Privacy policy
1. Summary
We are LifeWorks (Canada) Ltd. (“LifeWorks”), a corporation organized under the laws of Ontario, Canada. LifeWorks (Canada) Ltd. owns and operates the LifeWorks business through its subsidiaries in various countries including without limitation Canada, the United States, the United Kingdom and Australia. For the purposes of applicable data protection laws, LifeWorks is the data controller of your personal data and our primary business address is 895 Don Mills Road, Tower One, Suite 100, Toronto, Ontario M3C 1W3, Canada.
This Privacy Policy explains the collection, use and disclosure of personal information and sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read this Privacy Policy carefully to understand the ways in which we use, share and protect your personal information.
The management of personal information is fundamental to LifeWorks services and we are committed to protecting your privacy.
LifeWorks collects and uses personal information to identify you, establish eligibility, and to provide technology-enabled total health, wellbeing and human resources services (such as pensions and benefits, employee assistance programs, and health management programs), including through our websites and apps. We also use your information for our own purposes, including to analyze and improve our services and for communications.
Please see the headings below to get more detailed information on how LifeWorks handles your personal information and on any topics of interest in our privacy policy.
2. About this privacy policy
We created this privacy policy to tell you:
- What personal information we might collect about you;
- What we might do with that personal information; and
- Your choices about the personal information you provide.
This policy covers our websites, mobile apps, services provided through these platforms or otherwise accessed by a user (such as our counselling and well-being services) and any other interactions you may have with us (such as by telephone, email, or in person). This policy specifically covers our handling of personal information (including, in the case of some of our services, sensitive personal information) relating to identifiable individuals and does not apply to proprietary business information.
Some of our services are provided on behalf of our clients, which means our client remains primarily responsible for your personal information. For instance, we may be providing services on behalf of your employer or plan sponsor. In these circumstances, we may re-direct a query about our use of your personal information to our client.
3. Getting your consent
As part of using our services or interacting with us, we may collect and process some details about you. When we do so, we will collect, use or share your personal information with your consent for the purposes we’ve informed you of, or as may be otherwise permitted or required by law. Your consent can be express or implied (where this is permitted by law). For example, by participating in your benefits plan, you consent to LifeWorks' collection and use of your personal information to provide services to that plan. In some situations, we may get consent directly from you (including as described in this privacy policy). In other situations, we may rely on the consent you provided to your employer or benefits sponsor.
You can withhold or withdraw your consent for us to collect, use or share your personal information (to the extent our processing is based on your consent in accordance with applicable law). The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Depending on the circumstances, however, withdrawal of your consent may impact our ability to serve you, or in the case of administering benefits, it may prevent us from processing your claims.
4. Where we get your information
We collect personal information in the following ways:
- Directly from you;
- From your use of LifeWorks' services, programs, websites and apps;
- From your employer, association, insurer or benefits plan sponsor;
- When you attend a LifeWorks site or event;
- When you apply for a position at LifeWorks;
- If you contact us with a complaint or query;
- When you engage with us over social media; and/or
- From legally authorized third parties.
5. Children’s information
We will not knowingly collect, use or share your personal information if you are under the age of majority in your area without the permission of your parent or guardian. If you are underage and want to access our counselling and wellness services, your parent or guardian needs to contact LifeWorks on your behalf.
6. What information we collect and why
Our collection and use of your personal information depends on what products and services your sponsoring organization chooses to make available to you, which LifeWorks products and services you choose to participate in, and what information you choose to provide to us.
We may collect and use the following types of information for the following purposes:
Personal information
Personal information category
Identity information
Types of information we may collect
Your name, username, employee number or similar identifier, marital status, date of birth and reported gender
How we may use it
To identify and authenticate you
To communicate with you
To create and administer your account when you register for our service, including through our websites and apps
Contact information
Your billing address, postal address, email address and telephone numbers
To communicate with you and respond to your inquiries or for any other purposes related to LifeWorks services and Platform
To inform you of news about our products and services, as well as special promotions, offers or events
To create and administer your account when you register for our service, including through our websites and apps
Employment information
Your job title, place of work, hire date, employment history, work address
To determine eligibility and process applications
To administer products and services that you have with us
Interaction information
Telephone recordings and transcripts, records of communications (such as emails, letters, online chat, etc.)
