Privacy Policy

LAST UPDATED: January 2024

At Quinn Advisory Group, (“Quinn Advisory” or “we”), your privacy is of great importance to us. Quinn Advisory is dedicated to the protection of the personal information of benefit plan participants, website visitors and other individuals whose personal information is entrusted to Quinn Advisory.

Quinn Advisory takes full responsibility for the management and confidentiality of personal information. Personal information is collected, used, shared and stored in accordance with the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 and all applicable provincial privacy laws that apply to Quinn Advisory.

Quinn Advisory has appointed a Privacy Officer who oversees compliance with privacy laws and best practice. The Privacy Officer’s duties include:

• Developing and, on a regular basis, reviewing Quinn Advisory policies and practices to ensure consistent implementation and compliance;
• Ensuring all staff are trained on privacy best practices and are aware of the importance of safeguarding any personal information that they are privy to;
• Ensuring that all inquiries and complaints relating to privacy are appropriately handled; and
• Ensuring all third parties to whom Quinn Advisory provides access to personal information adhere to appropriate standards of care in managing that information.

‘Personal information’ is any factual or subjective information, recorded or not, about an identifiable individual. This includes your name, contact information, birthdate, any identifiers such as your social insurance number, and any identifiable on-line activity. It also includes information about your designated beneficiaries and covered dependants, if applicable. Any sensitive personal information such as medical or dental history, and any financial information, such as banking details, is handled with additional care.

Aggregate information that cannot be associated with a specific individual, such as the number of medical and dental claims made under a given benefit plan over a fixed period of time, is not personal information.

Personal information can be collected in several ways, including through application forms as well as any other documents you provide to Quinn Advisory, or that are provided to us by a third party such as an employer, insurance company or health professional. We collect limited personal information to offer and deliver our products or services and do so with your consent or as otherwise required or permitted by law. We identify when information may be provided optionally and when it is necessary in order to service you as your group benefits insurance provider or plan administrator.

When it is practical to do so, we will collect the information we need directly from you. In those instances where information is collected from your employer or provided by other organizations such as your provincial medical plan or insurance companies, your personal information will be handled in exactly the same way as if we collected it from you personally.

We obtain your consent when you apply for benefits coverage, or we rely on your employer to obtain your consent. We always obtain your express consent when you fill out a claim form.  Your consent is only implied for non-sensitive information when permitted by law, such as when we can reasonably conclude that you’ve given consent by some action, or when it is obvious that you would consent if directly asked. For example, if your benefit plan offers a pay-direct drug card and if you use the drug card to order your medication, we can conclude that you have given us your consent to release personal information about your eligibility for benefits to our pharmacy benefit manager and your pharmacist. Unless otherwise stated, your consent is effective on the date on which you consent, expressly or by implication.

Note that there may be instances where the law permits the collection, use or disclosure of your personal information without your consent, for example in the context of fraud prevention and investigations, where the collection, use or disclosure is done clearly to your benefit or is required to provide or deliver a product or a service that you requested, and where necessary to protect our legal interests or the safety of others, as permitted by applicable law. Moreover, Quinn Advisory may be involved in the sale or transfer of some or all of its business (including transfers made as part of insolvency or bankruptcy proceedings). As part of that sale or transfer, Quinn Advisory may disclose your personal information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.

In scenarios where we rely on your consent to collect, use, or disclose your personal information, your consent can be withdrawn at any time, subject to legal or contractual restrictions, by providing us with written notice (see “Section 14. Getting in Touch” below for our contact information). Upon receipt of notice of withdrawal of consent, we will inform you of the likely consequences of withdrawing your consent before we process your request, which may include the inability of Quinn Advisory to provide you with a particular benefit, product or service.

