Aon Solutions Canada Inc. (Health)

Why we collect, use and disclose personal information

Collecting personal information about you is essential to our being able to provide the products and services that best meet your needs (including individuals associated with you, all of whom we refer to as “Client” in this Privacy Policy). While the personal information we collect may come directly from you, it may also be provided by our affiliates or other third parties (such as employers, insurance companies and benefit administrators).

Personal information may be used for the following purposes that are integral to our services:

Consulting on health benefit needs, benefit plan design, benefit plan administration and governance, ongoing policy administration and related employment issues
Analysis of benefit plan performance and benchmarking to appropriate comparator groups
To determine eligibility and process applications for products and services and to provide information and services
To understand and assess ongoing needs of Clients and potential Clients and offer products and services to meet those needs
For communication, service, marketing, billing and administration
For benefits administration and data analysis and benchmarking
For fraud detection and prevention
Other purposes disclosed in our terms of business or disclosed to you at the time of collection, use or disclosure.

Personal information may also be used for additional purposes including:

For analytics
To develop proprietary tools and databases
To provide consulting services to insurance companies and clients
To comply with legal, audit, security and regulatory requirements

What information we collect

Depending on the products or services you request, we may collect information that you provide on applications for products and services. Information we collect may include but is not limited to:

Basic personal data and contact information (name, address)
Unique identifiers (Employee ID or payroll number)
Demographic information (date of birth, age, gender, marital status)
Employment information (date of hire, employment status, pay history, tax withholding information, date of termination)
Benefits program participation and cover information (benefit elections, retirement entitlement information, beneficiary information, claims information, benefit plan account balances or accrued benefits, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, or other adjustments)
Financial information (salary, tax code, third party deductions, bonus payments, benefits and entitlement data, national insurance contributions details)
Health related data (in relation to life, health, or employee benefits programs sponsored by the client/employer)
family status including dependents, beneficiary information
other relevant and necessary information and documents relating to the services we provide

In some cases you may provide us with information through technological means such as an online secure website. This information is used to administer your benefits program.

We may also automatically collect information through our marketing programs through the use of cookies, beacons and other technologies that track how you use our website and marketing communications.

Consent to use personal information

We may obtain your express consent or we may determine that consent has been implied by the circumstances. Express consent can be verbal (in person or over the telephone), written or by electronic application (including email). Implied consent occurs when we can assume you have given consent by some other action you take or decide not to take. For example, if you request a specific product or service and provide us personal information in that regard, we infer that you consent to us using that personal information reasonably to provide this service.

If you need to provide personal information about other individuals (such as employees, dependents, etc.), you must obtain their consent for these purposes prior to your disclosure to us.

When you request services from us, we ask that you provide information that enables us to respond to your request. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such personal information for these purposes. You also authorize us to use and retain this personal information for as long as it may be required for the purposes described above. Your consent remains valid even after the termination of our relationship with you, unless you provide us with written notice that such consent is withdrawn. You should note that by withdrawing your consent, or not providing it in the first place, you may limit or even prevent us from being able to provide you or an authorized third party (such as an employer) with the products or services desired.

In certain circumstances, refusing to provide personal information or withdrawing consent will mean that you will not be entitled to insurance policy issuance or renewal, insurance underwriting or claims administration of existing policies and could affect entitlement to coverage and benefits. Additionally, in certain circumstances we will not need to obtain consent or explain the purposes for the collection, use or disclosure of personal information. For example, this exception would apply if there is an emergency that threatens the life, health or security of an individual, for fraud detection or prevention, or if we must comply with a court order.

Sharing personal information with others

Aon only discloses personal information as is required and described in this Policy or as otherwise required by law. In providing our services, we may need to disclose the personal information we collect to affiliates, subsidiaries, successors and other service providers or agents who perform various functions for us. Such parties may be located in Canada, or in other jurisdictions outside of Canada. Where information is collected in Quebec such parties to which we disclose personal information may be located in Quebec or in other jurisdictions outside of Quebec. While your personal information is always subject to confidentiality obligations, while stored in another jurisdiction, it may be subject to the laws of that jurisdiction. As a result the information may be accessed by the courts, government, law enforcement, and regulatory authorities of that country.

Depending on the products or services that we provide to you, we may disclose personal information to insurance companies and/or their agents or underwriters, reinsurers, other benefits administrators and other parties who have a need for the information in order to make available insurance coverage and other products and services. If we are legally entitled to do so, we may share information with consumer reporting agencies, insurance reporting agencies and governmental authorities when requested to do so or in order to protect our business. We may also be required by law or by rules of arbitration or rules of court to share information.

Aon develops and uses proprietary platforms and databases to gather, store and use information about insurance policies and health and employee benefit plans, including, but not limited to, names, industry codes, policy types, premium and policy expiration dates as well as information about the insurance companies that provide coverage to its clients or compete for its clients’ insurance placements. Aon uses and combines this information and other information collected from Aon’s clients for the purposes of developing Aon’s products and services and Aon’s relationship with its clients (for example: benchmarking, market research, data analysis, and marketing of products and services that may be of interest to Aon’s clients) and to help insurance companies to strengthen their offerings for Aon’s clients. The databases may be accessed by Aon and Aon affiliates to provide consulting or other services to insurance companies for compensation as well as for other purposes described in this Privacy Policy.

As Aon continues to develop and grow, we may buy or sell parts of a business. As our businesses consist primarily of client relationships, information regarding the particular accounts or services being purchased or sold could include personal information and be one of the transferred business assets. We may also use this personal information to assess your future needs and to offer the products and services that may best meet those needs, from ourselves, our affiliates or reputable organizations selected by us. If you do not wish to receive these offers or such information, please contact our Privacy Officer as outlined in the Contact Information section.

Last Updated: September 22, 2023

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