Privacy Statements

Principle #1: The Caregiver Canada Inc.’s Accountability

The Caregiver Canada Inc. is accountable for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions. Caregiver Canada Inc. has established policies and procedures to comply with this code, and has designated one or more persons to be accountable for compliance.

1.1 The Caregiver Canada Inc.’s senior management has accountability for protecting its customers' personal information. Senior management, however, delegates the day-to-day procedures of compliance to others.

1.2 The Caregiver Canada Inc. is accountable for personal information in its possession or custody that is disclosed to a third party for processing or other administrative functions. The Caregiver Canada Inc. will safeguard this personal information through means such as a contract or other agreement with the relevant third party.

1.3 To practice the principles of this code, the Caregiver Canada Inc.:

  • Has policies and procedures to protect the privacy of personal information.
  • Has policies and procedures to receive and respond to customers' questions and complaints.
  • Informs customers and staff of the Caregiver Canada Inc.’s policies and procedures.
  • Trains staff to understand and follow the Caregiver Canada Inc.’s policies and procedures

The Caregiver Canada Inc. also oversees compliance with these policies and procedures through normal risk-based cyclical audits, and through compliance policies and procedures.

Principle #2: Identifying the Purposes of Collecting Personal Information 

The Caregiver Canada Inc. will identify the purposes for which it collects the personal information, before or when the information is collected.

2.1 Except as noted below, when a customer applies for a product or service, the Caregiver Canada Inc. will make sure the customer is made aware of:

  • Why the Caregiver Canada Inc. needs the personal information it is requesting.
  • How the personal information may be used with customer consent for other purposes.
  • The fact that the customer can refuse at any time permission for the Caregiver Canada Inc. to use personal information for these other purposes.

In some cases the Caregiver Canada Inc. may not explain or obtain customer consent for the other purposes for which the information has been collected. See 3.4, 3.4.1, and 5.1 for details.

 

2.2 The Caregiver Canada Inc. will collect and use personal information for only the following purposes:

  • To understand the customer's needs.
  • To analyze the suitability of our products or services for the customer.
  • To determine the customer's eligibility for our products and services.
  • To set up, manage and offer products and services that meet the customer's needs.
  • To provide ongoing service.
  • To meet legal and regulatory requirements.

2.3 The Caregiver Canada Inc. will identify the purposes for which it intends to use the personal information, in writing, orally in person or over the telephone, electronically or by any other alternative format or means it uses to communicate with its customers. The Caregiver Canada Inc. will use words that customers can easily understand.

2.4 Caregiver Canada Inc. staff who collect personal information will be able to explain the purposes to customers. Customers will also be able to ask for information about the purposes when they write to the Caregiver Canada Inc.

2.5 The Caregiver Canada Inc. will take care to explain all the purposes for which personal information is collected by that member including any purposes which may not appear to be as obvious as others. The purposes for collecting a name or address are obvious and do not need to be explained, but the purposes for collecting other information may not be obvious. For example as appropriate in the circumstances, the Caregiver Canada Inc. will tell customers that:

  • References are used to verify information on an application.
  • Personal information, including without limitation, the customer's age, used to determine the appropriateness of service for an individual.

 

Principle #3: Getting the Customer's Consent

 

The Caregiver Canada Inc. will make a reasonable effort to make sure customers understand how the personal information will be used by the Caregiver Canada Inc.

A customer's consent can be express, implied, or given through an authorized representative. A customer can withdraw consent at any time, with certain exceptions.

The Caregiver Canada Inc., may however collect, use or disclose personal information without the customer's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.

3.1 The Caregiver Canada Inc. will make a reasonable effort to make sure customers understand how the personal information will be used and disclosed by the Caregiver Canada Inc. It will get the customer's consent before or when it collects, uses, or discloses personal information.

Generally, the Caregiver Canada Inc. will seek consent to use and disclose personal information at the same time it is collected. Sometimes, however, the Caregiver Canada Inc. may identify a new purpose and it will seek consent to use and disclose personal information for that purpose after the information has been collected.

 

3.2 The Caregiver Canada Inc. will not attempt to deceive customers into giving consent. It will explain to customers how personal information will be used before they give their consent.

