Privacy
Policy
Gallivan: Student Health and Wellness, hereafter referred to as Gallivan,
follows the guidelines set out by the Privacy Commissioner and the federal
Personal Information Protection and Electronic Documents Act (PIPEDA) and
related provincial legislative Acts. This policy applies to all records in the
care, custody and control of Gallivan.
Gallivan is committed to protecting the privacy of their clients. The
regulation of collection, storage, utilization and dissemination of personal
information concerning its members and clients is part of Gallivan ongoing
efforts to ensure the decisions concerning individuals is based on accurate
information, that information is gathered for the purpose of providing service
to our clients and is not used inappropriately, and that clients’ personal
information is not disclosed to third parties outside the guidelines of the
PIPEDA.
Personal information is information about an individual that allows the
individual to be identified but does not include the individual’s business
contact information (name, business title, business phone, email or fax
number). Gallivan uses fair and lawful means to collect clients’ personal
information and will only collect such personal information from our clients
that is pertinent and consistent with legitimate business purposes set out in
this privacy policy, required by law or otherwise explained to a client at the
time of the collection. Whenever practical, we will collect the required
information directly from our clients, or from clients’ authorized
representative(s).
In general, we collect such personal information as a client’s name, address,
telephone number(s), student number and or date of birth to:
- confirm the identity of
the client;
- protect both the client
and Gallivan against errors, fraud or other misrepresentations;
- determine the client’s
eligibility for health and dental plans; and
- to properly administer
such health and dental plans to and for the client.?
Access to our
clients’ personal information is restricted to those directors, officers,
employees, licensed representatives, and other persons or organizations acting
for, or on behalf of Gallivan, who are bound by an obligation to Gallivan to
maintain the confidentiality of the information and who require access to the
information in the care, custody and control of Gallivan in order to provide
services to our clients at the optimal level.
The principals underlying Gallivan’ approach to the collection, use and
disclosure of our clients’ personal information are:
- Individuals, generally, should have the right to access the personal information collected, used and disclosed by Gallivan on their behalf in order to ensure it is complete, accurate and up to date;
- The collection, retention, use and disclosure of personal information contained in Gallivan records should be administered by Gallivan in a manner that will protect the privacy of individuals who are the subject of such information;
- Gallivan should seek individuals’ informed consent, whether implied or express, prior to the collection, use or disclosure of the individuals’ personal information; and
- There should be methods for resolving differences concerning privacy protection matters and concerns about access to information.?
Where personal
information is tied in with non-personal, non-confidential information Gallivan
makes every reasonable effort to sever and protect the personal information
from unauthorized disclosure. Gallivan shall refuse to disclose records, except
where required by law, where disclosure would reveal confidential personal
information without the informed and meaningful consent of the individual to
whom the confidential information pertains.
Gallivan only collects, records, uses and discloses such personal information
as is reasonably necessary for the proper administration of services. Gallivan
will obtain an individual’s informed consent, whether implied or express, to
whom the information relates:
- to the use and/or
disclosure of the personal information by Gallivan;
- to the consistent or
one time use or disclosure of the personal information for the purpose for
which the personal information was obtained for the compilation of
aggregate data;
- to the disclosure of
personal information to an officer or employee of Gallivan who needs the
information in the performance of his/her duties;
- to the use or
disclosure of personal information where the use and/or disclosure of the
information is necessary and proper in the discharge of Gallivan functions
and responsibilities;
- to the disclosure of
personal information for the purpose of complying with a requirement to
provide information lawfully imposed on Gallivan by a federal or
provincial governmental authority; and
- to the disclosure of
personal information pursuant to a court order or other legal means of
compulsion, disclosure is to a law enforcement agency or institution in
Canada.??
Gallivan will
take reasonable precautions to protect the security of records containing
personal information, will retain such information only for reasonable periods
of time and will make arrangements for the secure disposal and destruction of
such records when that period has expired.
Gallivan will ensure that personal information is:
- collected and retained only as authorized under the PIPEDA and other privacy legislation;
- used only for the purpose for which it is collected or a consistent purpose for providing service to clients;
- accurate and up-to-date; and
- protected by appropriate security measures, and that the appropriate policy and procedure is in place to reflect these principles.
A physical client record containing a clients’
personal information is maintained while the client is enrolled as a student,
an electronic copy of a client’s record is retained for seven (7) years. When
an enrollment break of two (2) years has elapsed the physical record is
destroyed. Any part of the physical and/or electronic client record that is
redundant is destroyed.
If a client is unable to access their records at the Benefit Plan Office,
requests for access to records must be made in writing to the Privacy Officer
at the contact information provided below. Access granted will normally be in
the form of a copy of the record in question. Individual administrative
officers are responsible for responding to requests from the Privacy Officer
for access to or disclosure of information from records under their control.
Privacy Principles
Accountability: We strive to protect
clients’ personal information used to establish and maintain clients’ benefits.
We continue to develop and implement policies and practices within Gallivan for
the security of clients’ information provided to us.
Purposes: The information that we
collect is only used to establish and maintain benefit coverage and to
communicate coverage information to the client.
Consent: Gallivan collects clients’
personal information, and in turn provides same to the institution and/or the
Benefit Plan Office with clients’ informed consent whether implied or express.
Collection: Only information that is
relevant to a client’s benefit plans is collected.
Use, Disclosure, and Retention:
Information is used only for the benefit plans and is only disclosed to those
parties directly involved in providing these benefits. Retention is only as
long as necessary to fulfill contractual obligations to the client or as
required by law.
Accuracy: Every effort is taken to
sustain information accuracy.
Safeguards: We protect our clients’
personal information with established safeguards appropriate to the sensitivity
of the collected information.
Openness: The Privacy Officer for Gallivan
will answer any inquiries within the allotted time frame should you need
information regarding our practices.
Individual Access: The client can
gain access to their information at the Benefit Plan Office and through Gallivan
Head Office in Waterloo, Ontario.
Concerns, Inquiries, and Requests: If
for any reason your questions cannot be answered in regards to your personal
information held at the Benefit Plan Office you may send an inquiry with your
institution name and student identification number to Gallivan Privacy Officer,
via email at privacyofficer@gallivan.ca or mail to:
Privacy Officer
Gallivan: Student Health and Wellness
Suite 206, 470 Weber Street, North
Waterloo, Ontario
N2L 6J2