Privacy Policy

THE WILLIAMSON GROUP PRIVACY POLICY:

THE WILLIAMSON GROUP has been in business since 1977, and has long practised confidentiality in the handling of all personal information it has collected from clients. TWG uses the information gathered solely to provide the services for which it has been retained. These services include:

  • Providing group employee benefit consulting

  • Group retirement consulting

  • Actuarial consulting

  • Pension administration

  • Benefits administration & benefit outsourcing services

  • Health & disability management

  • Individual financial planning

  • Group and individual life insurance.

This Privacy Policy has been based on the Canadian Standards Association Model Code for the Protection of Personal Information, and the Federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). It addresses how the staff, Officers and Directors of TWG intend to collect, use, and disclose Personal Information in the context of these principles. This policy reflects TWG's commitment to the privacy of our clients' Personal Information. TWG's collection, use and disclosure of their staff's Personal Information is dealt with in a separate policy. TWG may disclose Personal Information to any individual or organization for services that are provided to assist us in the conduct of our mandate, including an individual or organization that performs services on our behalf, but only if that individual or organization agrees to use the Personal Information solely for the purposes of performing tasks on behalf of, and under the instruction of, TWG and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Privacy Policy.

In order to be certain that you are aware of the scope of the information to which our Privacy Policy refers, please note the following definition (as defined in PIPEDA):

Personal Information: Means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal Information includes personal health information with respect to an individual, whether living or deceased.

Personal Information for the purpose of this policy shall not include information disclosed as aggregate data. Aggregate data for the purpose of this policy, refers to data that does not reveal, and cannot be manipulated to reveal, member-specific information.

1. ACCOUNTABILITY

The Personal Information TWG collects, or is provided, is used and disclosed for the purposes of conducting the services for which we are retained. As part of the employment process, our staff, Directors and Officers will sign a confidentiality agreement which outlines TWG's expectation of its employees to act responsibly in the handling of client information.

In order to further affirm our commitment to maintaining the confidentiality and privacy of our client's personal information, we have done the following:

  • TWG's management has developed and adopted this Privacy Policy
  • TWG has assigned a Privacy Officer on matters of privacy relating to TWG's use, disclosure, security and retention of personal or personal health information
  • TWG's Privacy Officer will also be responsible for maintaining this policy and updating staff on changes to both privacy legislation and business practices
  • TWG will update all staff on privacy related issues and legislation

2. IDENTIFY THE PURPOSE

TWG collects personal information in the course of providing services to our clients. The following is an example of circumstances in which TWG may be provided, or required to collect, personal information:

  • Individual claim assessments, legal processes and claim payment
  • Employer provided pension plan administration, pension calculations and payments, and actuarial costings
  • Administration and consulting for employer provided life and health benefit plans
  • Integrated health and disability management
  • Group and personal life insurance consulting
  • Financial planning consulting

3. OBTAIN CONSENT

Consent to use personal information is required to be obtained at the time of its collection. If TWG collects the personal information directly from an individual, TWG will obtain express consent for the collection, use and disclosure of such information. However, TWG may be contracted by employers to provide third party administration of employer sponsored pension or life and health plans. In these cases, personal information may be collected by another party before it is provided to TWG. Where possible in these circumstances, TWG will take reasonable measures to require that consent for their use of the personal information has been obtained.

If TWG uses personal information it has collected, or has been provided, for any reasons other than those disclosed to an individual at the time consent was given, then TWG will seek to obtain consent for the new use of the information.

4. LIMIT COLLECTION

TWG limits its collection of personal information to that which is reasonably required to accurately complete the services for which we have been retained. We are committed to respecting the privacy of an individual's personal information and will not collect personal information which is not reasonably required.

5. LIMIT USE, DISCLOSURE AND RETENTION

TWG limits its use and disclosure of personal information to the purpose(s) described at the time the information is collected. TWG retains personal information it collects only as long as is necessary to completely fulfill our services. TWG maintains a records retention policy. The retention policy has been developed to meet TWG's record retention requirements and is consistent with good business practices and known industry standards. In the event that TWG decides to purchase, sell, reorganize or transfer the assets of a business, including any Personal Information held by that business, TWG's client information may be subject to review for such purpose by another party. Should TWG or such other party wish to use any Personal Information for purposes not described herein, then consent for such use of the information will first be obtained

Note: As is the case with all companies, TWG may be lawfully bound to disclose personal information for purposes other than those described at the time consent was obtained. These purposes have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

6. BE ACCURATE

TWG recognizes that personal information can change. We encourage our clients to keep their personal information current so that we may provide the best services possible. If we are working with a company to manage a company sponsored benefit or pension plan, employee members will be required to inform their employer of any changes to their personal information. Where we have a direct client relationship, personal information can be changed as directed by our staff upon inquiry by email, phone or fax.

Within a reasonable time of being notified, TWG will update member records to reflect changes in personal information.

7. USE APPROPRIATE SAFEGUARDS

TWG has inventoried the various ways in which we store personal information, and has taken reasonable measures to ensure the security of this information within our premises and in our system databases.

Furthermore, TWG will require its staff to sign a confidentiality agreement within which is detailed the firm's expectation that staff will respect and safeguard client information. Through this agreement, employees are aware that a breech of confidentiality could result in termination of their employment.

8. BE OPEN

TWG's Privacy Officer is mandated to ensure that our Privacy Policy and internal Security and Record Retention Policies are maintained.

Should you wish to question why specific information is required; our Privacy Officer is available to answer any such inquiries.

In all matters of privacy, including access requests and privacy concerns, we encourage our clients to contact our Privacy Officer, Duff Williamson at: duff@williamsongroup.com

9. GIVE INDIVIDUAL ACCESS

It is extremely important for clients to know that they have access to their personal information. Requests for personal information held by TWG or corrections to such information can be made by contacting the sponsoring employer or, in the case of direct client relationships, personal information can be requested or corrected by contacting our Privacy Officer by email, phone or fax. In response to such requests, TWG will correct or provide that personal information which can be corrected or retrieved at a reasonable cost to TWG or the sponsoring employer, and will do so in a timely manner. In order to guard against fraudulent requests for access, TWG will require sufficient information to allow us to confirm the identity of the person making the request before granting access or making corrections.

Note: As is the case with all companies, TWG may be lawfully bound to deny access of an individual to their personal information. Reasons for such a denial have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

10. PROVIDE RECOURSE

TWG will review any and all concerns over privacy matters that are submitted to TWG. Privacy concerns are managed by our Privacy Officer, who provides both a response to the concern as well as contact information for regulatory authorities. TWG's Privacy Officer will use any concerns to assist in measuring the effectiveness of our Privacy Policy, as well as our business practices. Amendments to our Privacy Policy will be described on our website, alongside the updated policy. Whether or not Personal Information already collected and used at TWG will be affected by any such amendments, will also be discussed on our website alongside the notice of the change.

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