3.3 Customers can express consent orally, in writing or electronically. They can imply consent through action or inaction. They can also give consent through an authorized representative. Express consent is the preferred form.

 

Customers can express consent:

  • Orally, such as when information is collected over the telephone.
  • In writing, such as when completing and signing an application.
  • Electronically, such as when applying through a computer or electronic communicating device.

Customers can imply their consent by:

  • Using a Caregiver Canada Inc. product or service.
  • Not responding to the Caregiver Canada Inc.’s offer to have their personal information removed from a direct marketing list. In this case, the Caregiver Canada Inc. may assume that the customer consents to the use of the personal information. 

Before deciding what form of consent is appropriate, the Caregiver Canada Inc. will consider the type of personal information it needs, the reason for its use, and the type of customer contact that is involved.

3.4 The Caregiver Canada Inc. can’t collect or use personal information without the knowledge and consent of the customer in exceptional circumstances where such collection or use is permitted or as required by law.

For example the Caregiver Canada Inc. will not ask for consent when personal information is collected used, or disclosed in instances, such as:

  • In the clear best interests of the customer and consent cannot be obtained in a timely way.
  • When asking for consent may compromise the information sought and collection relates to an investigation of a breach of an agreement or a contravention of Canadian laws, as for example to detect and prevent criminal activity and dealings in proceeds of crime.
  • The Caregiver Canada Inc. will not ask for consent when personal information is collected or used if it is regulated public information.

When the Caregiver Canada Inc. obtains customer lists from another regulated organization, the Caregiver Canada Inc. will assume that the organization providing the personal information obtained each customer's consent before disclosing the information to the Caregiver Canada Inc.

 

3.4.1 The Caregiver Canada Inc. can disclose personal information without the knowledge and consent of the customer in exceptional circumstances where such disclosure is permitted or required by law. For example the Caregiver Canada Inc. will not ask for consent when personal information is:

  • Given to agents of the Caregiver Canada Inc. who need it to carry out business-related functions, such as fulfillment (e.g. mailing follow-up information packages), data processing or the printing of cheques and credit cards.
  • Given to its legal representatives.
  • Disclosed for the purpose of collecting an overdue account. 
  • Disclosed in order to:
    • comply with a subpoena or warrant.
    • respond to a lawful authority for lawful purposes.
    • facilitate the activities of an investigative body or government institution in dealing with a past, potential or actual breach of an agreement or contravention of the laws of Canada or a province or a foreign jurisdiction; or
    • comply with the law;
    • disclosed if it is regulated public information.
    • (for insurance products) transferred to other insurance companies that share the risk

 

3.5 Subject to legal and contractual restrictions, customers can refuse or withdraw consent at any time as long as:

  • The Caregiver Canada Inc. is given reasonable notice of the withdrawal.

The Caregiver Canada Inc. will let the customer know the consequences of refusing or withdrawing consent when customers seek to do so. Refusing or withdrawing consent for the Caregiver Canada Inc. to collect, use or disclose personal information could mean that the Caregiver Canada Inc. cannot provide the customer with some product, service or information of value to the customer.

The Caregiver Canada Inc., however, will not unreasonably withhold products, services or information from customers who refuse or withdraw consent.

 

Principle #4: Limits for Collecting Personal Information

 

The Caregiver Canada Inc. limits the amount and type of personal information it collects. Caregiver Canada Inc. will collect personal information for the purposes it identifies to the customer. The Caregiver Canada Inc. collects personal information using policies and procedures which are fair and lawful.

The Caregiver Canada Inc. will collect only the amount and type of information needed for the purposes documented by the Caregiver Canada Inc. and identified to the customer.

Principle #5: Limits for Using, Disclosing and Keeping Personal Information

 

The Caregiver Canada Inc. will use or disclose personal information only for the reasons it was collected, unless a customer gives consent to use or disclose it for another reason, or it is permitted or required by law.

 

Under certain exceptional circumstances, the Caregiver Canada Inc. has a legal duty or right to disclose personal information without customer knowledge or consent to protect matters which include the Caregiver Canada Inc.’s or the public interest.

 

The Caregiver Canada Inc. will keep personal information only as long as necessary for the identified purposes for which it was collected.