We collect, use and disclose personal information for the following specific purposes:

• To help us understand your insurance and service needs;
• To underwrite insurance coverage;
• To provide services and information about our services, including notifying you of benefits of your membership, such as discounts on products and services, and providing you with new services and features added or developed by Quinn Advisory;
• To verify your identity and your eligibility for benefits, and allow us to process applications for insurance;
• To allow us to process, adjudicate and pay claims to you and your eligible dependents;
• To determine premiums be associated with a group benefits insurance policy;
• For internal and external audits of benefits payouts;
• Where applicable, for income tax reporting purposes;
• To offer you additional insurance products or services that we believe you would benefit from knowing about. We may also tailor our offerings to you based on your demographics or other information, with the objective of meeting your specific needs.; The collection, use and disclosure of your personal information for such marketing purposes is entirely optional and is not required as a condition of doing business with us. You may withdraw your consent to the use of personal information for these optional marketing purposes at any time by providing us with written notice (see “Section 4. Getting in Touch” below for our contact information);
• To assess and manage risk, including detecting and preventing fraud or error;
• To meet legal and regulatory processes and requirements related to the provision of insurance products and services, as well as to meet Quinn Advisory’s contractual obligations; and
• For such other purposes for which you have provided your consent, or as otherwise permitted or required by law.

Please note that your personal information may be subject to an automated processing in the context of the adjudication of any insurance claims.

When you use Quinn Advisory’s website or mobile app, we automatically receive and record information on our server logs from your browser or mobile platform, including the date and time of your visit, your IP address, unique device identifier, browser type and other device information (such as your operating system version and mobile network provider). By setting cookies, Quinn Advisory is able to enhance a user’s on-line experience (e.g. we may identify you as a return visitor in order to provide you with more meaningful information). You can enable and disable cookies through your website browser, however some areas of the site, such as MyGroupHEALTH, may not work properly with cookies disabled.

The information we collect when you visit Quinn Advisory on-line helps us analyze and improve the performance of our digital services. Quinn Advisory uses Google Analytics for web statistical analysis. We make no effort to personally identify you based on your visit to our site if you are not logged into your account. If you wish, you may opt out of being tracked by Google Analytics by disabling or refusing the cookies; by disabling JavaScript within your browser; or by using the Google Analytics Opt-Out Browser Add-On.

Your personal information is shared only to the extent necessary to give effect to the purposes set out in this Privacy Policy. For example, in order to administer your benefits, we will share your personal information with the insurance provider(s) providing coverage and non-medical personal information with your Plan Sponsor (employer). We may also share information, but only as necessary and as specifically authorized by you, with medical professionals in order to properly assess your claim and to protect us and our coverage providers against fraud.

Quinn Advisory’s third party service providers may have access to your personal information in order to assist us in providing you with our insurance services, subject to strict contractual requirements.

Only authorized persons have access to your file as required for coverage or claim purposes.  Quinn Advisory will also release your personal information when we believe such release is appropriate in order to comply with the law, for example, if we receive a subpoena, court order or request from government authorities. However, if anyone else requests disclosure of the information in your file, we will only provide it if you have authorized us to release it to them.

Your personal information may be transferred to or accessed from a different jurisdiction to be processed or stored. The processing and storage outside of your jurisdiction may be conducted by us, one of our affiliates, our parent company by insurers and reinsurers, and our service providers. You can contact our Chief Privacy Officer for more information about our practices and policies regarding transferring personal information outside of your jurisdiction. The purposes for the transfers may include any purpose set out in this Privacy Policy, including providing services to you and the prevention of fraud and money laundering. Such information may be provided to law enforcement or national security authorities of that jurisdiction upon request, in order to comply with that jurisdiction’s laws. We take reasonable steps to ensure that any third parties who we entrust with your personal information are reputable and have safeguards in place to protect this information.

Quinn Advisory has implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful access to the personal information we manage and store. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by Quinn Advisory significantly reduce the likelihood of a data security breach.

Here are some examples of the security controls we have in place:

• Secure office premises with key card access;
• Locked filing cabinets and a secure shredding practice for paper records;
• The use of encryption, firewalls, anti-virus programs and robust authentication processes, including complex passwords, for electronic records; which are regularly upgraded
• Limited access to personal information by employees on a “need-to-know” basis;
• The use of data centers with effective physical and logical data security controls;
• Staff that are keenly aware of their data protection responsibilities; and
• Regular reviews of privacy compliance and best practice initiatives.

