Notice on Privacy and Confidentiality
Green Shield Canada's Commitment to Privacy
Protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business and is the responsibility of every employee of Green Shield Canada. As Canada's premier group and individual benefits specialist, we strive to provide you with the best customer service. The range of products and services we offer continues to expand and the technology we use continues to change. But, no matter how our business changes, we are committed to protecting and respecting your right to privacy and confidentiality.
Our Commitment to Privacy
Green Shield Canada is committed to the protection of any personal information collected by it or in its custody, including any information transferred to a third party to fulfill the purposes for which the information was collected.
Personal information includes any information, recorded or not, about an identifiable individual. Examples of personal information that are identifiable include names, age, sex, health status, health history, financial information, benefit claims data, etc. It also includes information that can be matched with other information in order to establish an individual's identity.
Green Shield Canada's Privacy Code
The Green Shield Canada 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 customers 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 benefit coverage.
- To protect you and us from error and fraud.
- To provide ongoing access to other services of Green Shield Canada.
When you first become a customer 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.
- 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 claim 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 customers, 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.
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 administer your benefit 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 in the following situations:
(a) for an emergency that threatens your life, health or security. We will subsequently inform you of this disclosure.
(b) 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) to another organization for the purposes of investigating a breach of an agreement or a contravention of the laws of Canada or a province that has been, is being, or is about to be committed and it is reasonable to expect that disclosure with your knowledge or consent would compromise the investigation.
(d) to another organization for the purposes of detecting or suppressing fraud or of preventing fraud that is likely to be committed and it is reasonable to expect that the disclosure with your knowledge or consent would compromise the ability to prevent, detect or suppress the fraud.
(e) made to a government institution, a part of a government institution or your next of kin or authorized representative and
i. there are reasonable grounds to believe that you have been, are, or may be the victim of financial abuse,
ii. the disclosure is made solely for the purposes related to preventing or investigating the above, and
iii. it is reasonable to expect that disclosure with your knowledge or consent would compromise the ability to prevent or investigate the abuse.
(f) We protect your personal information from error, loss and unauthorized access
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 provide ongoing access to other services of Green Shield Canada, when you are a customer 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. You can ask our Customer Service Representatives by phone at 1-888-711-1119 to obtain the personal information we hold about you, or if you have signed up for on-line access, you may visit our website at www.greenshield.ca and log on to the Plan Member section. There is no charge for verifying your personal information, however depending on the circumstances, there may be a minimal charge for the retrieval of personal information that you request. We will inform you if there is a charge. If you identify information that requires correction, we will assist you in identifying the appropriate means to have the correction(s) made.
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 unreasonable or impractical to reasonably retrieve, or cannot be disclosed for other legal reasons.
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 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. We respond to your request promptly
We will deal quickly with your request to see your personal information and always respond to you promptly.
11. 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 customers, 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.
12. We 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 it, let us know right away.
13. Resolving 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.
14. If your concern remains unresolved
If your concern remains unresolved, please contact:
Office of the Privacy Commissioner of Canada
30 Victoria Street