LifeWorks PRIVACY AND COOKIES POLICY policy
Direct Questions and Comments to: Privacy@LifeWorks.com
LifeWorks is committed to protecting your privacy. The Privacy and Cookies Policy describes how LifeWorks collects, uses, shares, and secures the information that LifeWorks collects from users who visit and use LifeWorks websites, the Mobile application, and EAP Services. This policy covers only LifeWorks practices with respect to your use of the LifeWorks services. We do not control the privacy practices of your employers.
LifeWorks collects, uses, shares, and secures information in accordance with applicable data protection laws, including but not limited to: The Health Insurance Portability and Accountability Act (HIPAA), the Personal Information Protection and Electronic Documents Act (PIPEDA), and the EU Data Protection Directive.
The Information LifeWorks Collects
LifeWorks collects both personal and non-personal information from you.
“Personal Information”, means data element or combination of data elements that can be used to directly or indirectly identify you.
”Non-personal information” means information that does not directly or indirectly identify you, including Personal Information that has been de-identified or anonymized.
This policy discloses LifeWorks’ handling of Personal Information.
How LifeWorks Collects Personal Information
LifeWorks collects personal information only for the purposes of providing and promoting the services. LifeWorks offers and limits use to those purposes, including initiating, maintaining, enhancing, and terminating the employee-employer relationship. Personal information shall be collected by fair and lawful means, and not by misleading or deceiving individuals about the purpose for which information is collected. LifeWorks may also collect personal information from other sources, either with the consent of the individual or where permitted or required by law.
LifeWorks may collect Personal Information from and about you in the following ways:
- In connection with your account, personal profile, your log-in and password details;
- Details of any booking requests or other transactions made by you;
- Communications you send to LifeWorks, for example to report a problem or to submit queries, concerns or comments regarding content;
- Information from surveys, promotions and competitions that LifeWorks may, from time to time, run on the Website or App, if you choose to respond to, or participate in, them;
- Technical information from your mobile device relating to the services you receive;
- Information relating to your location; and
- Information that you post in the form of comments or contributions to discussions
- To request in-person sessions with an Employee Assistance Program counselor
- To request and participate in a chat and/or video sessions
- For online authorization
Cookies – Many sites use “cookies,” which are pieces of information that include a unique reference code that a website transfers to your devices to store and sometimes track information about you. A number of cookies LifeWorks uses last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website will last for longer. LifeWorks uses persistent cookies on our website to allow LifeWorks to personalize your experience. For instance, cookies enable LifeWorks to (a) remember your viewing preferences without requiring you to re-type a user name and password; (b) allow you to navigate the Website more quickly and easily; (c) remember your login session so you can move from one page to another within the Website; (d) store your preferences; (e) customize elements of the layout and/or content of the pages of the Website for you; and (f) collect statistical information about how you use the Website so that LifeWorks can improve the Website. All cookies used on the Website are set by LifeWorks. If you choose, you can set your browser to reject cookies or you can manually delete selected cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our website, or that we may put on our website in the future.
Survey - When you visit LifeWorks Website, LifeWorks may ask you to complete a survey telling LifeWorks about your experience on our site. The survey is anonymous, but you may choose to provide your name and contact information so that LifeWorks can follow up on any comments.
Web Server Logs – The computer that delivers our web pages to you records information about your visit to our site. For example, the web server log records your IP Address, your Internet browser type, version and language, your operating system, your display’s screen size, the date & time of your visit and the pages you visit on our site.
You are under no obligation to provide any such information. However, if you should choose to withhold requested information, LifeWorks may not be able to provide you with certain services.