For quality assurance and staff training purposes
To retain a record of your interactions with LifeWorks
To provide you with the services and information which you request
To communicate with you and respond to your inquiries
To understand any concerns you may have, so that we can resolve disputes and improve your experience
Digital interaction information
Geolocation data, IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system (including the type of device used) and other technology, related to the devices you use to access our websites and/or our apps
To personalize your experience and understand how you use our sites and apps
To notify you of any relevant issues relating to our website or app (e.g., push notifications)
To measure how our apps and websites are performing
To identify opportunities for new products/services or improvements to existing ones
For system or product development and planning, audit and administrative purposes
For more information relating to our use of cookies, Google Analytics, and related technology, please review our Cookie Policy for the LifeWorks App
Job applicant information
Résumé, cover letter, reference letters, employment history and interests
For staffing and recruitment activities
To maintain an inventory of candidates for current and future work opportunities
Sensitive personal information
Sensitive personal information category
Financial information
Types of information we may collect
Your banking information, email linked to your electronic transfers, and payment information
How we may use it
For billing, administering claims and other financial and payment-related functions
To administer products and services that you have with us
Transaction information
Details about payments to and from you, and other details of products and services you have purchased from us, including customer account numbers
For administering services and auditing
To understand how you use our products and services
Health information
The state of your physical and/or mental health which we receive in connection with your use of our services, provided by you through connected devices or through any Assessment you complete
To determine eligibility and process applications
To administer products and services that you have with us
Note: For clients using absence and disability management services, LifeWorks or employee and family assistance programs, the personal health information collected for the purpose of providing one service will not be used or disclosed for the purpose of providing any other service. Although some health information may be used by LifeWorks in data analytics, it will not be disclosed in a way that allows identification of any individual
Biometric information
Your weight, height, body mass index, waist circumference, cholesterol, lipoprotein, triglycerides, glucose and blood pressure readings, sleep patterns or other similar information provided by you through connected devices or through any Assessment you complete
To administer products and services that you have with us
Lifestyle information
Your alcohol consumption, tobacco/nicotine use, eating and nutrition (e.g., number of servings of food groups and nutrition related questions), race, gender identity, sexual identity, religion, political belief, union membership, cardiovascular disease risk, emotional well-being (e.g., depression and stress), and readiness to change
To determine eligibility and process applications
To administer products and services that you have with us
Claims information
Information disclosed to us with your permission by your insurance, health plan provider, or plan sponsor regarding claims you have made under your policy and/or other information, including health information
To determine eligibility
To administer products and services that you have with us
To process and administer claims
To provide you with personalized services
We may also collect and use your information to:
- Perform services on your behalf or your employer’s/benefits sponsor’s behalf (including total health and wellbeing, rewards and recognition services, employee and family assistance services, health management programs, group benefits and investment plans, and pension administration services);
- Understand your needs, the suitability of our products and services, and assess future needs;
- Provide services tailored to your requirements and to treat you in a more personal way;
- Promote and market our products and services to you;
- Improve our business operations and the quality of our products and services;
- Develop and test new products and services;
- Manage our business and operational needs;
- Administer and protect the security of our business, and our websites, apps and other services;
- Meet our legal and regulatory obligations, including to enforce our legal rights; and
- Carry out activities consistent with the purposes of any of the above.
7. De-identified, aggregated, and anonymized information
We may use your personal information to generate de-identified, aggregated, or anonymized information that does not reveal your identity. LifeWorks uses this information to conduct research, compile aggregate data sets, statistics, and reports, and to perform analytics on our services, service standards, business operations, and trends.
We may share de-identified, aggregated, or anonymized information with our clients for reporting purposes, including usage of our services, and with third party service providers for use in creating marketing materials, cases studies and statistical analyses. This allows LifeWorks, its clients and our respective third party service providers to understand how we are performing, or develop relevant products, services or offers.
8. When does LifeWorks share your personal information?
LifeWorks may share your personal information with:
- Other LifeWorks entities in order to serve you, including for our internal management and administrative purposes.
- Third party service providers who are required to keep your information confidential and secure and are restricted from using or disclosing information for reasons other than performing services on our behalf or to complying with legal requirements.
- Third parties and partners in the event of a potential merger or acquisition, transfer of assets, reorganization, or bankruptcy. These parties are also required to keep your information confidential and secure and are restricted in their use of information to this purpose.
- Government, regulatory and law enforcement agencies to meet our compliance, regulatory, and risk management obligations or to comply with the law.
- The general public and other users when you post or share comments, blog postings, testimonials, or other similar information on our technology platforms.
- Your sponsoring organization or health plan provider when you provide your express or implied consent (where this is permitted by law) or if we are required to do so by law.
9. International transfers of information
LifeWorks is a global organization with affiliates, partners and subcontractors located in many countries around the world. To provide our services to you, LifeWorks may exchange personal information across geographical borders with LifeWorks entities, affiliates or service providers in other countries working on our behalf in accordance with applicable law.
