Basis of Lawful Processing
European data protection laws require us to be specific about our reasons or grounds for using your personal information. LifeWorks processes the personal information of users in the EU or UK on these grounds:
- Consent. When you have provided your consent or, in the case of sensitive personal information, when you have provided your explicit consent, to our collection of your information;
- Service performance. When we need to perform the service you are seeking or have agreed to, according to the User Terms you agree to when you create an account with LifeWorks;
- Legitimate interests. When we have a legitimate business or commercial reason for using your information, and your interests and your fundamental rights do not override those interests; and/or
- Legal obligation. When we need to comply with a legal or regulatory obligation.
Before collecting or using any special categories of data, we will only use that information:
- With your explicit consent;
- For the establishment, exercise or defence by us or third parties of legal claims; or
- If there is an exemption under local law that allows us to use it, such as in relation to the processing of special categories of data for insurance purposes, or for determining benefits under an occupational pension scheme.
LifeWorks may process your personal information on more than one ground depending on the reason or grounds for using your personal information. Please contact us if you need details about the specific grounds we are relying on to process your personal information.
Transfer of Personal Information Outside the EU or UK
LifeWorks will ensure that adequate safeguards are implemented if and when we need to transfer personal information outside of the EU or UK so that a similar degree of protection is afforded to it. Please contact us if you want more information on how we transfer and protect your personal information out of the EU or UK.
Data Subject Rights
- Right to be forgotten (Right to erasure). You may have the right to have your personal information erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data. Because LifeWorks provides you with services due to a contractual relationship we have with an organization you are associated with, there will be very few if any situations where you will be able to exercise this right.
- Right to restrict processing. You may ask us to suspend the processing of your personal information: a) if you want to establish the information’s accuracy; b) where you need us to hold the personal information, as you need it to establish, exercise or defend legal claims or assert certain rights; or c) you have objected to our use of your personal information, but we need to verify whether we have overriding legitimate grounds to use it.
If you have any questions or concerns about this policy or LifeWorks' handling of your personal information, or if you want to make a complaint, please communicate in writing with our Privacy Officer at:
By regular mail: Privacy Officer
895 Don Mills Road
Tower One, Suite 700
Toronto, ON M3C 1W3
By electronic mail: firstname.lastname@example.org
Please note that we may need to confirm your identity, request additional details and work with other LifeWorks departments to respond to you or to look into your concerns or complaint.
We may modify this notice from time to time and will post the most current version online.
Last updated: March 2020