How LifeWorks Uses Personal Information
LifeWorks will use the personal information you provide to:
- Create and administer your account when you register;
- Identify you when you sign in to your account for authentication purposes. After authentication, LifeWorks does not track any EAP-related activities to that specific account ;
- Enable LifeWorks to process your orders and to provide you with the services and information which you request;
- Verify and carry out financial transactions in relation to payments you make online;
- Collect your real time location to provide location services requested by you. You may opt out at any time from allowing further access by LifeWorks to your location data in “Location Services” under the “Settings” tab in your account. You can also stop all information collection by uninstalling the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the App market place network;
- Collect information relating to the recognition of other Users and colleagues, which can be viewed by other Users and your Employer;
- Send you information LifeWorks thinks you (or your Employer, in the case of authorized administrators) may find useful or which you have requested from LifeWorks, including receipt of marketing communications such as our periodic newsletter and information about our products and services, provided you have indicated that you are happy to be contacted for these purposes; and
- Provide anonymised aggregate transaction data to your Employer, whether directly or, if applicable, indirectly via a relevant third-party reseller, for the purpose of informing the Employer about its employees’ preferred retailers and offers. LifeWorks logs digital EAP activities and provides anonymized summaries to the company for reporting purposes.
- When you visit the Website or access or use any App, LifeWorks may automatically collect additional information about you, such as the type of internet browser or mobile device you use, any Website from which you have come to the Website or App, your IP address, and your operating system, which are automatically recognized by our web server. You cannot be identified from this information and it is only used to assist LifeWorks in providing an effective service on the Website or App and to collect broad demographic information for aggregate use.
- The Website or Apps may, from time to time, make chat rooms, message boards, news groups and/or other forums available to its Users. Any information that is disclosed in these areas may be visible to others within your network and you should exercise caution when using these and never disclose your personal information or make any statement that you would not wish others to see.
How LifeWorks Shares Information
LifeWorks may share information about you with third parties in certain circumstances including in the following situations:
- Affiliates – LifeWorks may disclose your personal information to any of LifeWorks affiliates, or to LifeWorks agents or contractors who assist LifeWorks in providing the applicable services. LifeWorks agents and contractors will only use your information to the extent necessary to perform their function. For EAP services, LifeWorks will only disclose as needed for EAP services (e.g. name to start a live chat session).
- Behavioral Advertisers – LifeWorks may participate in behavioral-based advertising, excluding for LifeWorks’ EAP services. This means that a third party may use technology, such as a cookie on your browser or a web beacon, to identify you on LifeWorks website so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on LifeWorks Website, or on other websites. If you would like to “opt-out” of receiving behavioral advertising based on your use of this website, you can do so by visiting the Network Advertising Initiative and the Digital Advertising Alliance.
- Blogs, Online Postings, and Testimonials - LifeWorks may decide to allow users to share comments, postings, testimonials, or other information. If you choose to submit such information to LifeWorks, the information that you submit may be available generally to the public. Information you provide in these areas may be read, collected, and used by others who access them.
- Business Transition- In the event that LifeWorks, or any portion of our assets, are acquired, LifeWorks may share all types Personal Information with the acquiring company.
- Law Enforcement - LifeWorks may report to law enforcement agencies any activities that LifeWorks reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, LifeWorks reserve the right to release your Personal Information to law enforcement agencies if LifeWorks determine, in our sole judgment, that either you have violated our policies, or the release of your Personal Information may protect the rights, property, or safety of LifeWorks, or another person.
- Legal Process - LifeWorks may share your Personal Information with others as required by, or permitted by, law. This may include sharing your Personal Information with governmental entities, or third parties in response to subpoenas, court orders, other legal process, or as LifeWorks believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against LifeWorks, or to defend against possible legal claims that LifeWorks determine in our sole discretion might be brought against LifeWorks.
- Partners – LifeWorks may share information with other companies that provide products or services that LifeWorks think may be of interest to you.
- Service Providers - LifeWorks may share Personal Information with companies or individuals that provide us with services. These services may include, among other things, providing products or services to you or your employer on our behalf, creating or maintaining our databases, researching and analyzing the usage and performance of the website, preparing and distributing communications, and responding to inquiries. For EAP services, Lifeworks will only share anonymized information.
- Your Employer – Aggregate and statistical data is provided to your employer or in some instances your health plan provider. This aggregate information will assist in program planning to improve the overall health of your employer, or to evaluate LifeWorks performance. Should your employer offer an incentive program related to a LifeWorks service, confirmation that you have successfully participated might be provided to your employer so you can receive your incentive.
