Employee Privacy Policy

Working Policy Purpose: This Policy ensures that regulatory & compliance obligations as set out in applicable Canadian Privacy Laws are met.

Working Policy Statement: This Employee Privacy Policy - Canada (“Policy”) is adopted by the Wawanesa Mutual Insurance Company, the Wawanesa Life Insurance Company and its wholly owned subsidiaries (“Wawanesa”, “we” or “us”) to comply with applicable Canadian Privacy Laws. The Policy applies solely to residents of Canada who are job applicants, employees, corporate officers and directors of Wawanesa (“you”). This Policy describes the categories of Personal Information (as defined below) collected by Wawanesa from you and the purposes for which we use and disclose such Personal Information.

Personal Information

For purposes of this Policy, Personal Information: means information about an identifiable individual. Personal Information about an employee or an applicant for employment may be collected, used, disclosed and retained in connection with the employee/employer relationship. It includes information that you have provided to us or information collected by us from other sources. It may include but is not limited to your name, residential and email addresses, age, gender, education, financial and health information.

1. Collection of Personal Information

We may collect the following categories of Personal Information about you:

Identifiers

Legal and preferred name mailing address, email address, date of birth, telephone number, marital status, work permit documentation, Social Insurance Number, bank account information if using direct deposit, or other similar.

Personal Information Categories

Name, signature, physical characteristics or description; address, telephone number, bank account number if using direct deposit; health insurance information, driver’s license number or Canadian/Provincial issued identification cards or numbers; Professional memberships, licenses and/or certifications; education or employment history.

Characteristics

Date of birth, native/preferred language, marital status, personal health information, sex and gender identity.

Internet or Network Activity

Browser history, search history, IP address, mobile device identifier, cookies, use of IT resources, and interaction with websites.

Geolocation data

Physical location.

Audio or visual data

Audio and video recordings, employee photos, images or pictures that may identify individuals.

Professional or employment-related information

Current or past job history, performance evaluations, internal reviews, communications and employee files.

Inferences drawn from other personal information

Profile reflecting a person's preferences, characteristics, behaviour, attitudes, intelligence, abilities, and aptitudes.

2. Use, Disclosure, Retention

Wawanesa protects personal information in a manner appropriate for the sensitivity of the information. Wawanesa employs adequate administrative, physical, and technical safeguards and makes reasonable efforts to prevent loss or misuse of, unauthorized disclosure, copying, modification, disposal, or destruction of, or unauthorized access to, personal information. We will only use or disclose your Personal Information for the purposes for which it was collected and otherwise as identified in this Policy.

We may use the Personal Information we collect from you or about you for the following purposes:

To evaluate eligibility and qualifications for employment, including administering pre-employment checks;
To establish, manage or terminate an employment relationship;
To establish and maintain communication with you;
To conduct performance evaluations, determine and recognize performance;
To assess qualifications for a particular job or task;
To establish training and/or development requirements;
To gather evidence for disciplinary action, or termination;
To manage a post-employment relationship between Wawanesa and the individual;
To establish a contact in the event of an emergency (such as emergency contact)
To administer pay and benefits;
To manage disability management (including work-related claims) and accommodations;
To arrange and manage Wawanesa sponsored events;
To develop and evaluate diversity programs;
For recordkeeping purposes;
To reimburse for expenses;
For research, analysis, and business development, including to develop and improve our business processes and services;
To develop, maintain and improve our website and services relating to your employment or potential employment;
To protect the safety and security of Wawanesa’s employees and to maintain the security and integrity of our systems, our assets and our facilities;
To respond to law enforcement requests and to comply with applicable labour; employment statutes and regulatory requirements, or as requested by government or regulatory authorities, law enforcement or court order;
To establish or defend legal claims and allegations;
For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, or other misconduct;
To seek advice from lawyers, auditors and other professional advisers.

We may disclose or share your Personal Information with the following:

Members of the Wawanesa Group (Wawanesa Mutual, Wawanesa Life, and its wholly owned subsidiaries)
We may share your Personal Information within the Wawanesa Group of companies to compile and review employment related information and for other analytics purposes, for legal and regulatory purposes, to ensure that the information that we have about you is correct, and to manage our relationship with you.
Regulatory and law enforcement.
We may disclose your Personal Information to regulatory or law enforcement authorities, anti-fraud organizations in cases of suspected criminal or other illegal activity, to detect and prevent fraud, or where we are otherwise required to satisfy a legal obligation that has been placed on us, such as in the case of a court order.
Service providers
We use third party service providers to provide certain services on our behalf which enable us to establish, manage and maintain our employment relationship with you.

Our retention periods for Personal Information are based on our business needs and legal requirements. We retain Personal Information for as long as is necessary for the purpose(s) that we collect it for, and any other permissible, related purpose. We may retain certain information to comply with regulatory requirements regarding the retention of such information. When Personal Information is no longer needed, we either anonymize or destroy it.

3. Access to Information and Questions

As a general rule, every employee has the right to consult and obtain communication of personal information which concerns him, her, they or them and which is contained in a file held by Wawanesa. An employee can also request that information which is inaccurate, incomplete or equivocal be rectified and that information not justified by the purpose of the file be deleted.

Wawanesa will respond to every request for access and rectification within 30 days of receiving the written request. In the event that Wawanesa cannot provide access to or rectify personal information, it will inform the employee concerned of the reasons why, subject to any legal or regulatory restrictions, and it will provide the person with any recourse available.

Access to information requests or questions you may have about this Policy can be directed to your Leader, Human Resource representative or to the Wawanesa Privacy Office:

By Mail:
The Wawanesa Mutual Insurance Company
Attention: Chief Privacy Officer
191 Broadway, Winnipeg, Manitoba, R3C 3P1

Email: privacy@wawanesa.com
Phone: 1-844-241-0226

4. Revisions to this Privacy Policy

Wawanesa may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will communicate any revised version of this Privacy Policy. Any changes to this Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change. This Privacy Policy was last reviewed as of the Effective Date set forth below.

5. Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by the Privacy Office. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation’.

This Privacy Policy does not create or confer upon any individual any rights or impose upon Wawanesa any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual's personal employee information. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.