Privacy Policy

Definition of Terms

Drawbridge

Drawbridge Inc., Drawbridge Systems Corp, and Drawbridge Health Inc. (hereinafter referred to collectively as “Drawbridge”, for ease of reference).

Drawbridge Data

Is data that is entrusted to Drawbridge for the purpose of administering the business on behalf of Drawbridge clients and their plan participants, including financial records, employee/participant files or any other data deemed as private and confidential. This Privacy Policy supplements Drawbridge’s professional and ethical obligations of the personal information entrusted to Drawbridge from our clients, and from Drawbridge employees.

Personal Information

Personal Information is any factual or subjective information, recorded or not, about an identifiable individual. In general, Personal Information, does not include business contact information, including your name, title, and business telephone number.

Chief Privacy Officer

The person at Drawbridge who is responsible for overseeing that privacy practices are carried out to ensure overall compliance with federal and provincial privacy legislation. This includes ensuring that all staff are trained on privacy best practices and carrying out any disclosure requirements under the applicable privacy legislation including privacy breaches.

Introduction

Drawbridge has always recognized and respected the privacy and confidentiality of Personal Information collected in the course of its daily business activities. As a further commitment, Drawbridge has created this Privacy Policy, which is an embodiment of Drawbridge’s adherence to the principles outlined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applies to all Drawbridge operations. A copy of PIPEDA is available at www.priv.gc.ca. Drawbridge complies with all applicable federal and provincial privacy legislation. In addition, Drawbridge has a documented process for reporting a breach incident for information in its possession or custody, including information that has been transferred to a third party for processing. This approach is consistent with the General Data Protection Regulation (“GDPR”). A copy of GDPR is available at www.gdpr.eu.

The Office of the Privacy Commissioner of Canada (“OPC”) defines a “breach of security safeguards” as:

  • the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards.

 

According to the OPC, a privacy breach is:

  • the loss of, unauthorized access to, or disclosure of, personal information. Breaches can happen when personal information is stolen, lost or mistakenly shared. Only breaches including personal information are in scope for PIPEDA, based on a test for a “real risk of significant harm.” The law defines “significant harm” to include bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.

 

PIPEDA’s Ten Fair Information Principles

The following ten principles of privacy are interrelated and are based on fair information practices. They are intended to recognize an individual’s right of privacy while balancing the need for an organization to collect, use or disclose Personal Information for legitimate business purposes.

1. Accountability

Drawbridge is accountable for all Personal Information in its possession or control, including any Personal Information transferred to third parties. Drawbridge has established policies and procedures to comply with this Privacy Policy. All staff are required to sign a Confidentiality Agreement as a condition of their employment. Whenever Drawbridge engages the services of a third-party provider, a Confidentiality and Non-Disclosure Agreement is executed to ensure safeguards are in place to protect Personal Information. In addition to regular audits and other compliance procedures, employee training is conducted regularly to ensure that standards set by federal and provincial privacy legislation are followed.

2. Identifying the Purposes of Collecting Personal Information

Unless additional purposes are identified to an individual before or at the time of collection, Drawbridge will collect Personal Information only for the following purposes.

    • compute and/or pay a benefit
    • payroll purposes
    • satisfy the reporting requirements of the provincial and federal governments
    • pay taxes and comply with civil and criminal law
    • determine future operating costs
    • accommodate audits
    • transfer applicable Drawbridge Data to a new or replacement benefit plan

 

3. Obtaining Consent

Drawbridge will collect, use or disclose Personal Information only with an individual’s knowledge and consent, except where required or permitted by law. This is commonly acquired through the completion of a benefit enrolment form. An individual can provide consent to the collection, use and disclosure of Personal Information about them expressly, or through an authorized representative. The latter would require written authorization from the individual to release the Personal Information. For an individual who is a minor, seriously ill, or mentally incapacitated, consent may be obtained from a legal guardian, or person having power of attorney. Subject to certain legal or contractual restrictions and reasonable notice, an individual can withdraw consent at any time. Drawbridge will inform individuals of the consequences of refusing or withdrawing consent when individuals seek to do so. Refusing or withdrawing consent could precipitate the destruction of an individual’s Personal Information and may, therefore, render ongoing participation in a benefit plan impossible.

