The management of personal information is fundamental to Morneau Shepell’s services and we are committed to protecting your privacy.
Morneau Shepell collects and uses personal information to identify you, establish eligibility, and to provide technology-enabled total health, wellbeing and human resources services (such as pensions and benefits, employee assistance programs, and health management programs), including through our websites and apps. We also use your information for our own purposes, including to analyze and improve our services and for communications.
- What personal information we might collect about you;
- What we might do with that personal information; and
- Your choices about the personal information you provide.
This policy covers our websites, mobile apps, services provided through these platforms or otherwise accessed by a user (such as our counselling and wellbeing services) and any other interactions you may have with us (by telephone, email, or in person). This policy specifically covers our handling of personal information relating to identifiable individuals, and does not apply to proprietary business information.
Some of our services are provided on behalf of our clients, which means our client remains primarily responsible for your personal information. For instance, we may be providing services on behalf of your employer or plan sponsor. In these circumstances, we may re-direct a query about our use of your personal information to our client.
Getting Your Consent
You can withhold or withdraw your consent for us to collect, use or share your personal information, as long as there are no legal or contractual requirements for us to process your information. Depending on the circumstances, however, withdrawal of your consent may impact our ability to serve you, or in the case of administering benefits, it may prevent us from processing your claims.
Where We Get Your Information
We collect personal information in the following ways:
- Directly from you;
- From your use of Morneau Shepell’s services, programs, websites and apps;
- From your employer, association, insurer or benefits plan sponsor;
- When you attend a Morneau Shepell site or event;
- When you apply for a position at Morneau Shepell;
- If you contact us with a complaint or query;
- When you engage with us over social media; and/or
- From legally authorized third parties.
We will not knowingly collect, use or share personal information if you are under the age of majority in your area without the permission of your parent or guardian. If you are under age and want to access our counselling and wellness services, your parent or guardian needs to contact Morneau Shepell on your behalf.
What Information We Collect and Why
Our collection and use of your personal information depends on what products and services your sponsoring organization chooses to make available to you, which Morneau Shepell products and services you choose to participate in, and what information you choose to provide to us.
We may collect and use the following types of information for the following purposes:
|Personal Information Category||Types of Information We May Collect||How We May Use It|
|Identity information||Your name, username, employee number or similar identifier, marital status, date of birth and reported gender||
|Contact information||Your billing address, postal address, email address and telephone numbers||
|Employment information||Your job title, place of work, hire date, employment history, work address||
|Financial information||Your banking information, email linked to your electronic transfers, and payment information||
|Transaction information||Details about payments to and from you, and other details of products and services you have purchased from us, including customer account numbers||
|Health information||The state of your physical and/or mental health which we receive in connection with your use of our services, through connected devices or through any health risk assessment you complete||
Your weight, height, body mass index, waist circumference, cholesterol, lipoprotein, triglycerides, glucose and blood pressure readings, sleep patterns or other similar information provided by you or collected by your devices or wearables
|Lifestyle information||Your alcohol consumption, tobacco/nicotine use, eating and nutrition (e.g., number of servings of food groups and nutrition related questions), cardiovascular disease risk, emotional wellbeing (e.g., depression and stress), and readiness to change||
|Claims information||Information disclosed to us with your permission by your insurance, health plan provider, or plan sponsor regarding claims you have made under your policy and/or other information, including health information||
|Interaction information||Telephone recordings and transcripts, records of communications (emails, letters, online chat etc.)||
|Digital interaction information||Geolocation data, IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system (including the type of device used) and other technology, related to the devices you use to access our websites and/or our apps||
|Job Applicant Information||Résumé, cover letter, reference letters, employment history and interests||
We may also collect and use your information to:
- Perform services on your behalf or your employer’s/benefits sponsor’s behalf (including total health and wellbeing, rewards and recognition services, employee and family assistance services, health management programs, group benefits and investment plans, and pension administration services);
- Understand your needs, the suitability of our products and services, and assess future needs;
- Provide services tailored to your requirements and to treat you in a more personal way;
- Promote and market our products and services to you;
- Improve our business operations and the quality of our products and services;
- Develop and test new products and services;
- Manage our business and operational needs;
- Administer and protect the security of our business, and our websites, apps and other services;
- Meet our legal and regulatory obligations, including to enforce our legal rights; and
- Carry out other purposes related to any of the above.
