At Saegis we understand the importance of privacy and the protection of personal information. Saegis1 places the highest value on ensuring the privacy and confidentiality of personal information entrusted to us and strives to comply with all legal and regulatory requirements.

This policy also complies with the requirements of Canada’s Anti-Spam Legislation (CASL) to ensure that appropriate consent has been obtained prior to sending electronic communications subject to CASL and that required unsubscribe mechanisms are readily available.

This privacy policy governs personal information collected by Saegis from or about individuals. As further outlined in this policy, Saegis collects, uses, and discloses information for the purposes of providing various services to its customers. Saegis also collects, uses, and discloses personal information, including electronic contact information, for reasons that are consistent with these purposes, or as permitted or mandated by law. Personal information is kept securely and retained only as long as necessary to fulfil its purpose. Except in limited circumstances, you have a right to access the information collected about you, within a reasonable time frame, in accordance with existing legislation.

Saegis will, from time to time, review and revise its privacy practices and this privacy policy. Policy changes will apply to the information collected from the date of the revised policy as well as to existing information held by Saegis at the time of amendment. Updates to this policy will be published on our website. Should you have any questions or concerns you may contact the Saegis Privacy Officer.

Personal information collected via the Saegis website is subject to the Saegis Privacy Statement, which is incorporated by reference as part of this policy.

Collection and use of personal information

Saegis collects personal information to fulfill the mandate of Saegis, which includes:

  • registering customers and processing payments for Saegis programs
  • communicating with customers
  • responding to inquiries and requests from customers
  • delivering Saegis programs
  • developing and delivering practice related solutions
  • conducting service-related surveys, providing educational programs, and other practice solutions
  • providing information about the services offered by Saegis
  • responding to inquiries received from individuals who are not customers of Saegis
  • promoting Saegis programs to members of the Canadian Medical Protective Association (CMPA)
  • meeting legal and regulatory requirements

Personal information is generally collected from the individual directly, or provided to Saegis by its parent company, the Canadian Medical Protective Association (CMPA). Saegis’ use of personal information is limited to these purposes or is consistent with them.

Saegis may receive personal information from the CMPA, such as your mailing address, contact and demographic information, for the purposes of offering particular services that may be of benefit to you. Saegis may also receive information from the CMPA to confirm membership with the CMPA or to update any contact information. For example, if you are a CMPA member and a customer of Saegis, when you inform the CMPA of an address change, this information may be changed for both organizations.  Saegis does not collect any information from the CMPA regarding members’ personal medico-legal information without consent.

We consider “personal information” to mean information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from the information. When you provide personal information, you agree and consent that Saegis may collect, use, and disclose your personal information in accordance with this privacy policy. Saegis does not sell, trade, barter, exchange or disclose for consideration any personal information. You are free to withdraw your consent. However, if you choose not to provide us with consent to collect, use, or disclose personal information, we may not be able to offer the services requested.

To the extent that any communication from Saegis qualifies as a “commercial electronic message” under CASL, the message will only be sent if appropriate consent has been obtained and a required unsubscribe mechanism is readily available. The term “commercial electronic message” is defined under CASL and includes an electronic message (e.g., email, instant messaging, text messaging) that offers to purchase, sell, barter, or lease a product, good or service; provide a business opportunity, or advertise or promote any of these items. You are free at any time to unsubscribe from receiving any future commercial messages that may be sent by Saegis.

For additional information about how Saegis collects information via our website, please see the Privacy Statement.

Disclosure of your personal information

Saegis will generally only disclose your personal information for purposes consistent with this privacy policy.

Disclosing information without consent

There are some circumstances where Saegis may disclose personal information without consent. Such circumstances include where Saegis:

  • is permitted or required by law, or by order of a court or tribunal
  • believes, upon reasonable grounds, that it is necessary to protect the safety of an identifiable person or group
  • believes it is necessary to establish or collect fees;
  • believes it is necessary to permit us to provide approved services, pursue or investigate available remedies (including legal remedies through a civil or criminal court process), or limit any damages that we may have or are likely to sustain
  • believes the information is public

Where obligated or permitted to disclose information without consent, Saegis will not disclose more information than is required.

Saegis will only disclose personal information about former customers in accordance with this privacy policy. Saegis retains the right to use non-identifiable information in any ethical way that it determines appropriate.

Accuracy and retention

Saegis endeavours to ensure that any personal information in its possession is accurate, current, and complete. Saegis generally retains personal information as long as Saegis believes it is necessary to fulfil the purpose for which it was collected.

Protection of personal information

Saegis endeavours to maintain adequate physical, procedural, and technical security with respect to its offices and information storage capabilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification or personal information. This commitment also applies to the disposal or destruction of personal information.

As part of those precautions, we restrict access to personal information to those employees and, under appropriate confidentiality agreements, external service providers we determine need to know that information in order that Saegis may provide its services. Saegis treats employee misuse of personal information as a serious offence for which disciplinary action may be taken. Saegis is also prepared to take all appropriate steps to enforce the provisions of confidentiality agreements with external parties.

Saegis may rely on service providers who are located in the United States and other countries. Some personal information collected by Saegis may therefore be retained in countries other than Canada where privacy laws may offer different levels of protection from those in Canada, and personal information my be subject to access by and disclosure to law enforcement agencies in those jurisdictions.

We audit our procedures and security measures, as appropriate, to ensure that they remain effective and reasonable. We take reasonable steps to confirm service providers adhere to accepted standards of information security.

Your Responsibilities

The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password to access some of our services, you are responsible for choosing a unique password and for keeping this password confidential.

While we take the security of your personal information very seriously, and we maintain a rigorous privacy program, we cannot guarantee the security of your information, and you provide us your information at your own risk. There are certain precautions you should take to maximize the security of your information. For example, you should regularly apply available security and application/system updates to your browser and operating system software, and protect your computers with up-to-date anti-virus and firewall software.

Access to your personal information

Saegis strives to provide access to personal information in keeping with all applicable legislation. Saegis may decline to provide access to personal information in accordance with existing legislation. We will provide information from our records in a form that is easy to understand and will also endeavour to provide explanations for any abbreviations or codes used. When possible, Saegis will also provide a list of organizations that may have received such information.

We may charge a reasonable cost (e.g., photocopying, mail charges) to the individual making the request.

Saegis reserves the right to decline to provide access to personal information where the information requested:

  • would disclose personal information about a third-party
  • would reveal confidential commercial information
  • could reasonably result in serious harm to an individual
  • may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions
  • was generated in the course of a formal dispute resolution process
  • is subject to solicitor-client or litigation privilege, or a professional privilege or obligation
  • is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information
  • does not exist, is not held, or cannot be found by Saegis
  • any other grounds under applicable legislation
  • as otherwise permitted by law

Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.

Saegis will not respond to repetitive or vexatious request for access and, in doing so, will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information. To guard against fraudulent requests for access, Saegis may require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.

Resolving your privacy concerns

In the event of questions about the collection, use, disclosure of or access to your personal information by Saegis, or Saegis’ CASL procedures, contact us:

Phone: 1-833-435-9979 or 613-729-3839

Address: 865 Carling Avenue, suite 110, Ottawa, Ontario K1S 5S8

Email: privacyofficer@saegissolutions.ca

1 Unless otherwise stated, any reference to Saegis includes Dow’s Lake Court Inc. c.o.b as Saegis and Saegis Safety Institute.