4. Limits for Collecting Personal Information

Drawbridge will limit the amount and type of Personal Information collected. Drawbridge will collect Personal Information only for the identified purposes or as otherwise permitted by law and, will only collect the information about an individual primarily from the individual or, from external sources if individuals have consented to such collection.

5. Limits for Using, Disclosing and Keeping Personal Information

Drawbridge will use or disclose Personal Information only for the reasons it was collected, unless an individual provides consent to use or disclose it for another reason. Under certain circumstances, Drawbridge may have a legal duty or right to disclose Personal Information without consent. Drawbridge will keep Personal Information only as long as necessary for the identified purposes.

6. Keeping Personal Information Accurate

Drawbridge will keep the Personal Information in its possession or control accurate, complete, current and relevant, based on the most recent information available to Drawbridge. Individuals may challenge the accuracy and completeness of Personal Information about them and have it amended as appropriate. If an individual demonstrates that Personal Information is inaccurate, incomplete, out-of-date or irrelevant, Drawbridge will revise or delete the Personal Information and, disclose the revised Personal Information to any third parties to whom wrong or outdated information was disclosed in order to permit them to revise their records.

7. Safeguarding Personal Information

Drawbridge will protect Personal Information with safeguards appropriate to the sensitivity of the information. The use of encryption, firewalls, anti-virus programs and robust authentication procedures, including updating passwords on a regular basis, are some examples of the security controls in place. Disaster Recovery (“DR”) tests are performed annually at a remote DR location. As part of this test, all server-based systems are recovered and verified. Privacy protection is outlined in a contractual agreement we enter into on an annual basis with the company that performs the DR testing.

8. Making Information About Policies and Procedures Available

Drawbridge will be transparent about the procedures used to manage Personal Information.

9. Providing Access to Personal Information

When requested to do so Drawbridge will advise an individual what Personal Information is in its possession or control about the individual, what it is being used for, and to whom it has been disclosed. Drawbridge will respond to the request no later than thirty (30) days after receipt of the request. This timeframe may be extended for a maximum of thirty (30) additional days, if, for example, additional time is required to conduct consultations. If that were to happen, Drawbridge would notify the individual in writing. In the unlikely event that Drawbridge determines that there may be a cost to the individual in granting such access, Drawbridge shall inform the individual of the costs permitted by law prior to granting such access.

10. Handling Complaints and Questions

Complaints and inquiries should be directed, in writing, to the Chief Privacy Officer at the following address: Drawbridge 110-61 International Blvd Toronto, Ontario M9W 6K4 All complaints will be investigated. If a complaint is found to be justified, Drawbridge will take appropriate measures, including, if necessary, amending policies and practices. If individuals are not satisfied with the way Drawbridge has responded to their complaint or inquiry they may file a written complaint with: Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3.

Changes to this Privacy Policy

In order to ensure that this Privacy Policy is kept up-to-date, Drawbridge reserves the right to amend it from time to time. Notice of changes to the Privacy Policy may be distributed through bulletins, statements, newsletters and/or posted on the Drawbridge website.

Revised Date: July 14, 2023.

Optional Group Life Insurance

Statistics indicate that Canadian families require insurance coverage at a level of four to six times their annual household income. One of the most valuable assets that we as individuals possess is the ability to earn an income. Loss of income through untimely death can have a devastating effect on a family’s lifestyle and dreams, unless provisions are made for the replacement of lost income. Optional Group Life Insurance provides the opportunity for you and your spouse to purchase additional life insurance to supplement the basic life insurance protection.


Optional Supplemental AD&D

Accidents happen everywhere–on the job, at home, on holidays, and in many other situations. This insurance provides an opportunity to purchase economical supplemental AD&D insurance. This coverage can be applied to you, your spouse, and your dependant children.

Disability Management

After illness or injury, the road to recovery can be lengthy. That makes an early start in assisting someone back to a healthy work state essential.



