GREEN SHIELD CANADA'S PRIVACY CODE
Our privacy code outlines our policies and procedures on privacy and describes the ways we ensure that your privacy and the confidentiality of your personal information is protected. It is based on the ten privacy principles outlined in Canada’s Personal Information Protection and Electronic Documents Act also known as PIPEDA. Our adoption of these principles 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 groups 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:
1We ask for your personal information for the following purposes:
To establish your identification.
To provide you and/or your dependants with the applicable benefit coverage.
To protect you and us from error and fraud
To provide ongoing access to other services of Green Shield
When you first become a group and benefit plan participant of Green Shield Canada, your personal information is obtained and used only with your consent. We obtain your consent before we:
provide benefit coverage.
offer you other Green Shield Canada services.
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 enrollment 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 that you incur.
Consent can be implied or inferred from certain actions. For example, if you present your benefit identification 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 Green Shield Canada to obtain payment for the service rendered, and for Green Shield Canada to process the related claim for payment and provide other services.
For our existing groups and benefit plan participants, 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 benefit claims that you submit for reimbursement or access to other services.
3Withdrawal 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 administer your benefit coverage. If so, we will explain the situation to you to help you with your decision.
4Exceptions to Consent
We may collect, use or disclose personal information without your consent only:
(a) for an emergency that threatens your life, health or security. We will subsequently inform you of this disclosure.
(b) 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.
(c) 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 employment with Green Shield Canada, each employee signs an Agreement requiring all information that they have access to be treated confidentially. They are also required to participate in annual security and privacy awareness training programs. 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 group and benefit plan participant 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 tell your plan sponsor to advise us of these changes. You can ask our Customer Service Representatives by phone at 1-888-711-1119 to obtain the personal information we hold about you, or do so in person by visiting our head office in Windsor, 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 Green Shield Canada, 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.
8We 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
9You 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.
10We Respond to Your Request Promptly.
We will deal quickly with your request to see your personal information and always respond to you promptly.
11We 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 plan participants, or that have information confidential to Green Shield Canada or are the property of Green Shield Canada. Because we must protect everyone's confidentiality and legal rights, we cannot make these files available to persons outside of Green Shield Canada. However, we will make available to you any factual information about you contained in such files.
12We monitor our compliance with the Green Shield Canada Privacy Code and are committed to upholding this Code.
We have policies and procedures in place to assist our employees in adhering to the Green Shield Canada Privacy Code. Our internal audit department monitors the adherence to this Code on a regular basis, and reports its findings to a Committee of the Board of Directors of Green Shield Canada.
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.
13Resolving Your Concerns Are Important To Us
Green Shield Canada 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 Green Shield Canada Privacy Officer
Write to: Privacy Officer
Green Shield Canada
P.O. Box 1606
FAX the Office of the Green Shield Canada Privacy Officer at 1-519-739-2253
The Green Shield Canada Privacy Officer’s office will acknowledge your complaint. Within two weeks of receiving your enquiry, the Green Shield Canada Privacy Officer 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.
14If Your Concern Remains Unresolved
If your concern remains unresolved, please contact:
The Office of the Privacy Commissioner of Canada
112 Kent Street
Toll Free: 1-800-282-1376
WEB SITE: www.privcom.gc.ca