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Our Privacy Policy
Our ability to administer Pension and Health Benefit Plans requires that D.A. Townley &
Associates keeps comprehensive knowledge of Plan Members'
employment history and certain personal information, which may
include medical information. We are committed to protecting your personal
information. Managing the information you provide to us in a
professional and secure manner is key to successful operation
of your benefit plans.
D.A. Townley has adopted the
following Privacy
Principles, which reflect our commitment to safeguarding
our Members' personal information:
- Information about you and your communications with us are
kept confidential.
- D.A. Townley will not sell your personal information.
- Information about you is gathered lawfully and fairly.
- Information about you is gathered, used and/or disclosed only to
provide you with benefits and services as outlined in your
plan documents.
- We
maintain appropriate procedures to ensure that personal
information in our possession is accurate and, where
necessary, kept up to date. You are entitled to seek a
correction of your personal information if you believe that
the information in our possession is not accurate.
- You
may access your personal information, subject to limited
exceptions and conditions.
- Personal information is not disclosed without the Member's
permission except in limited circumstances as permitted or required by
law. However, as the Administrator, we may share personal information with our actuaries,
administrator, agents, consultants or service providers in
connection with providing, administering, adjudicating,
costing, financially managing and servicing Members' plans
and benefit programs.
- Where
we choose to have certain services, such as actuarial
valuation,
provided by third parties, we take all reasonable precautions regarding
the practices employed by the service provider to protect your
personal information. We ask that they, in turn, undertake to
honour D.A. Townley's privacy policy and applicable
legislation.
- To protect your personal information against unauthorized access, disclosure, copying, use,
modification, theft or accidental loss, D.A. Townley will
maintain appropriate security mechanisms.
D.A. Townley & Associates has
adopted a Privacy Policy that complies with privacy
legislation applicable to the jurisdictions in which our Members reside, and to the programs and services which we
offer in the administration of your benefit plans. Based upon
the Canadian Standards Association's "Model Code for the
Protection of Personal Information" (now a statutory
standard under the federal Personal Information and Electronic
Documents Act), our policy governs the behaviour of our
employees, consultants and agents with regard to collection, use, and
disclosure of our Plan Members' personal information. D.A. Townley & Associates continues to work towards
compliance with this standard in all aspects of our business.
Collecting personal information about
you is essential to our ability to administer your benefit
programs and to provide you with on-going service. We take
great care to keep the information about you that we collect,
accurate, confidential and secure.
We want you to know why we need your
personal information, how the confidentiality of this
information is protected, and how you can find out what
information concerning you is recorded.
How
We Collect, Use and Disclose Personal Information
What information do we keep?
We collect and store non-public personal
information. It comes from a variety of sources such as the
applications or other forms that you complete (for example,
your name, your Social Insurance number, and your address),
from your employers, or from correspondence with you and
service providers you have engaged to provide medical or other
benefits. We collect only the information we need for the
purpose of providing and servicing health benefit and
retirement programs we administer on your behalf.
In order to provide certain benefits, we
may be required by legislation (such as the Pension Benefits
Standards Act) to collect and store your Social Insurance
Number.
We do not sell your personal
information.
Why
do we need the information?
We need to collect personal
information to:
- determine
your eligibility for benefits,
- administer
and adjudicate your benefits,
- determine
the cost and financially manage these programs,
- meet
regulatory or contractual requirements relating to the
benefits and related services provided to you.
We will make sure you understand why we
need the information by using clear, understandable language
when describing the purpose.
We
will obtain your permission
We collect, use or disclose your
personal information with your permission. Your permission may
be expressed in writing or be implied and you may give it to
us verbally, electronically, or through your authorized
representative.
With reasonable notice, and subject to legal and contractual
restrictions, you may withdraw your permission to
collect, use and disclose your personal information at any
time.
We will obtain your consent to collect or release medical
information about you.
Before we make information available to third parties, other
than an agent or authorized service provider who needs it, we
will tell you at the time we obtain your consent or before we
make the information available, who those persons or
organizations are, the kind of information we want to share
with them and why.
Of course, you can choose not to provide
us with some or all of your personal information. However,
this choice may hinder our ability to adjudicate any claims
you have for benefits to which you may be entitled.
How
long do we keep information?
We will keep your personal information
as long as it is necessary, or as required by law. When
personal information records are destroyed, we will use
appropriate safeguards to
prevent unauthorized parties from gaining access to the
information during the process.