Early Intervention Program

Drawbridge’s early intervention program concentrates on one’s ability, not their disability. Our aim is to assist the member in finding the right tools and solutions for a timely recovery, with the intention of returning the member to their previous, or modified job. Our integrated approach to disability management includes actively involving the member, employer, primary physician, and other treatment providers. This allows us to focus not just on the illness or injury, but also on other issues that may be impeding the member’s recovery and ultimate return to work.

How It Works

  • As soon as a member has been absent from work due to illness or injury for five consecutive days, the employer contacts Drawbridge to initiate the process.
  • The disability management team prepares to meet with the member, the member’s primary physician, and the employer, and coordinates the support of specialists.
  • After the initial assessment, the disability management team develops a course of action for the member’s return to the workplace.
  • We ensure that active and appropriate treatment is ongoing throughout the duration of the claim.

Advantages of a Disability Management Program

Employees


  • Statistically reduces length of recovery.
  • Promotes pro-active rehabilitation.
  • May provide modified/rehabilitative job capabilities.
  • Provides access to specialists and/or diagnostic procedures on a timely basis.

Employees


  • Expeditious return of plan member to workplace.
  • Reduces the duration and cost of employee absenteeism.
  • Strengthens employee and employer relationship by facilitating open communication.
  • Reduces loss of productivity.
Administrative Services Only

An ASO arrangement can help reduce the high administration costs charged by an insurance company. Under this arrangement, an employer provides benefits to plan members on a self-insured basis. No premium is paid to the insurer for ASO benefits. The employer only pays for the actual claims incurred by plan members, plus an administration fee. The ASO arrangement is best suited for benefits such as extended health and dental, since claims for these benefits are predictable, short term, and generally not catastrophic.

Stop Loss Insurance

To mitigate the impact of unexpectedly high claims under a self-insured plan, Drawbridge offers stop loss insurance. Once claims for an individual or family have reached a certain amount, the cost for any further claims during the policy year transfers from the employer to the insurer. The per individual or per family stop loss benefit can be designed in two different ways: (a) applied to drug claims only; or, (b) applied to the entire extended health benefit (excluding emergency out-of-country coverage). Drawbridge offer flexible stop loss benefit amounts starting at $500.

Health Spending Accounts

An HSA provides reimbursement for medical and dental expenses that qualify under the Income Tax Act and that are not covered elsewhere. While a Cost Plus program is usually only set up for business owners or key executives, a Health Spending Account can deliver benefits in a tax-effective manner for all employees. In order to be a tax-effective program, an HSA must comply with regulations set out by the Canada Revenue Agency, and it must be fully funded by employer contributions. An HSA works essentially like a bank account. A credit amount is allocated to each employee. The employees use the credited amount to cover an extensive range of medical and dental costs incurred for themselves or their dependents.



Advantages of an HSA

Employees


  • Credit amounts are non-taxable (except in Quebec).
  • Covers a broad scope of health and dental services not reimbursable under a group plan.
  • Gives the employee more control to spend their credits on what they need.
  • Offers an expanded definition of dependant.

Employees


  • Employer paid credits are deductible.
  • Effective cost containment strategy since benefit spending is limited to a defined contribution amount.
  • Can be coordinated with the group plan or offered on a stand-alone basis
Cost Plus


Cost Plus is a tax-effective way for an employer to pay for an individual’s claims that are not covered under the group benefit plan. This program is usually provided for incorporated business owners and other key executives. Unlike a traditional fully insured group benefit plan, Cost Plus is a self-insured program, paid with corporate dollars on a claim-by-claim basis. Cost Plus covers medical and dental expenses that qualify under the Income Tax Act.

Advantages of Cost Plus

  • Benefits paid to an individual are non-taxable
  • 100% tax deductible business expense
  • No monthly premium payments required
  • Covers a more extensive range of services and expenses than a group benefit plan
  • Broader definition of an eligible dependent

Before implementing a Cost Plus program, we encourage you to consult with your professional tax advisor to ensure you qualify, and before any expenses are submitted for reimbursement, you will need to ensure the expenses are eligible. For a complete list of eligible medical expenses (form IT-519), visit Canada Revenue Agency’s website or call 1-800-959-2221