 

5.1  The Caregiver Canada Inc. may disclose personal information without consent when required by law. For example:

  • subpoenas
  • search warrants
  • other court and government orders
  • demands from other parties who have a legal right to personal information.

5.2 In these circumstances, the Caregiver Canada Inc. will protect the interests of its customers by making reasonable efforts to ensure that:

  • orders or demands appear to comply with the laws under which they were issued.
  • it discloses only the personal information that is legally required, and nothing more.
  • it does not comply with casual requests for personal information from government or law enforcement authorities.

The Caregiver Canada Inc. may notify customers that an order has been received, if the law allows it.
The Caregiver Canada Inc. may notify customers of such orders by telephone, electronic mail or by letter to the customer's last known address.

5.3 The Caregiver Canada Inc. may want to use personal information to market products and services to its customers, either directly or through other Caregiver Canada Inc. or affiliates. The Caregiver Canada Inc. will obtain the consent of the customer before using personal information for this purpose.

 

When a customer applies for a product or service and provides personal information, the Caregiver Canada Inc. will:

  • Tell the customer that this personal information may be used by it or other Caregiver Canada Inc. or affiliates to market other products and services to the customer.
  • Describe the types of Caregiver Canada Inc. and affiliates who might market their products or services.
  • Ask the customer for consent, telling them that this use of personal information is optional.

The first time a new type of Caregiver Canada Inc. or affiliate provides promotional information about its product or service, the Caregiver Canada Inc. or affiliate will:

  • Explain the proposed use of the customer's personal information to the customer.
  • Give the customer an opportunity to withdraw consent for further use of their personal information.

5.4 The Caregiver Canada Inc. specifies in its policies and procedures the periods of time it will keep personal information. Some of these time periods are determined by legislation. If personal information has been used to make a decision about a customer, the Caregiver Canada Inc. will keep the personal information long enough for the customer to have access to it after the decision has been made, subject to any regulated record retention period.

5.5 The Caregiver Canada Inc. will destroy or erase any personal information no longer needed for its identified purposes or for legal requirements.

The Caregiver Canada Inc.’s policies and procedures explain how the Caregiver Canada Inc. will destroy personal information so that unauthorized persons or organizations do not gain access to it.

 

Principle #6: Keeping Personal Information Accurate

The Caregiver Canada Inc. will keep personal information as accurate, complete and current as necessary for the identified purposes for which it was collected.

Customers may, in writing, challenge the accuracy and completeness of their personal information and request that it be amended as appropriate.

6.1 The Caregiver Canada Inc. will make reasonable efforts to minimize the possibility of using inaccurate, incomplete, or outdated personal information to make a decision about the customer.

6.2 The Caregiver Canada Inc. will update personal information only if it is necessary for the purposes for which it was collected. 

6.3 The Caregiver Canada Inc. will make reasonable efforts to keep customers' personal information accurate and current if the information is used on an ongoing basis. This includes personal information disclosed to third parties for processing.

6.4 The Caregiver Canada Inc. will also rely on customers for keeping certain personal information (such as customer addresses) accurate, complete, and current. If a customer shows that personal information is inaccurate, incomplete, out of date, or irrelevant, the Caregiver Canada Inc. will revise the personal information. If necessary, the Caregiver Canada Inc. will disclose the revised personal information to third parties which were provided with the wrong information to revise their records as well.

6.5 If the Caregiver Canada Inc. does not agree to revise personal information as requested by the customer, the customer may challenge the Caregiver Canada Inc.’s decision. The Caregiver Canada Inc. will make a record of this challenge, and if necessary, disclose the challenge to the third parties who also possess the personal information, and advise the customer of the relevant complaint procedure.

 

Principle #7: Safeguarding Personal Information

The Caregiver Canada Inc. protects personal information with safeguards appropriate to the sensitivity of the information.

 

7.1  The Caregiver Canada Inc. safeguards personal information from loss or theft, and from unauthorized access, disclosure, duplication, use, or modification.

7.2  The Caregiver Canada Inc.’s safeguards vary depending on the sensitivity, amount, distribution, format, and storage of the personal information. The Caregiver Canada Inc. gives the highest level of protection to the most sensitive personal information.

