Privacy Policy

Collecting, using, and communicating personal information are essential in conducting our business as a financial services brokerage and third-party administrative services provider. At ARC Group Benefits Inc. (hereinafter referred to as “ARC”), we attach great importance to protecting the personal information entrusted to us and respecting privacy. We take this responsibility very seriously. To do so, we comply with the Personal Information Protection and Electronic Documents Act and the ten privacy principles based on the Act and the federal government’s electronic documents.

1. Accountability

We assume responsibility for the personal information entrusted to us, including information obtained from a third party or transferred to a third party for processing. We have designated a person to ensure compliance with this policy and applicable privacy laws, regulations, and guidelines. Working in collaboration with individuals responsible for specific business sectors with knowledge of their sector’s privacy needs, she ensures that access to personal information is restricted to those who need it to provide you or your organization with services. She also ensures that these individuals, administrators, officers, employees, representatives holding licenses and any other person or organization acting on behalf of ARC are responsible for protecting your personal information.

We ensure that the suppliers with whom we do business and who must collect, use, or disclose personal information only do so for authorized purposes and in accordance with applicable Standards and Laws in Canada.

2. Purpose of Collecting Information

We will specify the intended use of personal information at the time of collection or before.

This specification can be communicated in writing or verbally, depending on how the information is collected. Individuals collecting personal information must be able to explain the reasons for which the information is requested. We will only collect, use, and disclose the information we need for the purposes specified at the time of collection. As a broker and administrator of group insurance or pension plans, we use personal information to:

Communicate with you.
Confirm your identity and update your information.
Determine eligibility for requested products, services, or coverage.
Provide and administer products or coverage held with us and provide service for them. This includes conducting investigations, assessing claims, making payments, and creating and maintaining records of our business relationship.
Conduct internal data management and analysis.
Understand the needs of our clients and make recommendations for services and products.
If your information is collected by phone, the call may be recorded or monitored for the following purposes:
Creating a record of the information you provide.
Receiving or verifying instructions received from you.
Maintaining quality service levels.
Training our employees.

3. Consent

We collect, use, and disclose your personal information with your consent for the specified purposes or as permitted or required by law. We may obtain your consent in various ways. It can be expressed in writing or implied, provided verbally, electronically, or through an authorized representative. Consent may be implicitly given in cases where the information is not highly confidential, and consent for its collection, use, or disclosure can reasonably be inferred. Your consent can also be implicit or inferred from specific actions. For example, suppose you present your benefits card to a pharmacy instead of paying for the prescription directly. In that case, you consent to the pharmacy providing us with your personal information to process the claim.

In certain restricted cases, personal information may be collected, used, or disclosed without the person’s knowledge or consent. For example, obtaining consent may be impossible or impractical for legal, medical, or security reasons. When information is collected as part of an investigation into a potential breach of contract, for fraud prevention or detection, or criminal enforcement purposes, seeking consent may counteract the purpose of collecting the information.

Subject to legal or contractual restrictions, you can withdraw your consent anytime. However, withdrawing your consent may affect our ability to continue providing you with the products or services you have requested. We will explain to the individual the consequences of withdrawing their consent, such as contract termination, loss of benefits, or the inability to process their claims.

You can withdraw your consent to receive information about other products and services offered by ARC.

4. Limits on the Collection of Personal Information

We will collect personal information prudently. The amount and nature of the information collected will be limited to only the information reasonably necessary for the specified purposes. The personal information we collect comes from proposals and other forms collected directly from participants or through an Employer or authorized representative. We may also collect your personal information from healthcare providers, clinics, or insurance companies.

The personal information we collect about you may include, but is not limited to:

Identification information, such as first name, last name, gender, marital status, dependents, and their personal information (first name, last name, date of birth, gender, student status), home address, phone number, email address, and date of birth.
Financial and professional information, such as workplace, job position, annual income, and banking information.
Medical information, such as the healthcare provider’s name, medical history, or family medical history.

