Privacy Notice- Canada

Privacy Notice – Canada

This Privacy Notice describes how ComPsych Canada Ltd. (“ComPsych” or “we”) collects and processes personally identifiable information (“Personal Data”) about you when you access ComPsych’s Employee Assistance Program Services (“Services”). The information you provide to us will be recorded and stored on ComPsych’s network system located in the United States and it will be subject to United States law, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in the United States.

Purposes and Categories of the Information We Process About You

We process your Personal Data, which we collect from you directly and indirectly when you inquire about, access, and use the Services, and indirectly from third parties, such as your employer, for the purposes set out below. If you do not provide us with Personal Data when registering for Services, we may not be able to offer the Services to you. 

Purpose of Processing	Categories of Personal Data
To provide you with the information and Services offered by our Employee Assistance Programs, including our library of wellness resources, our “Guide Me” capability, our “Assess Me” capability and to connect you with health care providers where requested via the “Connect Me” capability	Name Contact details Username Password Information about your employer Information you provide on your health and wellbeing Information collected automatically when you access our websites, such as your IP address and internet or other electronic network activity information
To provide you with a personalized experience when using ComPsych Services	Name Contact details Username Information about your employer Information you provide on your health and wellbeing Information collected automatically when you access our websites, such as your IP address and internet or other electronic network activity information
To assess and improve the quality of ComPsych Services, including to assess product use, completion rates and other internal business aspects, as well as the quality of our website.  For example to assess how to improve website navigation and user interfaces, to assess what Services are best meeting user interests, and to troubleshoot identified issues.	Username Information about your employer Information you provide on your health and wellbeing Information collected automatically when you access our websites, such as your IP address and internet or other electronic network activity information
To provide customers with reports on usage rates, trends and outcomes, based on aggregated data	Information you provide on your health and wellbeing Information collected automatically when you access our websites, such as your IP address and internet or other electronic network activity information
To provide customer friendly Services, including to address security, health and safety concerns and to provide technical support	Name Contact details Username Password Information you provide on your health and wellbeing Information collected automatically when you access our websites, such as your IP address and internet or other electronic network activity information
To pursue business-related purposes, including to investigate, prevent or take action regarding (suspected) illegal activities, safety concerns, or violations of ComPsych polices, in the context of any litigation, the planning and implementing of potential mergers and acquisitions and the resolving of billing disputes with customers	Name Contact details Information about your employer Information you provide on your health and wellbeing Information collected automatically when you access our websites, such as your IP address and internet or other electronic network activity information
To comply with our legal obligations under applicable laws and regulations, including with our governmental reporting and tax requirements	Name Contact details Information about your employer Information you provide on your health and wellbeing Information collected automatically when you access our websites, such as your IP address and internet or other electronic network activity information

For the processing of information you provide on your health and wellbeing and inferences regarding your characteristics (“Special Category Personal Data”) we will rely on your “explicit consent” where required by applicable laws. You can contact us using the details in the “Data Subject Rights” section below for more information.

Where required by applicable laws, we process (Special Category) Personal Data on the basis of your (explicit) consent, as provided by you by your affirmative action in the form of clicking a checkbox or other form of (explicit) consent. When we process your (Special Category) Personal Data on the basis of your (explicit) consent, you may withdraw that (explicit) consent at any time by contacting our Privacy Official.  Such withdrawal of consent will not affect the lawfulness of processing conducted before the time of withdrawal. If you withdraw your consent, we may still be required to process your (Special Category) Personal Data to comply with applicable laws, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.

In addition to the right to withdraw your consent, you have the right to access and correct your Personal Data. To exercise your rights contact our Privacy Official.

We may also anonymize your information in such a way that you may not reasonably be re-identified by us or another party, and we may use this anonymized data for the purpose of providing customers (your employer) with reports on usage rates, trends and outcomes, based on aggregated data as described above. To the extent we anonymize any data originally based on (Special Category) Personal Data we will maintain and use such information in anonymized form and will not attempt to reidentify the data.

ComPsych does not share your Personal Information with third party marketers and will not reveal your Personal Information to your employer unless you explicitly consent to such.  

ComPsych implements technical and organizational measures to protect your Personal Data against unauthorized or unlawful use, processing and disclosure, and accidental loss or destruction. Including: (1) the use of identity and access management technologies to control access to systems on which information is processed and stored; (2) the encryption of your personal information in transit via Transport Layer Security 1.2 (TLS 1.2) and AES 256 at rest; (3) requiring all employees to comply with internal information security policies and keep information secure; (4) requiring all employees to complete training about information security; and (5) monitoring and regularly reviewing our practice against our own policies and against industry best practice.

We retain your Personal Data until we no longer need it to fulfil the purposes for which it was collected. However, we may retain your Personal Data for a longer period when required to comply with our legal and regulatory obligations regarding information or record retention.

To exercise your rights related to your Personal Data, or if you have any questions about ComPsych’s privacy practices or the processing of your information please contact our Privacy Official by sending an e-mail to [email protected].