De-identified, Aggregated, and Anonymized Information
We may use your personal information to generate de-identified, aggregated or anonymized information that does not reveal your identity. Morneau Shepell uses this information to conduct research, compile aggregate data sets, statistics and reports, and to perform analytics on our services, service standards, business operations, and trends.
We may share de-identified, aggregated or anonymized information with our clients for reporting purposes, including usage of our services, and with third party service providers for use in creating marketing materials, cases studies and statistical analyses. This allows Morneau Shepell, its clients and our respective third‑party service providers to understand how we are performing, or develop relevant products, services or offers.
When Does Morneau Shepell Share Your Personal Information?
Morneau Shepell may share your personal information with:
- Other Morneau Shepell entities in order to serve you, including for our internal management and administrative purposes.
- Third‑party service providers who are required to keep your information confidential and secure and are restricted from using or disclosing information for reasons other than performing services on our behalf or to complying with legal requirements.
- Third parties and partners in the event of a potential merger or acquisition, transfer of assets, reorganization or bankruptcy. These parties are also required to keep your information confidential and secure and are restricted in their use of information to this purpose.
- Government, regulatory and law enforcement agencies to meet our compliance, regulatory, and risk management obligations or to comply with the law.
- The general public and other users when you post or share comments, blog postings, testimonials, or other similar information on our technology platforms
- Your sponsoring organization or health plan provider when you provide your express or implied consent or if we are required to do so by law.
International Transfers of Information
Morneau Shepell is a global organization with affiliates, partners and subcontractors located in many countries around the world. To provide our services to you, Morneau Shepell may exchange personal information across geographical borders with Morneau Shepell entities, affiliates or service providers in other countries working on our behalf in accordance with applicable law.
Examples of countries we transfer and exchange personal information with include, but are not limited to, the United States of America, the United Kingdom, Canada and Australia.
Storage of Your Information
Morneau Shepell may store your personal information in its databases located in the United States, Canada, the United Kingdom or other countries. Some of our service providers may also store or access personal information from countries other than where you reside or receive services, and in those circumstances, are subject to the laws of that jurisdiction. Because of this, there may circumstances where other foreign governments, courts, law enforcement agencies or regulatory agencies are entitled to access the personal information collected and held by Morneau Shepell or our sub-contractors.
If you are visiting our website from a country other than Canada, your communication through our website or any of our services may result in the transfer of information across international boundaries. By using our website or any of our services, you consent to the collection, storage, and processing of your information in Canada and other countries (including the United States, the UK and Australia) in accordance with applicable data protection legislation.
Retention of Your Information
We only keep your information as long as it is contractually, operationally or legally necessary. When we no longer need the information, it is either destroyed or de-identified.
We use reasonable physical, technological, organizational and contractual safeguards, appropriate to the sensitivity of the information, to protect personal information in our possession or under our control, from unauthorized access, disclosure or use.
Accessing Your Information
When requested in writing, we will inform you of the existence, use, and disclosure of your personal information that we maintain. We may not be able to provide you with all the information you request, depending on the circumstances, and there may be a charge for copies of your personal information.
Correcting Your Information
We will make reasonable efforts to keep your information accurate and up-to-date. If a change or correction is required, let us know right away. We’ll make appropriate updates needed to keep things running smoothly. You can review your personal information by looking at the correspondence we send to you, through your online accounts with us, or by requesting access to your personal information, as described above.
If you have any questions or concerns about this policy or Morneau Shepell’s handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Officer
Morneau Shepell Ltd.
895 Don Mills Road
Tower One, Suite 700
Toronto, ON M3C 1W3
By electronic mail: firstname.lastname@example.org
Please note that we may need to confirm your identity, request additional details and work with other Morneau Shepell departments to respond to you or to look into your concerns or complaint.
We may modify this notice from time to time and will post the most current version online.
Last updated: March 2020