Policy Statement

MindWell-U (MWU) is committed to protecting the privacy of personal information. Personal information collected, used, disclosed and retained in the course of business by MWU is governed by our commitment and recognition to our obligation to meet the spirit and terms of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Reason for Policy

MWU recognizes that an individual’s right to privacy is essential. With the development of new information and communication technologies, the ability to collect, record and extract personal information has grown. MWU’s goal is to maintain anonymity and protect personal information that has been collected. Our relationships are founded on trust and we are committed to maintaining that trust. This privacy policy is our guarantee that we will maintain the confidentiality of the personal information entrusted to us.

Responsibilities

Along with the provincial and federal legislation, MWU abides by and practices the national voluntary code, established by the Canadian Standards Association (CSA) International that sets basic principles for safeguarding personal data. CSA International’s Model Code for the Protection of Personal Informational aims to strike a balance between the legitimate information requirements of business, industry and institutions operating in the information age and the privacy rights of individuals. MWU’s interpretation of these 10 principles is outlined below.

Ten Basic Principles

MWU is responsible for personal information under its control and shall designate an individual to be accountable for the organization’s compliance with the following principles.

The purposes for which personal information is collected shall be identified by MWU at or before the time the information is collected.

The knowledge and consent of the individual is required for the collection, use or disclosure of personal information.

The collection of personal information shall be limited to that which is necessary for the purposes identified by MWU. Information shall be collected by fair and lawful means.

Personal information shall not be used or disclosed for purposes other than those for which it is collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of the stated purposes.

Personal information will be as accurate, complete and up-to-date as necessary. You may request a correction of an error or omission in your personal information.

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. MWU is authorized to refuse access to personal information if disclosure would reveal confidential business information. MWU uses appropriate security measures when destroying personal information.

MWU shall make specific information about its policies and practices relating to the management of personal information readily available to individuals.

Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information (provided by them), and shall be given access to that information.

An individual shall be able to address a challenge concerning compliance with the above principles to MWU’s Privacy Officer.

Procedures

MWU employees and subcontractors who collect, maintain, and/or use personal information will do so in accordance with the applicable policies mentioned above. MWU must obtain an individual’s (employee or client) consent when it collects, uses or discloses personal information. MWU follows the following procedures when collecting, using, disclosing or retaining information.

Information Collection and Use

MWU only collects the information it needs in order to maintain a high level of service to you. This information may include: name, e-mail address, as well as group or location organizational category determined by your organization. As well your telephone number, buddy’s email address and other information obtained via surveys is voluntarily provided. We collect and use information only:

• for the purpose for which the information was collected or for a use consistent with that purpose;
• To communicate with the customer and respond to their inquiries
• To deliver course materials in an appropriate manner and medium. Ie, text and email messages.
• Invite a buddy of choice to engage in the training with you.

Data Location

All MWU customer websites are housed in the DigitalOcean data centre in Toronto, Canada. (https://www.digitalocean.com/legal/data-security/) The database, web pages, and business objects reside on a dedicated cloud platform. Support is performed in Ontario, Alberta and British Columbia, Canada by MindWell-U staff and contractors.

MWU reserves the right to aggregate data for comparison purposes. This data provides the capability for program managers to compare results with others in similar industries, location, or other criteria. This provides benefits to all customers.

MWU protects personal information by making reasonable security arrangements against the risk of unauthorized access, use, collection, disclosure or disposal. Personally Identifying Information such as emails/names etc. of participants registered with MWU are not provided to clients.

Contact Information: If you have a question or concern about any collection, use or disclosure of personal information by MWU, or about a request for access to your own personal information, please contact:

Mindwell-U Privacy Officer
Brian Mould
Address: PO Box 49025 Royal Oak Victoria, BC V8Z 0G2
Phone: 1 855 630 7076
E-mail: brian@mindwellu.com

If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of British Columbia:

Office of the Information and Privacy Commissioner of British Columbia Address: 4th Floor, 947 Fort Street, Victoria, British Columbia, V8V 3K3 CANADA
Phone: 1-800-663-7867
Email: info@oipc.bc.ca
Website: https://www.oipc.bc.ca