Privacy Policy

Effective Date: July 1, 2025

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Ellement Consulting Group Limited Partnership (“Ellement”, “we”, “us”, or “our”) is committed to protecting your privacy and ensuring the confidentiality and security of your personal information.

This Privacy Policy (“Policy”) explains how we collect, use, disclose, retain, and protect personal information in connection with the administrative services we provide for benefit and pension plans. It also outlines your rights and how you can exercise them.

Our privacy practices are guided by the Canadian Standards Association’s Model Code for the Protection of Personal Information and comply with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant provincial legislation.

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1. Scope

Ellement is a third-party administrator (TPA) that provides administrative services and, where applicable, actuarial and consulting services for employee benefit and pension plans sponsored by our clients (collectively referred to as the "Client"). Ellement handles personal information strictly on behalf of, and under the authority of our Clients, in accordance with governing plan documents, service agreements, and applicable privacy legislation.

This Policy applies to all personal information collected, used, or disclosed by Ellement in the course of delivering our services. It is intended to provide transparency regarding our privacy practices across all business operations, including - but not limited to - administrative systems, client portals, communication platforms, and customer support services.

This includes, but is not limited to, personal information collected through:

Member and client communications;
Employers, unions, and trustees;
Enrollment or claims processing;
Ellement-operated websites, portals, and digital tools;
Paper-based or electronic correspondence;
Customer service interactions;
Retirement and pension-related services, where applicable.

This Policy applies to all Ellement employees, contractors, and authorized third-party service providers who handle personal information on our behalf.

2. Personal Information

“Personal Information” refers to any information about an identifiable individual. This may include your name, date of birth, social insurance number, employment details, as well as more sensitive information such as health and financial records used to administer benefit or pension plans. Where applicable, this also includes information about other individuals related to you, such as your spouse, common-law partner, children, and beneficiaries.

3. Collection of Personal Information

Ellement collects personal information only to the extent necessary to fulfill the purposes outlined in this Policy or as required by law. Information may be collected directly from you, indirectly through your union, employer, plan sponsor, trustees, healthcare providers, government departments, other third-party service providers, or through your use of our Online Services, which include our websites, portals, and mobile applications. Personal information may be collected through various means, including electronic forms, paper documents, telephone conversations, or in-person interactions. If you contact us—or we contact you—by phone, the call may be recorded for monitoring, training, and quality improvement purposes.

Depending on the nature of your relationship with us, the types of personal information we may collect include, but are not limited to:

Identification and contact details;
Plan-related data;
Dependant and beneficiary information;
Employment-related data;
Login and technical data.

Examples of purposes for collecting personal information include, but are not limited to:

Verifying eligibility for benefit or pension plans;
Enrolling you and your eligible dependants in these plans;
Processing benefit or pension claims;
Performing actuarial, administrative, or statistical analyses;
Ensuring compliance with legal and regulatory requirements;
Detecting and preventing fraud or unauthorized activities;
Communicating important updates and information related to your benefit or pension plans.

We may also collect personal information through the use of cookies and similar tracking technologies when you use our Online Services. Cookies help improve your experience by storing your preferences and simplifying future visits. You can manage your preferences and control how cookies are used by accessing your browser settings.

4. Use of Personal Information

Personal information is used for the following purposes, including but not limited to:

Administering and managing benefit and/or pension plans on behalf of our Clients, including verifying identity and eligibility, enrolling you and your eligible dependants, maintaining accurate participant/member records, and supporting continuity of plan administration;
Processing claims, entitlements, and contributions related to benefit or pension plans;
Communicating important plan information and updates, including features or services available to you;
Responding to inquiries and supporting service delivery through our various support channels;
Coordinating with authorized parties, such as insurers, actuaries, consultants, auditors, regulators, plan sponsors, trustees, healthcare providers, and government bodies;
Conducting audits, investigations, and quality control activities to ensure operational integrity and compliance;
Managing risk and meeting legal, contractual, and regulatory obligations, including:
- Preventing and detecting fraud, misrepresentation, or criminal activity;
- Responding to lawful requests or orders from courts, law enforcement, or regulatory authorities;
- Complying with tax reporting and related regulatory requirements.
Collecting feedback on our services and Online Services (e.g. through optional surveys) to improve performance, user experience, and service quality;
Improving our business operations and service delivery, including through analytics and process enhancement.

We may, with your explicit consent, use your personal information to provide you with information about products or services that may be of interest to you. You can manage your communication preferences at any time by updating your settings through the member portal or by contacting us directly.

5. Disclosure of Personal Information

Ellement does not sell or commercially share your personal information. We disclose personal information only when necessary, and only to authorized parties, to fulfill the purposes outlined in this Policy or as required by law.

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Authorized recipients may include, but are not limited to:

Clients such as plan sponsors, employers, unions, and trustees;
Insurance carriers and reinsurers;
Auditors, consultants, actuaries, and legal counsel;
Authorized administrators and third-party service providers;
Government departments, regulatory agencies, courts, and law enforcement bodies;
Other parties as permitted or required by applicable laws.

