Our Privacy Policy

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 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 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 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
4250 Canada Way
Burnaby, British Columbia
V5G 4W6

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.

For More Information

For more information, please contact Pacific Blue Cross and D.A. Townley’s Privacy Officer at 604-419-2000 or toll-free 1-877-722-2583) or by email privacyofficer@pac.bluecross.ca.