People Corporation has policies in place with respect to privacy and accessibility, applicable to all entities and divisions. Full details are provided below.
People Corporation and you – Partner in Privacy
Knowledge and Consent
The central concepts of PIPEDA are Knowledge and Consent. Under PIPEDA, organizations are required to obtain the consent of individuals before acquiring and handling their personal information. In obtaining consent, it is the responsibility of the organization to identify the purpose(s) for which the personal information is being collected, as well as how it will be used, disclosed, etc., when the information is collected. The use or disclosure of such information is limited only to those purposes consented to by the individual.
People Corporation Privacy Practices
Enrolment and claims information will be collected from plan sponsors for their plan members:
- To enrol the employee (and spouse/partner/eligible dependents where applicable) in the elected plan coverage, to correct or amend member information, or to implement changes to coverage that may be enacted over the term of the plan;
- To verify eligibility and authenticate the identity of the employee and/or eligible dependents;
- To ensure benefits are paid in accordance with the policy provisions;
- To protect the plan from undue expenses due to error or fraud by auditing and reporting on plan activity to the plan sponsor;
- To only use such information as is required to provide the services outlined in the group benefits contract.
Enrolment and other plan member records will be secured in locked cabinets while on People Corporation premises. Such documentation will be retained for a reasonable period of time after the member has left the plan, or after the plan has terminated, to ensure any and all outstanding claims can be adjudicated in accordance with the plan design. When documentation is destroyed it will be shredded.
People Corporation Complaint Process
The following process will be used when responding to Privacy Act complaints:
- The complaint should be made in writing to the People Corporation Privacy Officer at firstname.lastname@example.org
- The Privacy Officer will investigate the complaint and provide a written report of his/her findings to the Executive Team of People Corporation. The investigation will require sufficient time so as to be thorough; however, will be completed in a timely manner;
- The Executive Team will respond to the complainant outlining the outcome of the investigation and if necessary, identify any remedial steps that will be taken to resolve the complaint and the timeframe in which such steps will be completed;
A copy of the complaint, the investigation report, the outcome, along with a record showing the completion of any required remedial steps will be retained by People Corporation and will be made available to the Privacy Commission at their request.
Accessibility at People Corporation
People Corporation and its affiliates and subsidiaries actively foster a culture where all people are treated fairly, with dignity, mutual respect and professionalism, and we uphold the principles of diversity, acceptance of differences, and respect for others.
Creating a working environment for our employees, and a service experience for our clients, that respects the dignity and independence of all people, including people with disabilities, is a central part of this commitment.
People with disabilities should have:
- the opportunity to access and use our goods and services and to benefit from those services, in the same place and in a similar manner as other clients.
- information and communication available in an accessible format.
- positive and productive experiences accessing our websites and other digital tools.
- full and meaningful participation in our workplaces as People Corporation employees.
People Corporation is committed to meeting all provincial and territorial legislative requirements related to Accessibility, including the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Accessibility for Manitobans Act, 2013 (AMA), the Nova Scotia Accessibility Act (2017), and all relevant Human Rights Codes. Where the requirements differ, the highest standard is adopted regardless of location to ensure compliance.
Information and Communication
People Corporation will meet the communication needs of people with disabilities in a manner that is appropriate for them by:
- training all representatives of People Corporation on how to interact and communicate with people with various types of disabilities;
- ensuring that our representatives who communicate with clients over the telephone are trained to speak clearly, slowly and in plain language;
- offering other means of communication, or providing alternate formats for documents upon request, and at no additional charge; and
- ensuring our digital content and websites meet Web Content Accessibility Guidelines (WCAG) 2.0 Level A and AA criteria.
People Corporation is committed to digital accessibility, and to being fully compliant to the Web Content Accessibility Guidelines (WCAG) 2.0 Level A and AA and complying with the AODA effective communication requirements.
To accomplish this, we have partnered with eSSENTIAL Accessibility to administer our accessibility program and oversee its governance. Their accessibility program evaluates our digital products on an ongoing basis in accordance with best practices and is supported by a diverse team of accessibility professionals, including users of assistive technologies. The platform, moreover, goes beyond minimum compliance requirements by making an assistive Client Experience technology application available to clients who have trouble typing, gesturing, moving a mouse, or reading.
Persons with disabilities are welcome to use their own assistive devices when accessing People Corporation’s services or offices. All representatives are trained on how to support those using assistive devices, as well as on any assistive devices or accessible features we may have available in our offices.
People Corporation welcomes support persons accompanying a person with a disability and makes space available so that the individual always has access to their support person. All representatives are provided with training to ensure that consent is obtained prior to sharing any personal information in the presence of the support person.
Service animals accompanying a client are allowed entry to all areas of our offices accessible to the public. All representatives receive training on how to support clients accompanied by service animals in an appropriate manner.
Notice of Service Disruption
If People Corporation’s ability to provide accessibility features in a publicly accessible space is disrupted, such as an elevator being out of service, we will provide notice of that disruption with as much notice as possible. This notice will include the reason, the anticipated duration and whether there are other ways to access our services during the disruption. Notices will typically be placed at all public entrances, at service counters, and we will make every effort to notify clients who have appointments by email or telephone.
When completing major renovations of our existing offices, or selecting new office space, People Corporation will ensure that our locations with client access meet the baseline level of accessibility for public spaces per the relevant provincial legislation.