Personal information does not include an employee’s name, title, business address, business phone number, business fax number, or business email address.

We collect your personal information in various ways:

A completed and signed membership application.
A claim application submitted via the mobile application or employee portal.
During our communications with you, in writing or over the phone.
Other sources including, but not limited to:
Your advisor or authorized representative.
The employer of an insured person.
Service providers we work with to issue and manage our products and services, whether now or in the future.
Public sources like a government agency or a website.

You can contact us in writing to keep your calls from being recorded. You can also request that we respond to you in writing only.

5. Limits on the Use, Disclosure, and Retention of Personal Information

We will use or disclose personal information only for the purposes it was collected unless the individual consents to its use or disclosure for other purposes. Personal information will be retained only for the duration necessary for the specified purposes. We will never sell your personal information to third parties.

We may share your personal information with another company to assess a claim or provide service. We disclose personal information only to those who need it, such as the service providers we use. For example:

Our service providers.
Insurance companies with which you have coverage.
Providers who need this information to provide us with their services or products. Examples of services include data storage, insurance companies, financial institutions, affiliated companies, and other healthcare organizations we work with.
People, organizations, and investigative bodies working to prevent, detect, or investigate suspected fraud, breach of agreement, or violation of the law.
Any entity in the event of a merger or change of control of ARC Group Benefits Inc., in whole or in part, and only if the parties agree that the collection, use, and disclosure of information are limited to the purposes of the commercial transaction and compliant with applicable laws.

We may work with service providers outside of Canada. Your personal information will be subject to the laws that apply in those countries, including access to information laws.

6. Accuracy of Personal Information

The use of information will determine to what extent it is necessary to update personal information, considering the individual’s interests. Information will be sufficiently accurate, complete, and up to date to minimize the risks that a decision relating to a person is based on inappropriate information. You have the right to ask us to modify or correct the information we have collected about you. We will make the necessary changes if your personal information is inaccurate or incomplete. Depending on the nature of the disputed information, the modification may be correcting, adding, or deleting information.

7. Protection of Personal Information

Personal information will be protected by security measures proportional to their level of confidentiality. Technical and organizational means are implemented to protect against unauthorized access, theft, reproduction, use, or inappropriate communication, for example:

Physically, by constructing security measures and physical barriers.

Organizationally, through our policies, practices, and access levels (security authorizations and access limitation based on need-to-know).

Technologically, using passwords, encryption, firewalls, antivirus, and anonymization software.

All staff members receive regular training on compliance rules and must adhere to a code of conduct. Our service providers must also protect their systems from unauthorized access and apply security standards.

8. Accessibility to Information on Practices and Policies

We will provide individuals with accurate information about its policies and practices for managing personal information. Upon written request, we will answer questions about our practices regarding managing personal information. You can contact our responsible person for personal information protection for any information request or complaint.

9. Access to Personal Information

Upon request, we will confirm whether personal information is held about you, how you can access it, and provide a description of the uses for which it is reserved, including disclosure to third parties (if applicable).

10. Complaint Resolution

A person can raise objections to any breach of this policy with our responsible person for personal information protection. We will provide individuals making an inquiry or filing a complaint with the applicable complaint handling protocol. Any complaint will be thoroughly investigated according to the complaint handling policy, and appropriate measures will be taken if we find the complaint valid, such as making changes to this policy or our procedures.

All questions, inquiries, or requests relating to the protection of personal information should be directed to the person designated as responsible for personal information protection, whose contact information is:

Catherine-Julie Vézina

Director of Operations

ARC Group Benefits Inc.
261, Saint-Jacques Street, 3rd Floor
Montreal (Quebec) H2Y 1M6

Telephone: 514-357-2534

Email: cvezina@arcsupport.ca

This policy may be amended or updated at any time, with or without notice.

Last Update Date: October 2022