By using the Platform, you consent to the collection and use of your Personal Information by Howatt HR and our agents, as described in this Policy.
“Account” means the unique user identification generated by the IP address of each new User who accesses the Portal.
“Aggregate Data” means the data which may be provided to the Client Organization in a statistical format which shall not include any personal identifiable information.
“Client Organization” is the organization who has retained Howatt HR to perform the Mental Fitness Index Assessment for their employees, agents, contractors, or members.
“Data Aggregation” is the process by which individual MFI results will be combined, and the data will be expressed in summary form, with the removal of any identifying information which would result in the exposure of the identity of any user.
“Identifying Information” means personally identifiable information that identifies an individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify an individual. This includes information such as your name, address, e-mail address, job position within an organization, and date of birth.
“Non-Personal Information” is information of an anonymous nature, such as an Internet Protocol Address (IP Address), the domain used to access the site, and the type and version of browser or operating system being used. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, average time spent on the Site, and information volunteered by the user, such as survey information, is also considered Non-Personal Information.
“Personal Health Information” means identifying information about an individual, if the information relates to the physical or mental health of the individual, including information that consists of the health history of the individual’s family, relates to the provision of health care services to the individual, or as it relates to payments or eligibility for health care, or eligibility for coverage for health care, in respect of the individual.
“Personal Information” within the context of this Policy, means both Identifying Information and Personal Health Information.
Collection of Personal Information
Registration: Personal Information may be collected from Client Organizations to initiate Users’ access to the Platform. This allows expedition of Users’ enrolment and access to the Platform, and may include without limitation, the User’s name, e-mail address, telephone number, and job position, therefore allowing for the user to access the Platform with their unique User ID. Howatt will only retain such personal information for as long as is reasonably necessary in allowing the user access to the Platform.
It is not the intention of Howatt HR that Personal Information or Personal Health Information will be collected as a part of the Mental Fitness Index Assessment. However, the Mental Fitness Index may include generally non-identifiable employee demographics (indirect PII) (these are: Generational Group, Gender, Years of Service, Education Level. Debt Load, Work Hours per Week, Commute Time, Working Arrangement (e.g. from office, from home), Care Responsibilities (children, pets), Chronic Health Conditions, Yearly Vacation Time, and Daily Stressors). If any group of users is not large enough so that any of the above demographics should become personally identifiable information, such information will be removed during the Data Aggregation process.
Any information submitted through the Platform which may have identifiable characteristics, ie., job details which would cause the user to be identified by the Client Organization, will be removed prior to aggregate information being provided to the Client Organization if aggregate information is to be provided. Such Personal Information shall only be retained only for as long as is necessary. Any Personal Information or Personal Health Information which is submitted by a user through the Platform shall be removed as soon as possible, and will not ever be shared with the Client Organization or any other third party.
Use of Personal Information
We do not (nor do we intend to) sell or otherwise market Personal Information to third parties. We limit the collection, use, retention and disclosure of Personal Information to that which is reasonably necessary for the purposes outlined below. By using the Platform, you consent to our
collection from, verification with and communication to the Provider and any third party for the purposes set out in this Policy, by Howatt HR and any corporation, company or other entity effectively controlling or controlled by Howatt HR or associated with others under common control or ownership, and includes, but is not limited to subsidiaries (the “Affiliates”). Personal Information will not be used without your consent for any purpose other than those mentioned in this Policy.
Law and Compliance
In addition to compliance with the Federal Personal Information Protection and Electronic Documents Act, Howatt HR has adopted the Privacy and Confidentiality Standards as described by the Canadian Institutes of Health Research, Natural Sciences and Engineering Research Council of Canada, and Social Sciences and Humanities Research Council of Canada, as well as the Tri-County Policy Statement: Ethical Conduct for Research Involving Human Subject Chapter 5. Thus, all disseminated results are presented in an aggregate format. If a user group is comprised of less than 30 people, their aggregate data will not be disseminated to ensure participant confidentiality.
Agents and Contractors
Howatt HR may hire other companies or contractors to provide services on its behalf (the “Agent”). Howatt HR gives Agents only the Personal Information they need to deliver the service. Howatt HR requires Agents to maintain the confidentiality of the Personal Information and prohibits them from using such information for any other purpose.
Howatt HR and its Agents may use your Personal Information for the following purposes:
To provide users with a Mental Fitness Index score and to generate customized improvement tools, to provide a Client Organization with statistical information and aggregate reports, and statistics and aggregate reports to improve the Portal.
All Platform information will be collected and hosted by Howatt HR’s data collection system, provided by Voxco and the servers are located in Montreal, Canada. Howatt HR uses commercially reasonable efforts to ensure that your Personal Information is stored and maintained in a secure environment. Howatt HR uses encryption technology such as TLS/SSL during transmission and the storage of Personal Information. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
Howatt HR will keep your Personal Information for as long as necessary in connection with the purposes identified in this Policy or as required by law, which may extend beyond the termination of Howatt HR’s relationship with the Patient or Provider. You must notify Howatt HR at firstname.lastname@example.org if you no longer want your information to be retained by Howatt HR. Upon receipt of such request, Howatt HR will use best efforts to delete your personal information within ninety (90) days of your request.
You acknowledge and agree that it may not be possible to completely delete all Personal Information due to technological and legal constraints. Such a legal constraint may include the requisitioning of Howatt HR by provincial or federal government entities to disclose Personal Information for the purpose of an investigation.
Third Party Websites
Access to Personal Health Information
Changes to This Policy
Howatt HR may amend and update this Policy at any time, which will be reflected by the “last modified” date below. It is recommended that you read over this Policy from time to time to keep informed of Howatt’s commitment to the protection of your private information and any changes to this Policy. You must agree to this Policy and any changes to this Policy prior to continuing use of the Platform.
Should you have any questions or concerns about this Policy, please send your correspondence to:
Jesse Adams, Privacy Officer Howatt Strategic HR Consulting Inc.
3646 Acadia Street Halifax, Nova Scotia B3K 3P6
All privacy communications will be confidential.
Last Updated: March 18, 2021