Examples of countries we transfer and exchange personal information with include, but are not limited to, the United States of America, the United Kingdom, Canada, and Australia. If your personal information is transferred outside of your country, we will take appropriate measures to ensure an equivalent standard of personal information protection under applicable law. We will also obtain consent where this is required under applicable law. Please contact us if you want more information on how we protect personal information transferred out of your country.
Notice to users in China
The below information, which may be collected from you or provided by your Sponsoring organization, is exported out of China:
Personal information collected (including sensitive information)
Identity information
Description
Provided by you or your sponsoring organization when creating your account such as your name, date of birth, employee number, gender, language
Contact information
Provided by you or your sponsoring organization when creating your account such as your email, Country, City
Employment information
Provided by you or your sponsoring organization when creating your account such as Company name, job title, work status, employment start date
Health information
The state of your physical and/or mental health provided by you in connection with your use of our services, provided by you through connected devices or through any Assessment you complete
Biometric information
Your weight, height, body mass index, waist circumference, cholesterol, lipoprotein, triglycerides, glucose and blood pressure readings, sleep patterns or other similar information provided by you through connected devices or through any Assessment you complete
Lifestyle information
Your alcohol consumption, tobacco/nicotine use, eating and nutrition (e.g., number of servings of food groups and nutrition related questions), cardiovascular disease risk, emotional well-being (e.g., depression and stress), and readiness to change. This information is provided by you through Assessments you may complete
10. Storage of your information
LifeWorks may store your personal information in its databases located in the United States, Canada, the United Kingdom, Australia or other countries. Some of our service providers may also store or access personal information from countries other than where you reside or receive services, and in those circumstances, are subject to the laws of that jurisdiction. Because of this, there may be circumstances where other foreign governments, courts, law enforcement agencies or regulatory agencies are entitled to access the personal information collected and held by LifeWorks or our subcontractors.
If you are visiting our website from a country other than Canada, your communication through our website or any of its services may result in the transfer of information across international boundaries.
11. Retention of your information
We only keep your information for as long as it is contractually, operationally or legally necessary. When we no longer need the information, it is either destroyed or anonymized.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
12. Safeguards
We use reasonable physical, technological, organizational, and contractual safeguards, appropriate to the sensitivity of the information, to protect personal information in our possession or under our control, from unauthorized access, disclosure, or use.
13. Accessing your information
When requested in writing, we will inform you of the existence, use, and disclosure of your personal information that we maintain. We may not be able to provide you with all the information you request, depending on prescribed circumstances, and there may be a charge for copies of your personal information.
14. Correcting your information
We will make reasonable efforts to keep your information accurate and up to date. If a change or correction is required, let us know right away. We’ll make appropriate updates needed to keep things running smoothly. You can review your personal information by looking at the correspondence we send to you, through your online accounts with us, or by requesting access to your personal information, as described above.
15. Other data subject rights
Depending on the country in which you are based, you may have additional rights over your personal information, including:
- Right to delete personal information. You may have the right to request the deletion of your personal information upon the withdrawal of your consent for us to process such information or other circumstances provided under applicable law, provided that such data no longer needs to be processed by us to fulfil our legal and regulatory obligations.
- Right to restrict or object to processing. You may have the right to request us to anonymise, delete or otherwise restrict or object to the processing of your personal information in certain circumstances, such as where you establish that the information collected by us is unnecessary or excessive.
- Right to data portability. You may have the right to request us to provide you with your personal information in a structured, commonly used, and machine-readable format and a right to request that we transfer such information to another party.
- Right to lodge a complaint. You may have the right to lodge a complaint about the way we handle or process your personal information with the relevant authorities.
Note for data subjects in France: under French law you also have a right to define guidelines relating to the fate of your personal data in the event of your death.
If you would like to exercise any of these rights, please use the contact details below.
16. Marketing
We may occasionally send you email notices concerning our Website, App or Services, which may include emails tailored to you based on your activity on our Websites or Apps. You may also receive emails from us arising from your use of particular Services requiring email communication. Where possible, you will be given the option to choose a different method of communication or to opt out of receiving such communications, although it may adversely affect or otherwise prevent you from receiving the full scope of Services you signed up to receive.
17. Contact information
If you have any questions or concerns about this policy or LifeWorks' handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Office
LifeWorks (Canada) Ltd.
25 York Street
Tower One, Suite 100
Toronto, ON M5J 2V5
Canada
By electronic mail: privacy-vieprivee@lifeworks.com
Please note that we may need to confirm your identity, request additional details and work with other LifeWorks departments to respond to you or to look into your concerns or complaint.
18. Changes to our Privacy Policy
We may modify this notice from time to time and will post the most current version online.
Last updated: March 2022