People Corporation is committed to training all representatives on Accessible Client Service as soon as practicable after being hired to ensure we are a welcoming environment for people with disabilities.
Training includes relevant provincial accessibility laws, including AODA and the AMA, and the aspects of the Human Rights Codes that apply to people with disabilities. We maintain records of policy acknowledgements, and the dates of training, which details how to interact, communicate with, and support our clients with disabilities.
We will also provide role-specific training for those working on digital accessibility or policy development, and train hiring managers to ensure awareness and understanding of our accessibility obligations to current, and future, employees.
Accessing our Policies
In addition to this online version, the Policy is available in other formats upon request. If you have a question about this policy, our Accessibility Officer is available to discuss it by contacting email@example.com.
People Corporation has additional policies, practices and procedures that enable our representatives to provide service to persons with disabilities. Copies of these can also be obtained by contacting our Accessibility Officer. Any policies that do not respect and promote the principles of dignity, independence, integration, and equal opportunity for people with disabilities will be modified or removed.
Communication supports will always be made available on request, in a timely manner, and at no additional charge.
Your Feedback Matters
People Corporation welcomes feedback on the accessibility of our policies and services. Clients and others affected by People Corporation’s accessibility features and practices are encouraged to provide feedback so that barriers can be identified, and concerns responded to. We strive to respond to all feedback within five business days.
Methods of providing such feedback include:
- in person, or by calling any of our offices;
- by completing a client feedback form, available in print in any of our offices, and submitting it to reception;
- by sending an email to Accessibility@peoplecorporation.com ;or
- by contacting our Accessibility Officer/Chief People and Employee Experience Officer Beth Millard-Hales at 1-866-840-3950
People Corporation Multi-Year Accessibility Plan
This 2021-2026 Multi-Year Accessibility Plan (‘Plan’) outlines the actions that People Corporation and its affiliates and subsidiaries will put in place to remove and prevent barriers to accessibility for people with disabilities, per our Accessibility Policy. This plan formalizes existing accessibility efforts and details our future strategies to improve access.
The plan will be reviewed and updated at least every two years.
People Corporation is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity, and we are committed to meeting the needs of people with disabilities in a timely manner.
We will do this by fulfilling our requirements under all provincial and territorial legislative requirements related to Accessibility, including the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Accessibility for Manitobans Act, 2013 (AMA), and the Nova Scotia Accessibility Act (2017). Although Accessibility legislation has not yet been enacted in all of the provinces we operate in, all People Corporation representatives will be expected to comply with our Accessibility policies.
Strategies and Actions
An Accessibility Committee will be struck to ensure that our Accessibility Plan, policies, and procedures continue to meet the diverse needs of people with disabilities who interact with People Corporation as clients, and as employees. This committee will meet regularly to review progress on our strategies and review proposed training and tools. Committee members will be selected from People Corporation’s workforce to ensure diversity of lived experience, education, and role within the organization.
Information and Communications
People Corporation is committed to meeting the communication needs of people with disabilities. We will continue to, upon request, provide or arrange for information in accessible formats and/or provide communication supports for persons with disabilities in a timely manner and without additional cost. We will:
- Continue to work with eSSENTIAL Accessibility to ensure all websites and web content meet WCAG 2.0 Level A and AA and provide all representatives working on websites or web content with appropriate technical training to meet these standards; and
- Create a Digital Accessibility Committee. Working in partnership with the Accessibility Committee, this committee will ensure our systems and software provide an inclusive and accessible digital experience for all.
People Corporation is committed to fair and accessible employment practices.
We will continue to review, and modify as necessary, existing recruitment, assessment and selection procedures to ensure people with disabilities have equitable access within our organization. We will:
- Publicly identify to applicants that our recruitment and selection processes provide accommodations as required;
- Notify successful candidates that documented individual accommodation plans are provided to current employees, as required;
- Develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities;
- Ensure a return-to-work process where appropriate accommodation and support is in place;
- Ensure that performance management, career development and redeployment practices take into consideration the accessibility and accommodation needs of employees with disabilities;
- Provide the option for individualized emergency response plans, as required.
- Develop and implement necessary training for hiring managers and supervisors on accommodation, return-to-work and other related policy and process changes; and
- Communicate new and revised policies and processes to all People Corporation representatives.
Design of Office Spaces
When completing major renovations of our existing offices, or selecting new office space, People Corporation will ensure that our locations with client access meet the baseline level of accessibility for public spaces per the relevant provincial legislation. In the event of service disruption we will notify the public of the disruption and how to access our services in an alternative fashion.
People Corporation is committed to training all representatives on Accessibility legislation and the Human Rights Codes as soon as practicable after being hired, in a manner that best suits the duties of the representative.
We maintain records of policy acknowledgements, and the dates of training.
As we improve our Accessibility for all persons with disabilities interacting with People Corporation, additional training materials will be developed as required, and with the approval of our Accessibility Officer and the Accessibility Committee.
As part of our due diligence with potential acquisitions, People Corporation will assess any remediation required to bring the entity’s digital communications and website to the WCAG 2.0 A and AA standard, aligned with our approach. Required remediation with any technology that does not conform to this standard will be completed in as expedited a manner as practicable.
For More Information
In addition to this online version, the Plan is available in other formats upon request. If you have a question about this policy, our Accessibility Officer is available to discuss it by contacting Accessibility@peoplecorporation.com. Communication supports will always be made available on request, in a timely manner, and at no additional charge.