7.3  The Caregiver Canada Inc. safeguards personal information through security measures. For example:

  • Physical security, such as secure locks on filing cabinets and restricted access to offices.
  • Electronic security, such as passwords, personal identification numbers, and encryption.

7.4  The Caregiver Canada Inc. informs its staff regularly about the Caregiver Canada Inc.’s policies and procedures for protecting customers' personal information, and emphasizes the importance of complying with them. As a condition of employment, employees are required to conform to the Caregiver Canada Inc.’s policies and procedures.

7.5  The Caregiver Canada Inc. may disclose personal information to third parties for printing cheques, data processing services or administrative services, collection, or for other goods and services. The Caregiver Canada Inc. requires these third parties to safeguard all personal information in a way that is consistent with the Caregiver Canada Inc.’s measures, or as regulated by law.

7.6  As referred to in section 5.5, the Caregiver Canada Inc. uses care when disposing of or destroying personal information, to prevent unauthorized access to the information.

 

Principle #8: Making Information About Policies and Procedures Available to Customers

 

The Caregiver Canada Inc. is open about the policies and procedures it uses to manage personal information. Customers have access to information about these policies and procedures. The information will be made available in a manner that is generally easy to understand.

8.1  The Caregiver Canada Inc. makes available to customers information about the policies and procedures it uses to manage personal information. It also makes available copies of this code.

8.2  Information about the Caregiver Canada Inc.’s policies and procedures and code has been written so that it is generally easy to understand and it is readily available to customers.

 

Principle #9: Customer Access to Personal Information

 

When customers make a request in writing, the Caregiver Canada Inc. will within a reasonable time tell them what personal information the Caregiver Canada Inc. has, what it is being used for, and to whom it has been disclosed.

When customers request it in writing, the Caregiver Canada Inc. will give them access to their personal information. The Caregiver Canada Inc. will respond to the written customer request in a timely fashion. In certain situations, however, the Caregiver Canada Inc. may not be able to give customers access to all their personal information. The Caregiver Canada Inc. will explain the reasons for this lack of access and any recourse the customer may have, except where prohibited by law.

9.1  A customer has the right to know, by written request, what personal information is held by the Caregiver Canada Inc..  

9.2  The Caregiver Canada Inc. will attempt to be as specific as possible about the persons from whom it collected the personal information, to whom it has disclosed the personal information, and how and when the information was disclosed. The Caregiver Canada Inc. will take this information from its records, and will provide it to the customer in a form that is generally easy to understand, providing explanations for abbreviations and codes. The Caregiver Canada Inc. will provide the personal information to the customer within a reasonable time, and for a cost commensurate with the effort to retrieve the information, or at no cost.

9.4  The Caregiver Canada Inc. will not provide the personal information that is in its control if

  • In so doing, it would reveal personal information about a third party and such personal information is not severable from the requesting individual's personal information.
  • It is subject to solicitor-client or litigation privilege.
  • It contains the Caregiver Canada Inc.’s own confidential commercial information and such confidential commercial information is not severable from the requesting individual's personal information. For example, the Caregiver Canada Inc. may use a scoring formula, form an assessment of risk, or make a collection recommendation that is confidential to the Caregiver Canada Inc..
  • In so doing, it would reveal information that would reasonably be expected to threaten the life or security of another individual and such information is not severable from the requesting individual's personal information.
  • It is information that was generated in the course of a formal dispute resolution process.
  • It cannot be disclosed for legal reasons. For example, the Caregiver Canada Inc. may not legally be able to provide the customer with information relating to disclosures to lawful authorities for law enforcement or crime prevention purposes. In some provinces the Caregiver Canada Inc. cannot legally provide a customer's credit bureau report to that customer.
  • It is used for the detection and prevention of criminal activity and dealings in proceeds of crime.

 

Principle #10: Handling Complaints and Questions

The Caregiver Canada Inc. will investigate all complaints and if it finds a complaint justified, the Caregiver Canada Inc. will try to resolve it. If necessary, the Caregiver Canada Inc. will take appropriate measures, including changing its policies or procedures, to ensure that other customers will not experience the same problem.

 

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