Gallivan & Associates Student Networks, hereafter referred to as Gallivan & Associates, follows the guidelines set out by the Privacy Commissioner and the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and related provincial legislative Acts. This policy applies to all records in the care, custody and control of Gallivan & Associates.

Gallivan & Associates is committed to protecting the privacy of their clients. The regulation of collection, storage, utilization and dissemination of personal information concerning its members and clients is part of Gallivan & Associates ongoing efforts to ensure the decisions concerning individuals is based on accurate information, that information is gathered for the purpose of providing service to our clients and is not used inappropriately, and that clients’ personal information is not disclosed to third parties outside the guidelines of the PIPEDA.

Personal information is information about an individual that allows the individual to be identified but does not include the individual’s business contact information (name, business title, business phone, email or fax number). Gallivan & Associates uses fair and lawful means to collect clients’ personal information and will only collect such personal information from our clients that is pertinent and consistent with legitimate business purposes set out in this privacy policy, required by law or otherwise explained to a client at the time of the collection. Whenever practical, we will collect the required information directly from our clients, or from clients’ authorized representative(s).

In general, we collect such personal information as a client’s name, address, telephone number(s), student number and or date of birth to:

• confirm the identity of the client;
• protect both the client and Gallivan & Associates against errors, fraud or other misrepresentations;
• determine the client’s eligibility for health and dental plans; and
• to properly administer such health and dental plans to and for the client.

Access to our clients’ personal information is restricted to those directors, officers, employees, licensed representatives, and other persons or organizations acting for, or on behalf of Gallivan & Associates, who are bound by an obligation to Gallivan & Associates to maintain the confidentiality of the information and who require access to the information in the care, custody and control of Gallivan & Associates in order to provide services to our clients at the optimal level.

The principals underlying Gallivan & Associates’ approach to the collection, use and disclosure of our clients’ personal information are:

• Individuals, generally, should have the right to access the personal information collected, used and disclosed by Gallivan & Associate on their behalf in order to ensure it is complete, accurate and up to date;
• The collection, retention, use and disclosure of personal information contained in Gallivan & Associates records should be administered by Gallivan & Associates in a manner that will protect the privacy of individuals who are the subject of such information;
• Gallivan & Associates should seek individuals’ informed consent, whether implied or express, prior to the collection, use or disclosure of the individuals’ personal information; and
• There should be methods for resolving differences concerning privacy protection matters and concerns about access to information.

Where personal information is tied in with non-personal, non-confidential information Gallivan & Associates makes every reasonable effort to sever and protect the personal information from unauthorized disclosure. Gallivan & Associates shall refuse to disclose records, except where required by law, where disclosure would reveal confidential personal information without the informed and meaningful consent of the individual to whom the confidential information pertains.

Gallivan & Associates only collects, records, uses and discloses such personal information as is reasonably necessary for the proper administration of services. Gallivan & Associates will obtain an individual’s informed consent, whether implied or express, to whom the information relates:

• to the use and/or disclosure of the personal information by Gallivan & Associates;
• to the consistent or one time use or disclosure of the personal information for the purpose for which the personal information was obtained
• for the compilation of aggregate data;
• to the disclosure of personal information to an officer or employee of Gallivan & Associates who needs the information in the performance of his/her duties;
• to the use or disclosure of personal information where the use and/or disclosure of the information is necessary and proper in the discharge of Gallivan & Associates functions and responsibilities;
• to the disclosure of personal information for the purpose of complying with a requirement to provide information lawfully imposed on Gallivan & Associates by a federal or provincial governmental authority; and
• to the disclosure of personal information pursuant to a court order or other legal means of compulsion, disclosure is to a law enforcement agency or institution in Canada.

Gallivan & Associates will take reasonable precautions to protect the security of records containing personal information, will retain such information only for reasonable periods of time and will make arrangements for the secure disposal and destruction of such records when that period has expired.

Gallivan & Associates will ensure that personal information is:

• collected and retained only as authorized under the PIPEDA and other privacy legislation;
• used only for the purpose for which it is collected or a consistent purpose for providing service to clients;
• accurate and up-to-date; and
• protected by appropriate security measures, and that the appropriate policy and procedure is in place to reflect these principles.

A physical client record containing a clients’ personal information is maintained while the client is enrolled as a student, an electronic copy of a client’s record is retained for seven (7) years. When an enrollment break of two (2) years has elapsed the physical record is destroyed. Any part of the physical and/or electronic client record that is redundant is destroyed.

If a client is unable to access their records at the Benefit Plan Office, requests for access to records must be made in writing to the Privacy Officer at the contact information provided below. Access granted will normally be in the form of a copy of the record in question. Individual administrative officers are responsible for responding to requests from the Privacy Officer for access to or disclosure of information from records under their control.

Privacy Principles

Accountability:
We strive to protect clients’ personal information used to establish and maintain clients’ benefits. We continue to develop and implement policies and practices within Gallivan & Associates for the security of clients’ information provided to us.

Purposes:
The information that we collect is only used to establish and maintain benefit coverage and to communicate coverage information to the client.

Consent:
Gallivan & Associates collects clients’ personal information, and in turn provides same to the institution and/or the Benefit Plan Office with clients’ informed consent whether implied or express.

Collection:
Only information that is relevant to a client’s benefit plans is collected.

Use, Disclosure, and Retention:
Information is used only for the benefit plans and is only disclosed to those parties directly involved in providing these benefits. Retention is only as long as necessary to fulfill contractual obligations to the client or as required by law.

Accuracy:
Every effort is taken to sustain information accuracy.

Safeguards:
We protect our clients’ personal information with established safeguards appropriate to the sensitivity of the collected information.

Openness:
The Privacy Officer for Gallivan & Associates will answer any inquiries within the allotted time frame should you need information regarding our practices.

Individual Access:
The client can gain access to their information at the Benefit Plan Office and through Gallivan & Associates Head Office in Waterloo, Ontario.

Concerns, Inquiries, and Requests:
If for any reason your questions cannot be answered in regards to your personal information held at the Benefit Plan Office you may send an inquiry with your institution name and student identification number to Gallivan & Associates Privacy Officer, via email at privacyofficer@gallivan.ca or mail to:

Privacy Officer
Gallivan & Associates Student Networks
Suite 206, 470 Weber Street, North
Waterloo, Ontario
N2L 6J2