MHS Privacy Policy

MHS is committed to safeguarding the privacy of personal information that is provided to us in order to purchase our products and services. Our commitment has led to the establishment of a comprehensive Privacy Policy that complies with the Canadian federal government's Personal Information Protection and Electronic Documents Act ("PIPEDA"). This Privacy Policy specifically defines why and how we collect, use and disclose your personal information.

Contents


1. Why does MHS gather personal information?
(a) Why does MHS collect my personal information?
To purchase MHS products, customers must be registered with MHS. The purchase process involves completion of a Qualification Form to determine eligibility to purchase restricted products. You are asked to provide your name, social security number or tax identification number, address, license number, credit card information and other personal or non-personal information which are required in order to process your purchase request as well as maintain your customer account.
To become EQ-i® or MSCEIT™ certified, MHS requires completion of the relevant assessment tool as well as other personal information gathered through the Qualification Form and purchase process.

(b) Do I have to provide you with my personal data?
You may visit and browse the MHS Online Catalog or make general inquiries without providing any personal information. You will need to register with MHS if you would like to make a purchase of our products and services. By completing the purchase process you consent to MHS' Privacy Policy.
Before purchasing through the MHS Online Catalog, please read the additional Terms and Conditions
All prices are subject to change without notice. Customers are responsible for any applicable duties and taxes. Prepayment by credit card (Visa, MasterCard or American Express) is required for all orders. If prices on your order are incorrect, we reserve the right to adjust the invoice amount by up to 10% unless otherwise stated on your order.

(c) What kind of personal information does MHS need to keep on record?
MHS retains personal information in order to maintain customer accounts and/or to maintain a record of your certification status. Certification results are retained by MHS but are de-identified and never disclosed to a third party, including an employer, without prior consent. MHS also retains aggregate, non-person-specific data obtained from the processing of MHS products and services, for research and statistical purposes for internal use by MHS, its affiliates, subsidiaries, licensees, successors, assigns, suppliers, and advertisers. Your identity is kept strictly anonymous.


2. How will MHS use my personal information?
(a) Will you share my information with anyone else, like marketing companies?
Under no circumstances does MHS sell, rent, distribute, or release personal information to a third party, unless required to do so by law, in the course of a merger or acquisition, due diligence, or sale of assets. MHS may use your personal information and transaction history to generate statistics and aggregate reports for internal use as well as to extend further sales and service offerings via telephone, mail, or other electronic means.

MHS uses your personal information to process your order and contact you in response to your request. We may use it to send you marketing materials about additional information about the products and services that we offer.
Please note that MHS has no responsibility for the privacy policies and practices on websites that may be linked to our website or to companies that may provide additional products or services. You should refer to those organizations' privacy policies to learn how they collect, use and disclose information about you.

(b) How do you ensure my personal information is safe?
Purchasing test materials or administrations or becoming certified by MHS does not involve the transfer of personal information of our client's customers. With respect to our scoring software, MHS does not receive, create, or use identifiable personal information, including personal health information through its software. MHS' scoring software, e.g., PsychManager™ or SmartLink™ are stand-alone platforms that are intended to run on a single desktop, but can be integrated into a network of PCs. No personal information is disclosed to MHS while using the software.

In regards to our mail/fax scoring services, MHS encourages our customers to provide client ID numbers (not a Social Insurance Number (SIN) or a Social Security Number (SSN)) rather than a client's name on the response sheet so that MHS does not receive any identifiable personal information about a client. By doing this, MHS has no way to link the ID number with a specific individual. MHS will, however, accept, for scoring purposes, any response sheets that contain a client's name, age, responses, and other personal information. Answer sheets, once received, are kept in a locked, access-restricted cabinet. Those that are faxed, are accessible on our internal network only by client service representatives and others authorized to access such material.

To further protect the data transmitted to MHS, MHS' online scoring services shall encrypt access passwords, which mean that identifiable data  is made accessible only to our customers or their designated administrators ("Administrators").  Administrators will be prompted to change their existing password the first time they log into the MHS Scoring Organizer. The client's information, including any personal information,  is not  accessible by MHS unless an Administrator provides MHS with his or her protected password. MHS will be able to reset a password, at the request, of an Administrator if necessary.