In addition, we recommend that you do your part in protecting yourself from unauthorized access to your personal information. Quinn Advisory is not liable for any unauthorized access to your personal information that is beyond our reasonable control.

You may have the right, in certain circumstances, to obtain personal information you have provided us with (in a structured, commonly used, and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

We make every effort to ensure that the personal information we hold is accurate, complete and up-to-date for the purposes for which we collect it. You can make a written request for access to your personal information at any time. You may also request that your personal information be corrected if there are any inaccuracies, or that it be erased as permitted or required by law.  You will need to provide as much information as you can to help us process your request and locate the information you require.

If you need assistance in preparing your request, please contact use and we would be pleased to help you. Upon your written request, Quinn Advisory will also inform you of how your personal information has been or is being used, and who your personal information has been shared with. If we have obtained information about you from other people, we will let you know who we got it from upon your request.

Quinn Advisory responds to access requests within 30 days, unless an extension of time is permitted by law. We may charge a fee to cover any expenses related to responding to your access request as permitted by law. Note that there may be contexts where access is refused or only partial information is provided, for example, in the context of an on-going investigation or where another individual’s personal information or identity must be protected.

Quinn Advisory retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with our retention schedules. Personal information that has been used to make a decision about a benefits plan participant shall be retained long enough to allow the individual access to the information after the decision has been made.  Quinn Advisory is subject to specific legal requirements with respect to retention periods as well, for example, as outlined in income tax laws.

Once your information is no longer required by Quinn Advisory to administer products or services and meet legal or regulatory requirements, it is securely destroyed, erased or made anonymous. Keep in mind however that residual information may remain in back-ups for a period of time after its destruction date.

Quinn Advisory takes privacy complaints very seriously and has a procedure in place for escalating and managing any privacy related concerns to ensure that they are responded to in a timely and effective manner. Any suspected privacy breach must be escalated internally to Quinn Advisory’s Privacy Officer who oversees the containment, investigation and corrective actions for the breach situation.

In the event that you are not satisfied with Quinn Advisory’s resolution of a complaint or privacy breach, you may contact the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner as appropriate.

We may offer links from our websites to the sites of third parties, such as affiliated organizations, that may be of interest to you. Quinn Advisory makes no representations as to such third parties’ privacy practices and we recommend that you review their privacy policies before providing your personal information to any such third parties.

Quinn Advisory’s use of social media serves as an extension of our presence on the Internet and help us build a positive brand image as well as offer our customers personalized service. Quinn Advisory maintains several social media accounts that are not hosted on Quinn Advisory’s servers. Users who choose to interact with Quinn Advisory via social media, such as Facebook, should read the terms of service and privacy policies of these services/platforms.

We may change this Privacy Policy from time to time in order to better reflect our current personal information handling practices. Thus, we encourage you to review this document  frequently! The “Last Updated” date at the top of this Privacy Policy indicates when changes to this policy were published and are thus in force. Your continued use of Quinn Advisory products and services following the posting of any changes to this Privacy Policy means you accept such changes.

We do not directly collect personal information from children under the age of 14. Any personal information belonging to a child under the age of 14 that may be collected, used, and disclosed by Quinn Advisory is strictly limited to the information provided by a person with parental authority over the child for the purposes set out in this Privacy Policy.

Any inquires, concerns or complaints regarding privacy should be directed to:

Privacy Officer
GroupHEALTH Global Benefit Systems Inc.
Suite 400
15315 31st Avenue
Surrey, B.C.  V3Z 6X2

Tel: 1-866-963-9995
E-mail: privacy@grouphealth.ca

Your concerns will receive prompt attention. Our Privacy Office can also provide you with more detailed information about Quinn Advisory’s policies and practices or assist you with completing an access to information request. Keep in mind however that e-mail or text messaging are not secure forms of communication, so never send confidential personal information to us this way.

Thank you for continued trust in Quinn Advisory.