Privacy and Accessibility

People Corporation has policies in place with respect to privacy and accessibility, which policies apply to its entities and divisions. Full details are provided below.

Privacy

People Corporation and You - Partners in Privacy

In responding to the requirements of PIPEDA, People Corporation has developed its Privacy Policy and Complaint Procedure, identifying how plan member information will be handled, shared, stored and destroyed. Please review our policy and complaint process statements to ensure they are in alignment with your own privacy policy and practices. It is the responsibility of each employer to obtain the consent of each employee and where applicable, each employee’s spouse/partner, identifying how their personal information will be used and shared with respect to outsourced services, such as group health plans. It is our expectation that such consent will be obtained by you prior to providing People Corporation with personal information about an individual.

Knowledge and Consent

The central concepts of PIPEDA are Knowledge and Consent. Under PIPEDA, organizations are required to obtain the consent of individuals before acquiring and handling their personal information. In obtaining consent, it is the responsibility of the organization to identify the purpose(s) for which the personal information is being collected, as well as how it will be used, disclosed, etc., when the information is collected. The use or disclosure of such information is limited only to those purposes consented to by the individual.

People Corporation Privacy Policy

People Corporation will make every effort to ensure that personal information regarding group benefit plan members, their spouses/partners and/or eligible dependents is handled, secured, shared and destroyed using means that reflect the spirit of enacted privacy legislation. Only the information necessary to effectively administer each group benefits plan; obtain quotes for underwritten/insured products within that plan; verify the identity and eligibility of a plan member, spouse or eligible dependent; adjudicate and pay eligible claims; and audit plan expenditures will be collected and used by People Corporation. Such information will only be provided to those insurers/adjudicators contracted by People Corporation to provide services within the plan. Health benefit providers contracted to provide services through People Corporation will be required to have their own privacy policy and practices defined and in operation. People Corporation will endeavour to strike a reasonable and appropriate balance between individuals’ privacy rights, and the requirements of People Corporation to collect, use, disclose and report such information in the operation of the plan. People Corporation’s Privacy Policy will be reviewed from time to time to ensure it is accomplishing its purpose and as may be necessary to respond to changes in legislation.

People Corporation Privacy Practices

Enrolment and claims information will be collected from plan sponsors for their plan members:

  • To enrol the employee (and spouse/partner/eligible dependents where applicable) in the elected plan coverage, to correct or amend member information, or to implement changes to coverage that may be enacted over the term of the plan;
  • To verify eligibility and authenticate the identity of the employee and/or eligible dependents;
  • To ensure benefits are paid in accordance with the policy provisions;
  • To protect the plan from undue expenses due to error or fraud by auditing and reporting on plan activity to the plan sponsor;
  • To only use such information as is required to provide the services outlined in the group benefits contract.

Enrolment and other plan member records will be secured in locked cabinets while on People Corporation premises. Such documentation will be retained for a reasonable period of time after the member has left the plan, or after the plan has terminated, to ensure any and all outstanding claims can be adjudicated in accordance with the plan design. When documentation is destroyed it will be shredded.

People Corporation Complaint Process

The following process will be used when responding to Privacy Act complaints:

  1. The complaint should be made in writing to the People Corporation Privacy Officer; privacy@peoplecorporation.com
  2. The Privacy Officer will investigate the complaint and provide a written report of his/her findings to the Executive Team of People Corporation. The investigation will require sufficient time so as to be thorough, however, will be completed in a timely manner;
  3. The Executive Team will respond to the complainant outlining the outcome of the investigation and if necessary, identify any remedial steps that will be taken to resolve the complaint and the timeframe in which such steps will be completed;

A copy of the complaint, the investigation report, the outcome, along with a record showing the completion of any required remedial steps will be retained by People Corporation and will be made available to the Privacy Commission at their request.

People Corporation's Commitment to Accessibility

Principles

People Corporation and its affiliates and subsidiaries in the Province of Ontario are committed to improving accessibility. Our accessibility policies are founded on the guiding principles identified in the Accessibility for Ontarians with Disabilities Act:

  • Dignity and independence: We accept the right of all persons to decline or accept assistance while receiving our services.
  • Integration: We provide services in a similar manner to all clients regardless of disability.
  • Equity: All clients have access.

People Corporation has put the policies and procedures outlined in this document in place as required by the Accessibility for Ontarians with Disabilities Act (AODA) and confirms compliance with Ontario Regulation 429/07.

Please see our Accessible Customer Service Plan and Multi-Year Accessibility Plan below.

Accessible Customer Service Plan

Policies and Procedures

Training

People Corporation is committed to training staff on Ontario's accessibility laws and on accessibility aspects of the Human Rights Code that apply to persons with disabilities. Training includes:

  • An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard.
  • People Corporation's plan related to the customer service standard.
  • How to interact and communicate with people with various types of disabilities.
  • How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or support person.
  • What to do if a person with a disability is having difficulty in accessing People Corporation's services.