We Will
Protect Your Personal Information
We
are responsible for your information
We are responsible for all personal
information in our possession, including information
transferred to a third party service provider or agent
so that we can provide you with benefits and related
services.
How
we protect information
Only D.A. Townley & Associates and employees, employees or
trustees of plan sponsors, agents and authorized service
providers who need it to do their jobs may access your
personal information. Where possible,
when we provide information to third parties
such as actuaries, we attempt to eliminate any references that
allow identification of the individuals. We require all
employees, agents and authorized service providers to comply
with this Privacy Policy.
We have developed and are continuing to
enhance security procedures to safeguard and protect personal
information against loss, theft, unauthorized disclosure,
copying, and unauthorized use or modification. We will
maintain appropriate safeguards and security procedures that
reflect the types of documents, including electronic or paper
records, organizational measures including security clearances
and limiting access on a "need-to-know" basis, and
technological measures such as the use of passwords and
encryption. While we endeavour to protect all information, the
most sensitive information, such as medical information,
receives the highest level of protection.
For telephone inquiries to our Benefits
Administration staff, the information provided varies based on
the relationship of the person making the inquiry to the Plan Member
(e.g., authorized service provider, Plan Member, or
dependent). After the caller has been screened for appropriate
identification, only information pertaining to the specific
claim, treatment, or benefit in question is shared.
Your
Right to Access Your Personal Information
Your
rights
You have the right to ask whether we
hold any personal information about you. You have the right to
see that
information, as provided by law. Where we have obtained
medical information about you from a third party, we will
release this information only through your permission.
You also have the right to know:
- how
we collected your personal information,
- how
we are using it,
- and to
whom it may have been disclosed.
How
to request an update or correction
If you believe any of the information we
have collected about you is incorrect or incomplete, you have
the right to ask us to change it.
You may make a request to change our
records about you by writing to our Privacy Officer, at:
D.A. Townley
& Associates Ltd.
101 – 4190
Lougheed Highway
Burnaby,
British Columbia
V5C 6A8
If you show that your personal
information is inaccurate or incomplete, we will make the
necessary changes, and where appropriate, we will contact any
third parties with whom this information has been shared.
If you feel we have not dealt with your
request to your satisfaction, you may register a
privacy-related complaint by contacting D.A. Townley's Privacy
Officer. We will explain our complaint procedure to you and
investigate all complaints.
If a complaint is justified, we will take all
appropriate steps to set the situation right, including
changing our policies and practices if necessary. We will also
let you know what
other complaint procedures may be available to you.
We reserve the right to revise our
privacy policy as needed. If changes are made, the new policy
will be posted on the www.datownley.com
web site.
Web Site Policy
This Web site does not automatically gather any specific
personal information from you, such as your name, phone number
or e-mail address. We would only obtain this type of
information if you supply it by sending us an e-mail or
registering in a secure portion of the site.
D.A. Townley & Associates employs software programs to
monitor network traffic to identify unauthorized attempts to
upload or change information, or otherwise cause damage. This
software receives and records the Internet Protocol (IP)
address of the computer that has contacted our Web site, the
date and time of the visit and the pages visited. We make no
attempt to link these addresses with the identity of
individuals visiting our Web site unless an attempt to damage
the Web site has been detected.
D.A. Townley & Associates occasionally uses
"cookies" to track how our visitors use this site or
to determine sites previously visited. The cookies we use do
not allow us to identify individuals. They are compiled into
statistical information on traffic patterns and are used to
assess site efficiency. If a D.A. Townley site is using
cookies that collect personal information, a notice will
appear on the site advising of such use and you will be
provided with an opportunity to refuse them. Such refusal will
not affect the site performance or restrict your ability to
access information from this site. (A "cookie" is a
file that may be placed on your hard drive without your
knowledge by a web site to allow it to monitor your use of the
site.)
Visitor information is not disclosed to anyone except D.A.
Townley personnel who need the information to carry out
responsibilities of their job. Any further disclosure of the
personal information you give us will be in accordance with
Townley's Privacy Policy.
External Service Providers
In order to effectively operate its Web sites, D.A. Townley
& Associates uses external service providers. These
service providers are bound by a contract with D.A. Townley to
treat any personal information they may receive in a manner
that is consistent with the provisions of Townley's Privacy
Policy.
For More Information
For more information, please contact our
Privacy Officer at 604-299-7482 (if you are located outside the Lower Mainland of
British Columbia, call 1-800-663-1356) or by e-mail at
privacyofficer@datownley.com.
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