The term “Personal Information” refers to any information about an identifiable individual or any information that allows an individual to be identified. Personal Information includes: (a) your name, home address, age, personal email and personal telephone number; (b) your Social Insurance Number; (c) any credit card information you provide; (d) any financial information that you provide or that becomes known to Bright Benefits; (e) your Bright Benefits plan number; and (f) other information that specifically identifies you as an individual.
In general, Personal Information does not include your business contact information, such as your name, title or position, business address, business email address, business telephone or fax number.
Bright Benefits collects, uses and discloses your Personal Information with your knowledge and consent (which may be either express or reasonably implied) and only for purposes that we have identified prior to or at the time we collect the Personal Information. Some of the purposes for which Bright Benefits may collect, use and disclose your personal information are as follows:
By submitting your Personal Information to Bright Benefits, you signify your consent to the collection, use and disclosure of your Personal Information in accordance with this Policy. If you do not consent to the collection, use and disclosure of your Personal Information in accordance with this Policy, please do not provide any Personal Information to us. Of course, certain services can only be offered to you if you provide Personal Information to Bright Benefits, and therefore Bright Benefits may not be able to offer you those services if you choose not to provide us with the required Personal Information. Bright Benefits will not obtain consent through deceptive or misleading practices.
Bright Benefits only collects the Personal Information that is necessary and appropriate for the identified purposes. Bright Benefits will not use or disclose your Personal Information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.
We will not sell, trade, lend or otherwise voluntarily disclose to any third parties any Personal Information that you have provided to us for any purpose not identified under this Policy. We may share your personal information with third parties to assist us in administering services which you have requested and to our professional advisors or otherwise for legitimate and reasonable purposes for which we have obtained your prior consent.
Bright Benefits may disclose your personal information to a government or regulatory entity that has asserted its lawful authority to obtain the Personal Information or to comply with an order made by a court, person or body with jurisdiction to compel the production of information.
Bright Benefits has policies in place that govern the retention of Personal Information only for as long as deemed necessary for the identified intended purposes for which it was originally collected or as legally required.
You may withdraw your consent to the use and disclosure of your Personal Information by Bright Benefits. To do that, please contact our Privacy Officer as outlined below. Please note however, that as noted above, certain services can only be offered to you if you provide Personal Information to Bright Benefits, and therefore Bright Benefits may not be able to offer you those products or services if you choose not to provide us with required Personal Information. Additionally, once Bright Benefits has entered into a contract with you, you may not be able withdraw your consent until such time as the obligations under such contract have been fulfilled. This is necessary since we may be required to use your Personal Information in the normal course of administering any contract that you have entered into with Bright Benefits.
Bright Benefits maintains appropriate safeguards to protect the confidentiality of all Personal Information that it receives. All Personal Information received is held in a secure manner regardless of the format in which it is held. Bright Benefits has comprehensive security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of Personal Information. All Personal Information received by Bright Benefits in an electronic format is stored on servers located in Canada.
You may request access to your Personal Information or information about Bright Benefits’ collection, use and disclosure of that information by contacting our Privacy Officer, in writing, at the address identified below. Subject to certain exceptions prescribed by law, you will be given reasonable access to your Personal Information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include information that is prohibitively costly to provide, information that contains references to other individuals, and information that cannot be disclosed for legal, security or commercial proprietary reasons.
Bright Benefits has policies and procedures to receive, investigate, and respond to your complaints and questions with respect to this policy. Such questions or concerns should be directed to the Company’s Privacy Officer by e-mail (firstname.lastname@example.org) or by mail (855 Arcola Avenue, Regina, Saskatchewan S4N 0S9). Further documentation or information may be asked for at the time of the request to verify your identity.
This policy will be reviewed at least annually by Bright Benefits’ Governance Committee, to ensure that the procedures remain consistent with regulatory requirements, and with overall goals and objectives of Bright Benefits. The Policy may only be changed by the approval of Bright Benefits Board of Directors.