New employees receive training within one week of their employment start date. Personnel will be trained when changes are made to policies or procedures. Training logs are maintained, listing the employees who have taken the required training and the dates the training was completed.

Information and communications

People Corporation is committed to meeting the communication needs of people with disabilities. When asked, we will provide information and communications materials in accessible formats or with communication supports. This includes publicly available information about our goods, services and facilities.

People Corporation will consult with people with disabilities to determine their information and communication needs.

Clients Using Assistive Devices

Clients are encouraged to use their assistive devices in our offices. Staff if trained to ask clients if they require assistance prior to providing physical assistance or touching equipment.

Clients with Service Animals

Service animals are allowed entry to all areas accessible to the public. Staff will not interact with the animal.

Clients with Support Persons

Support persons are encouraged to accompany the client when the client chooses. The right to give or withhold consent for sharing of information remains with the client regardless of the presence of a support person.

Notices of Availability

In the event of a temporary service disruption planned or unplanned, in People Corporation's ability to accommodate people with disabilities, notice will be made. Notices will be posted at entrances and on relevant websites. Notice will include a predicted timeframe for resumption of service and any resources that are available in the meantime.

Comments about our Policy

Clients are made aware of our policy and will be informed about the methods by which they can provide feedback on our accessibility policy and practices.

Clients are encouraged to provide feedback on the way People Corporation provides services to persons with disabilities. Clients may provide feedback verbally or in writing by:

Questions/complaints regarding policies or service will be responded to within 5 business days.

Modifications to this or other Policies

Any People Corporation policies that do not respect and promote the dignity and independence of people with disabilities will be modified or removed.

Alternate forms of this document are available, upon request.

Multi-Year Accessibility Plan

This 2014 to 2021 accessibility plan outlines the policies and actions that People Corporation and its affiliates and subsidiaries in the Province of Ontario will put in place to improve opportunities for people with disabilities.

Statement of Commitment

People Corporation is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.

Accessible Emergency Information

People Corporation is committed to providing clients with publicly available emergency information in an accessible way upon request. We will also provide employees with disabilities with individualized emergency response information and plans, where necessary.

Training

People Corporation will provide training to employees on Ontario's accessibility laws and on the Human Rights Code as it relates to persons with disabilities. Training will be provided in a way that best suits the duties of employees. People Corporation has taken steps to ensure all employees are provided with the training needed to meet Ontario's accessible laws by January 1, 2015. People Corporation and its affiliates and subsidiaries in the Province of Ontario will ensure that:

  • All new employees receive training within one week of their employment start date
  • All personnel will be trained when changes are made to policies or procedures.
  • Training logs indicating the employees who have taken the training and the date their training was completed will be maintained.

Information and Communications

People Corporation is committed to meeting the communication needs of people with disabilities. We will consult with people with disabilities to determine their information and communication needs. People Corporation will design all new websites to conform with WCAG 2.0.

People Corporation has taken the following steps to make ensure existing feedback processes are accessible to people with disabilities upon request by January 1, 2015. People Corporation's Accessible Customer Service Plan encourages clients to provide feedback on the way we provide services to persons with disabilities. Clients may provide feedback orally or in writing by:

People Corporation will take the following steps to make sure all publicly available information is made accessible upon request by January 1, 2016.

  • Review all publicly available information to determine where barriers or gaps exist and develop plans and processes to ensure that all information is accessible or can be made accessible on request prior to January 1, 2016.
  • People Corporation will provide alternate formats of information, at no additional cost, upon request

People Corporation will take the following steps to make all websites and content conform with WCAG 2.0, Level AA by January 1, 2021.

  • People Corporation will develop a plan to ensure that all websites and content conform with WCAG 2.0, Level AA by January 1, 2021.

Employment

People Corporation is committed to fair and accessible employment practices. People Corporation will ensure that reasonable accommodations are made for persons with disabilities during recruitment, assessment and selection processes and that reasonable accommodation is made for employees with disabilities throughout the duration of their employment with People Corporation. People Corporation will:

  • Ensure that recruitment and selection processes provide accommodations
  • Ensure suitable accommodations are provided to current employees, as required
  • Ensure a return to work process where appropriate accommodation and support is in place
  • Ensure that performance management, career development and redeployment practices take into consideration the accessibility and accommodation needs of employees with disabilities
  • Ensure that workplace emergency response information is provided in accessible formats, upon request
  • Review its accommodation policies and revise where necessary to reflect People Corporation's commitment to fair and accessible employment practices.
  • Develop and implement necessary training on accommodation policy and process changes
  • Communicate new and revised policies and processes to personnel.

Design of Public Spaces

People Corporation will put the following procedures in place to prevent service disruptions to its accessible parts of its public spaces.

In the event of a service disruption, People Corporation will provide alternatives for obtaining service. Information will be posted in lobby/reception areas and/or websites.

For More Information

For more information on this accessibility plan or to request an accessible format of this document at no additional charge, please contact:

Eric Johnstone
Email aoda@peoplecorporation.com
Phone (204) 940.3905