Security
Any personal information contained in the Qualification Form that is mailed or faxed to MHS is stored in a locked cabinet or in a locked room with access restrictions. To protect the privacy of information sent electronically, including your name, address, email and credit card number, and your client's test results, a secure server is utilized. MHS employs an advanced security system, Secure Socket Layers (SSL) encryption technology to protect the transmission of your information. For example, only when personal information reaches MHS' online store server is your the information decrypted. However, we remind you that given the nature of internet communications, your communications may be susceptible to data corruption, interception and/or delays, and your privacy cannot be guaranteed.
(c) What will MHS do in the event of a potential breach involving client’s information?
In the event that MHS becomes aware of a security breach which MHS believes has resulted or may result in a risk of harm in the unauthorized access, use or disclosure to nonpublic personal information of our clients, MHS will promptly investigate the matter and notify the applicable parties of such breach. Such investigation will be without delay, consistent with (1) legitimate needs of law enforcement and the Privacy Commissioner’s Office; (2) measures necessary to determine the scope of the breach; (3) efforts to identify the individuals affected; and (4) steps to identify cause of breach and restore the reasonable integrity of our secure server.

MHS employees, customers and/or sponsors are required to contact the Privacy Officer immediately when made aware of a potential breach or any privacy noncompliance issue at MHS.

 (d) How does MHS use information received from website visitors?
Our website obtains information that is automatically generated by a user's Internet Service Provider (ISP). This information may include the IP address, domain types, the browser type used to access our site, the location of the ISP's servers, the pages of our site that the user views during the visit, any search terms entered on this site, the website address and email address of a user, and any other information transmitted from the user. This information may be collected for system administration purposes, to gather broad demographic information, to monitor the level of activity on the site, for technical support, and to improve our website by responding to customer interests and needs.
MHS does not link IP addresses to personal information; however, we reserve the right to link IP addresses and other information supplied by the ISP to personally identifiable information for security purposes in order to protect the integrity of our system.
(e) Does MHS use cookies?
Cookies are small text files that a website transfers to your computer's browser. We may use cookies to measure traffic patterns, to personalize content and to control security. The cookies we use supply non- personally identifiable information, but may identify your computer, browser, and Internet specifications.

(f) How long does MHS keep information about me?
After you have completed what you registered for, MHS will, as a matter of policy keep on file a record of (i) the products and services you have purchased; (ii) your certification status; (iii) your contact information; and (iv) any aggregate de-personalized information including test data, indefinitely.


3. How do I change or update my personal information or opt out of receiving marketing materials?
(a) How can I update my information or opt out of receiving marketing materials?
If you want to change, update, remove your personal information or opt out of receiving marketing materials from MHS, please email Customer Service at: customerservice@mhs.com or phone 1-800-268-6011 (within Canada), or 1-800-456-3003 (in the U.S.), or 1-416-492-2627 (outside of Canada & the U.S.).

(b) Will you let me know if you make changes to the MHS Privacy Policy?
If we make important changes, we will notify you by posting a notice on our home page at www.mhs.com/ and/or notify you by mail or email, as needed. Once we tell you about such changes, you will let us know that you accept them by continuing to use our website and our services. In addition, since MHS has the right to change this policy, as circumstances require, you should visit our website from time to time to re-read the policy.


4. Where can I get additional information about the Privacy Legislation and Contact MHS if I have questions or concerns?
(a) Where can I find out more about the privacy legislation?
You can get more information about the new privacy legislation from the Government of Canada Privacy Commissioner's website at www.privcom.gc.ca

(b) Who at MHS should I contact with questions or concerns about this Privacy Policy?
If you have any questions or concerns pertaining to this Privacy Policy or have any other privacy-related issue pertaining to the personal information you provide us, please let us know by contacting our Privacy Officer. This person is responsible for making sure that your personal information is protected and for dealing with any privacy-related issues that may arise.


5. Statement of Compliance
MHS is committed to controlling the collection, use, and disclosure of personal information in accordance with PIPEDA. MHS has adopted the Canadian Standards Association's Model Code for the Protection of Personal Information which is recognized as the national standard for the collection, use, and disclosure of personal information and which principles are reflected in Schedule 1 to PIPEDA.

As such, MHS will meet the following requirements, unless exempted by law or under PIPEDA:

(a) Accountability
MHS is responsible for personal information under its control and shall designate a Privacy Officer who will be accountable for MHS' compliance with the Act.

(b) Identifying Purposes
The purposes for which personal information is collected shall be identified by MHS at or before the time the personal information is collected.

(c) Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where exempted under the Act.

(d) Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by MHS. Personal information shall be collected by fair and lawful means.

(e) Limiting Use, Disclosure, and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted or required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

(f) Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

(g) Safeguards
Personal information shall be protected by security safeguards appropriate to the sensitivity of the personal information.

(h) Openness
MHS shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

(i) Individual Access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that personal information. An individual shall be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate.

(j) Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles. Please email any compliance concerns to the Privacy Officer at: privacyofficer@mhs.com.


You can contact the Privacy Officer at:
Multi-Health Systems Inc.
3770 Victoria Park Ave.
Toronto, ON, M2H 3M6
Email: privacyofficer@mhs.com
Telephone: 416-492-2627
Fax: 416-492-3343