To ensure accountability, Manion has appointed a Privacy Officer who oversees privacy compliance, employee privacy training and addresses privacy questions or concerns as they arise.
What is Personal Information?
Personal information is information that identifies you as an individual. It includes not only your name and address, age and gender, but also your work history, your identification numbers, including your Social Insurance Number (SIN) and the names of your designated beneficiary(ies) and covered dependants (if applicable). Any medical or dental history provided to us in connection with Welfare claims is personal health information, which is also considered personal information, but is treated with extra sensitivity.
Aggregate information that cannot be associated with a specific individual, such as the number of claims made under a given Plan over a fixed period of time, is not personal information.
Why Does Manion Ask You For Your Personal Information?
Your personal information is essential in order to administer your Welfare and Pension benefits. We ask for and use your personal information for the following purposes:
- Arranging for insurance coverage where applicable.
- Administering your Pension benefits where applicable.
- Verifying your eligibility for benefits
- Paying claims on behalf of you and your eligible dependants.
- Internal audits of benefits payouts and external audits of our management of trust monies.
- Where applicable, income tax reporting purposes or to comply with other legal requirements.
- Where necessary, preparation of reports used by the Plan Sponsor in the financial management and oversight of the Plan(s).
- Understand your insurance needs and respond to your questions or concerns.
- Offering 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.
- Meet or our legal or 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.
Obtaining your Consent before Using your Personal Information
For plans governed by a Board of Trustees, 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.
If you do not consent to certain uses of information, or if you withdraw your consent after it has been given, we may not be able to provide you with a particular benefit or service. If so, we will explain the situation to you and let you know what your options are.
Use of Your Social Insurance Number (SIN)
We ask for your SIN for:
1. Income tax reporting purposes to comply with the requirements under the federal Income Tax Act and the Quebec Act respecting the Ministere du Revenu (if applicable).
2. Administrative purposes to ensure:
- An accurate match between personal information collected from you and the information reported by contributing employers if the employer reports information to Manion using your SIN; and
- You are accurately and uniquely identified internally on our system.
If we don’t need your SIN for income tax reporting purposes, you may choose not to give it to us. In that case, another identification number will be assigned to you with no impact on the services you receive.
Disclosure of your Personal 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 such limited release of personal health information.
Manion will release 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, your personal information may be transferred to a foreign jurisdiction to be processed or stored. Such inforamtion may be provided to law enforcement or national security authorities of that jurisdiction upon request, in order to comply with foreign laws.
Retention of your Personal Information
Manion has developed guidelines and procedures with respect to the retention of personal information both on and off-site. 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.
Manion makes every effort to securely destroy or make anonymous personal information that is no longer required to fulfill identified purposes.
We Keep your Personal Information Secure
Manion takes reasonable measures to ensure that personal information is kept safe from loss or theft, unauthorized access, use, copying, disclosure or modification. Safeguards include physical, organizational and technical measures, such as (but not limited to):
- Security card access to premises;
- Restriction of employee access to files on a “need to know” basis;
- Confidentiality undertakings by all employees;
- Locking up personal information and never leaving it unattended and in plain view;
- Firewalls, anti-virus, strong passwords and software solutions for technical security (including secure, 128-bit encrypted Secure Socket Layer sessions on our website); and
- Regular reviews of privacy compliance initiatives.
You Can See and Verify the Accuracy of Your Information
You have the right to access the information in your file and to verify, update and correct it. There is no charge for verifying or correcting your information, however, if you want a copy of all of your records, there may be a charge to cover our costs. We will let you know in advance if there will be a charge to provide you with this information. All access requests must be in writing and will be dealt with in a timely manner.
In order to safeguard personal information, you may be required to provide sufficient identification information in order for Manion to authorize access to your file.
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.
There may be cases where, by law, we are unable to provide you with access to your personal information. If we must refuse an access request, we will let you know the reason as soon as possible.
Manion’s websites may automatically record some general information about your visit in order for us to engage in web statistical analysis using Google Analytics. We want to make sure our sites are useful to visitors. This information may include the:
- Internet domain for your Internet service provider, such as “company.com” or “service.ca” and the IP address of the computer you are using to access the Manion’s website;
- Type of browser you are using, such as Internet Explorer, Firefox or Chrome;
- Type of operating system you are using such as Windows or Macintosh;
- Date and time of the visit to our site, the pages of our site that were visited, and the address of the previous website you were visiting if you linked to us from another website
- Age category, gender, and affinity interests as determined by demographic and interest reports available through Google Analytics.
Data collected for web analytics purposes may be processed in any country where Google operates servers, and thus may be subject to the governing legislation of that country.
Our Privacy Commitment to You
As your Plan Administrator, we take our commitment to protecting your privacy seriously. We do everything we can to keep your information secure from unauthorized access or misuse. If you have any questions or concerns about this policy or feel that we are not living up to the commitment we are making to you, please contact us as follows:
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 (5:00pm on Fridays)
Toll Free Switchboard: 1 866 532-8999
Fax: (416) 234-2071
Our goal is to resolve any privacy issue you may have in a timely manner to your satisfaction.