Some of these parties may be located outside your province or outside Canada. In such cases, your personal information may be subject to the laws of those jurisdictions, including access by foreign governments or authorities.

We may also share information with government or regulatory bodies when required to comply with legal obligations or to detect, investigate, or respond to fraud, cyber threats, misrepresentation, or criminal activity.

In all cases, we ensure that any third party handling personal information on our behalf is bound by appropriate contractual, technical, and organizational safeguards that meet Ellement’s privacy and security standards.

6. Protection of Personal Information

Ellement takes the security of personal information seriously. We employ a combination of administrative, technical, and physical safeguards to protect personal information against unauthorized access, use, disclosure, alteration, or destruction.

These measures include, but are not limited to:

Secure facilities and restricted access for authorized personnel;
Role-based access controls and authentication protocols;
Encryption of sensitive data during transmission and storage;
Ongoing monitoring and regular security audits of our systems and networks;
Policies and procedures for secure data handling, retention, and disposal;
Privacy training and awareness programs for all employees.

We are committed to maintaining high standards of information security. Our safeguards are regularly reviewed and updated to reflect evolving risks, emerging technologies, and industry best practices. We take every reasonable step to ensure that the personal information we manage remains protected and confidential at all times.

7. Use of Technology and Analytics

Ellement’s online services - including our websites, portals, and mobile applications - may use technologies such as cookies, log files, and session tracking tools to enhance performance, improve functionality, and support service delivery. These tools help us better understand how users interact with our platforms so we can continuously improve the user experience. Information collected through these technologies is used solely for internal analysis and service optimization and is not shared externally.

We may also use technologies such as artificial intelligence and chatbots to streamline interactions and enhance client support. When these tools interact with personal information, we apply the same strong privacy and security safeguards that guide all our data handling practices, in full compliance with applicable privacy standards.

These technologies do not collect personally identifiable information unless you voluntarily provide it. Information gathered may include, but is not limited to:

Browser type and version;
Pages visited and time spent;
Device type and operating system;
Interaction patterns and session behaviors.

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, but doing so may affect your ability to use certain features of our online services.

8. Accuracy of Personal Information

We are committed to ensuring that the personal information we collect, use, and disclose is as accurate, complete, and up to date as necessary for the purposes for which it is used. We rely on individuals, employers, plan sponsors, and service providers to provide accurate information and to notify us promptly of any changes.

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Where available, individuals may review certain personal information through our secure member portal and request updates or corrections directly. If you believe that the personal information we hold about you is incorrect or incomplete, you may also request a correction by contacting us using the information provided in the “Contact Us” section of this Policy.

We will respond to requests and make appropriate updates as required under applicable privacy laws.

9. Retention and Destruction

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by our internal policies, legal obligations, regulatory requirements, or contractual agreements with our clients.

The length of time we keep personal information may vary depending on the type of information and the nature of the services being provided. In some cases, we may retain certain information for extended periods to ensure continuity of service, support audits, resolve disputes, enforce agreements, or comply with applicable laws.

Once personal information is no longer required, it is securely destroyed, erased, or de-identified in accordance with industry standards and applicable legal requirements.

10. Policy Updates

We may update this Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we do, we will provide notice and update the “Effective Date” at the top of this policy. Updates are effective as of the date the notice is given.

Your continued use of our services following any changes to this Policy signifies your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

11. Consent

By providing your personal information to Ellement - whether directly or indirectly through your union, employer, plan sponsor, healthcare provider, or other authorized third parties - you consent to its collection, use, and disclosure as described in this Policy and as permitted or required by law.

Consent may be obtained in a variety of ways, including but not limited to:

Explicitly, such as through signed forms or online acknowledgments;
Implicitly, such as by submitting a claim, enrolling in a plan, contacting us, or using our Online Services; or
Through authorized representatives, such as your union, employer or healthcare provider who provide your information to us for administrative purposes.

Use of Ellement’s Online Services also signifies your agreement to the collection of personal information as outlined in this Policy, including through tools like cookies and usage analytics.

12. Your Privacy Rights

At Ellement, we believe you should have clear visibility and control over your personal information. As part of our commitment to transparency and accountability, you have the following rights regarding the personal information we handle on behalf of our clients:

Access – You can request access to the personal information we hold about you.
Correction – You can ask us to correct your personal information if it’s inaccurate or incomplete.
Inquiries – You have the right to ask questions about our privacy practices at any time.

Requests must be made in writing and may be subject to verification. In some cases, we may be unable to fulfill your request due to legal, contractual, or regulatory limitations. If that happens, we’ll explain the reason and inform you as soon as possible.

Contact Us‍

Ellement has designated a Privacy Officer who is responsible for overseeing compliance with this Policy and ensuring that your personal information is handled in accordance with applicable privacy laws and best practices.

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You may contact the Privacy Officer with any questions, concerns, or requests related to your personal information.

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Privacy Officer
Ellement Consulting Group Limited Partnership

1345 Taylor Avenue, Winnipeg, MB, R3M 3Y9

Email: privacy@ellement.ca