At Morneau Shepell, we are committed to protecting the confidentiality, security and accuracy of the personal information we receive about you. The management of personal information is fundamental to our services and this Privacy Policy explains our approach to honouring this commitment.
Collection, use and disclosure
Typically, Morneau Shepell receives your personal information directly from you or your authorized representatives, or from your employer, your employer’s authorized agents, association, insurer or benefits plan sponsor.
We limit the collection, use and disclosure of personal information to information that is necessary for the following purposes:
- To perform services that we have been hired to do by your employer, association, insurer, benefits plan sponsor or by you. These services may include:
- Employee and family assistance programs and services (“EFAP”);
- Health management programs and services;
- Organizational health and training programs;
- Pension and benefits consulting services to assist in the design, delivery and management of the pension and benefits programs offered by an association, insurer or plan sponsors to their employees or members;
- Pension, health & welfare and health benefit exchange administration services to assist in the administration of the pension, benefits, and/or insurance programs that associations, insurers or plan sponsors offer their employees or members; and
- Group investment and benefits plans and programs developed and administered by Morneau Shepell;
- To provide our employer, association, insurer and plan sponsor clients and their employees and members with information about our services, products and their usage and to enhance our overall service delivery.
- To conduct research, compile aggregate data, statistics and reports and to perform analytics about Morneau Shepell’s services, service standards and trends for use by Morneau Shepell, its clients and our respective third party service providers. These forms of data, statistics and reports do not contain any information that could reasonably be used to identify you personally.
- For audit, quality control and legal and regulatory compliance purposes including the protection of our interests in civil or criminal proceedings, to resolve any disputes that we may have and to enforce our agreements.
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.
As Morneau Shepell continues to develop and grow, we may buy or sell parts of a business. As our businesses consist primarily of the delivery of services to clients, information regarding the particular accounts or services being purchased or sold could include personal information and be one of the transferred business assets.
Consent
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 expressed or implied. For example by participating in your benefits plan, you consent to our collection and use of your personal information for the purposes of providing services related to such plan. Further, your consent may be obtained directly by us or through your association, insurer, employer or benefits provider.
You may withhold or withdraw your consent for us to collect, use and disclose your personal information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested, or, in the case of insurance and group insurance benefits, it may prevent us from keeping your coverage in force, or properly evaluating and processing any claims.
Safeguards
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, 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, 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.