Special Benefits Insurance Services Commitment To Privacy

Special Benefits Insurance Services’ 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 clients 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:

1. We ask for your personal information for the following purposes:

   • To establish your identification.
   • To provide you and/or your dependants with the applicable benefits.
   • To protect you and us from error and fraud.
   • To provide ongoing services.

2. Consent

   When you first become an individual benefit plan participant through Special Benefits Insurance Services, your personal information is obtained and used only with your consent. We obtain your consent before we:

   • Accepted you in a Special Benefits Insurance Services plan through one of our authorized partners.
   • Offer you other Special Benefits Insurance Services health insurance products.
   • 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.

   Your consent can be either express or implied. Express consent can be verbal or written. For example, when you sign an application 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 claims form, you are giving us written consent to use your personal information to reimburse you for benefit costs you incur.

   Consent can be implied or inferred from certain actions. For example, if you present your Pay Direct Drug 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.

   For our existing clients, 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 benefits claims that you submit for reimbursement.

3. Withdrawal 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 don’t consent to certain uses of personal information, or if you withdraw your consent, we will not be able to offer you our full range of services and may not be able to provide you with health coverage. If so, we will explain the situation to you to help you with your decision.

4. Exceptions to Consent

   We may collect, use or disclose personal information without your consent only:

   1. for an emergency that threatens your life, health or security. We will subsequently inform you of this disclosure.
   2. if we must disclose personal information 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.
   3. 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.

5. 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 dealing with Special Benefits Insurance Services, 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.

6. 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 client 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.

7. 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, you must advise us of these changes. You can ask our Customer Service Representatives by phone at 1-800-667-0429 to obtain the personal information we hold about you, or do so in person by visiting our office in Toronto, Ontario.

   There is no charge for verifying or correcting your personal information. Depending on the circumstances, there may be a minimal charge for 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 Special Benefits Insurance Services, is too costly to retrieve, 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.

8. 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 a third party benefit plan administrator 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.

9. 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.

10. Google Analytics, Google Advertising, and Remarketing Campaigns

    SBIS tracks user statistics through Google Analytics.

    We also take part in Google Advertising and remarketing campaigns. This means third parties, including Google, may display our ads.

    These third parties, including Google, do this through the use of cookies — small pieces of data received by your computer.

    You may be shown ads based on your web history, including visits to our site.

    If you would rather not take part in these Google campaigns, please follow the instructions on Google’s advertising opt-out page.

11. We Respond to Your Request Promptly.

    We will deal quickly with your request to see your personal information and always respond to you promptly.

12. 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 members, or that have information confidential to Special Benefits Insurance Services or are the property of Special Benefits Insurance Services. Because we must protect everyone’s confidentiality and legal rights, we cannot make these files available to persons outside of the Special Benefits Insurance Services office. However, we will make available to you any factual information about you contained in such files.

13. We monitor our compliance with the Special Benefits Insurance Services Privacy Code and are committed to upholding this Code.

    We have policies and procedures in place to assist our employees in adhering to the Special Benefits Insurance Services Privacy Code. Our Principal 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.

14. Resolving Your Concerns Are Important To Us

    Special Benefits Insurance Services 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, you can take the following actions:

    Contact the Principal of Special Benefits Insurance Services

    Call the office of Special Benefits Insurance Services
    at 416-601-0429 or toll free at 1-800-667-0429

    Or write to:
    Principal
    Head Office:
    Special Benefits Insurance Services
    366 Bay St, 7th Floor, Toronto, ON, M5H 4B2

    North East Branch:
    Special Benefits Insurance Services
    158 Casimir Street, Port Perry, ON, L9L 1B7

    FAX the Special Benefits Insurance Services office Principal at 416-601-0308

    The Special Benefits Insurance Services office will acknowledge your complaint. Within four weeks of receiving your enquiry, the Principal of Special Benefits Insurance Services 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.

15. If Your Concern Remains Unresolved

    Please contact:
    The Office of the Privacy Commissioner of Canada
    112 Kent Street
    Ottawa, Ontario
    K1A 1H3

    Telephone: 1-613-995-8210
    Toll Free: 1-800-282-1376
    Fax: 1-613-947-6850
    Web Site: www.privcom.gc.ca
    E-mail: info@privcom.gc.ca