LifeWorks, its employees, and contractors take responsibility for personal information in accordance with LifeWorks policies and standards. LifeWorks is accountable for personal information it processes, including personal information that has been transferred to a third party to be processed. Contractual requirements will be used to provide a comparable level of protection wile information is being processed by a third party on LifeWorks’ behalf.
LifeWorks trains its employees with respect to its privacy policies and practices.
Notice, Choice and Consent
LifeWorks provides notice as to the purposes for which personal information is collected, used, retained, and disclosed. By using this product, you are consenting to the collection, use, disclosure and sharing of your personal information as described in this policy. If optional services form part of the services purchased by your employer, LifeWorks will describe choices available to individuals and may obtain explicit consent from you, as appropriate.
Subject to legal or contractual restrictions, LifeWorks shall abide by the withdrawal or variation of consent, and shall advise the individual of the consequences of a change in the scope of consent. In cases where consent has been obtained by the employer, the individual will be referred the customer.
Unless required by law, Lifework shall not use or disclose personal information for any purpose other than the purpose for which it was originally collected without first identifying and documenting the new purpose and obtaining the appropriate consent.
Once data has been de-identified, aggregated or summarized it shall no longer be considered personal information, and individuals cannot seek to have their information removed from an aggregated data set, nor is consent for further use required.
Retention and Disposal
LifeWorks retains Personal Information only as long as necessary to fulfill the purposes disclosed above or as legally required and thereafter appropriately disposes of such information.
LifeWorks will either physically or electronically erase the personal information or make it anonymous in a non-recoverable manner.
Access and Quality
Unless LifeWorks is permitted or required by law to prohibit access, you have access to your Personal Information for review and updating within the site by logging into your personal profile.
In delivering services, LifeWorks relies on employers and employees to supply LifeWorks with accurate, complete and up-to-date information that is relevant to LifeWorks’ delivery of the services. Individuals are asked to review their records on a regular basis and make the appropriate updates or notify their employer of errors promptly.
Where Personal Information is not made directly available to you, a request must be made in writing to case_info_request@LifeWorks.com. LifeWorks will provide access to personal information in accordance with the applicable data protection law.
How LifeWorks Secures Information
LifeWorks take reasonable and appropriate measures to help keep information secure, and to help prevent it from becoming disclosed to individuals who are not described in this policy. Even so, no security system is perfect and we cannot promise, and you should not expect, that your information will remain secure in all circumstances.
Individuals may raise concerns or complaints regarding their Personal Information with LifeWorks by completing the Data Privacy Complaint Form and submitting it via email to Privacy@LifeWorks.com or by mailing it to LifeWorks Privacy Office 5th Floor 675 Cochrane Drive, North Tower Markham, Ontario L3R 0B8.
If an individual files a complaint, LifeWorks will investigate the matter or suspected failures to comply with this policy. LifeWorks will take all appropriate actions to remedy any such issues. If the matter cannot be settled, LifeWorks agrees to cooperate with the dispute resolution system set forth below.
If individuals feel that their complaint was not satisfied, they may file a formal complaint with the regulatory bodies below.
- In Canada, the Privacy Commissioner of Canada or the Privacy Commissioner in the applicable province
Office of the Privacy Commissioner of Canada
30 Victoria Street
- In the E.U., the United Kingdom’s Information Commissioner’s Officer or their member state Data Protection Authority.
The Information Commissioner’s Office
Information Commissioner: Mr. Christopher Graham
c/o ICO International Team
Water Lane, Wycliffe House
Wilmslow-Cheshire SK9 5AF
Phone: +44 1 625 54 5 246
To contact the DPAs directly see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
- In Switzerland, the Swiss Federal Data Protection and Information Commissioner
Office of the Federal Data Protection and Information Commissioner FDPIC
CH - 3003 Berne
Telephone: +41 (0)58 462 43 95
Telefax: +41 (0)58 465 99 96
- In the U.S. , the Attorney General in the applicable state
LifeWorks’ will conduct periodic assessments to confirm the accuracy of this policy and verify its adherence to LifeWorks’ Privacy Principles. In addition, LifeWorks’ will deploy internal auditing measures to monitor its compliance with the Principles and to address all questions or complaints.
Changes to this Policy
EFFECTIVE DATE: 10/24/2016