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Privacy Policy

At Shepell·fgi, 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.

Accountability

Shepell·fgi is responsible for personal information under its control. Under the leadership of Shepell·fgi’s Privacy Officer robust privacy working groups comprised of individuals from the various areas of the business and operations are accountable for Shepell·fgi’s compliance with this Privacy Policy.

What does Shepell·fgi use your personal information for?

Information collected by Shepell·fgi is used to:

  • Perform services for which we have been hired to do on behalf of our clients. These services include:
    • Employee assistance programs and services (“EAP”) for our clients’ employees;
    • Health Management programs and services for our clients and their employees; and
    • Organizational health and training programs for our clients and their employees.
  • Provide our clients and their employees/members with information about our services and products and enhance our overall service delivery.
  • Create anonymous and aggregate statistics and reports about Shepell·fgi’s services, service standards and trends.  These statistics and reports do not contain any information that could indentify you personally.
  • Information collected by Shepell·fgi is also used to provide our clients with information about our services and products to help enhance the overall effectiveness of our programs and service delivery.
  • Protect the rights and interests of Shepell·fgi, for audit and defence related purposes as required, and/or to assist in managing the business of Shepell·fgi.

Typically, Shepell·fgi receives your personal information from two sources: (i) directly from you; and (ii) from your employer.

Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by Shepell·fgi in this Privacy Policy or otherwise disclosed to you. All personal information shall be collected by fair and lawful means.  Shepell·fgi shall not collect personal information indiscriminately.

Limiting Use, Disclosure & Retention

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes, unless required by law to retain such information for a longer period of time.

Safeguards

Shepell·fgi will employ safeguards to protect personal information from unauthorized access, disclosure, copying, or use, by employing various methods of protection, appropriate to the sensitivity of the information.  The methods of protection may include:

  • Physical measures (locked filing cabinets, restricted access to files and offices);
  • Technological measures (passwords, encryptions, firewalls, and audits); and
  • Organizational controls (security clearances, limiting access on a "need-to-know" basis, staff training, confidentiality agreements, policies and procedures).
  • Contractual confidentiality covenants.

Shepell·fgi shall also employ care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.  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, including insurance laws, tax laws, pension laws, and statute of limitations laws.

Personal Health Information – EAP and Disability Claims Management Services

For clients using EAP and Disability Claims 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 the other service. Internal access to the personal health information is granted on a role-based “need to know” basis.

Accuracy

Personal information collected by Shepell·fgi will be as accurate and complete as is necessary to provide our services.

Individual Access

Upon request, Shepell·fgi shall inform the individual of the existence, use, and disclosure of his or her personal information.  An individual may also have access to their personal information at a cost intended to cover actual expenses and subject to the exceptions noted below.

Shepell·fgi 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, if it contains information that may be harmful to the individual or others, or as may otherwise be required by law. Shepell·fgi will advise the individual of the reason for denying the access request.

An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.  When an individual successfully demonstrates the inaccuracy or incompleteness of personal information Shepell·fgi uses to provide services, Shepell·fgi will correct or update the information as required.

Privacy Concerns

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 regular mail:
Privacy Officer
Shepell·fgi
One Morneau Sobeco Centre, Suite 700
895, Don Mills Road
Toronto, Ontario M3C 1W3

By electronic mail:
privacy-vie-privee@shepellfgi.com

 
© 2014 Shepell·fgi