these services/platforms.

 

12. Changes to this Policy

 

We may change this Privacy Policy from time to time in order to better reflect our current personal information handling practices. Thus, we encourage you to review this document frequently! The “Last Updated” date at the top of this Privacy Policy indicates when changes to this policy were published and are thus in force. Your continued use of Manion products and services following the posting of any changes to this Privacy Policy means you accept such changes.

 

13. Getting in Touch

 

Any inquires, concerns or complaints regarding privacy should be directed to:

Chief Privacy Officer
Manion Wilkins and Associates Ltd.
500-21 Four Seasons Place
Etobicoke, ON M9B 0A5

• Telephone: Call Centre (416) 234-3511
• Hours: 7:30 am to 7:30 pm (7:30 am to 5:00 pm on Fridays)
• Toll Free Switchboard: 1 866 532-8999
• Fax: (416) 234-2071
• E-mail: privacyofficer@manionwilkins.com

Your concerns will receive prompt attention. Our Privacy Office can also provide you with more detailed information about Manion’s policies and practices or assist you with completing an access to information request. Keep in mind however that e-mail or text messaging are not secure forms of communication, so never send confidential personal information to us this way.

Thank you for continued trust in Manion.