Privacy Policy
REV:2025

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​Data Privacy Statement for EAP Bermuda

Effective Date: April 15, 2025

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1. Introduction

At EAP Bermuda, we are committed to protecting the privacy and personal information of our clients, employees, and partners. This Privacy Policy outlines how we collect, use, store, and safeguard your personal information when you access our services, interact with our team, or use our website (www.eap.bm).

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Our commitment to privacy is rooted in our belief that trust and confidentiality are essential to providing effective support and fostering an inclusive environment. We adhere to the Bermuda Personal Information Protection Act 2016 (PIPA) to ensure your data is handled with care and integrity.

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2. Information We Collect

We collect personal and sensitive information to provide effective and personalized services.

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2.1 Personal Information
This may include, but is not limited to:

• Name, address, and contact details (email address, phone number).

• Date of birth.

• Employment details (organization name, position, and workplace concerns).

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2.2 Sensitive Personal Information
In the course of providing services, we may collect sensitive information, such as mental health or medical data. This is handled with the highest level of confidentiality, as required by PIPA Section 7.

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2.3 Non-Personal Information
Our website (www.eap.bm) may collect non-personal data, such as browsing behavior, IP address, and device information, for analytics and service improvement.

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3. Purpose of Data Collection

We collect and use your information for the following purposes:

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3.1 Counseling and Support Services

• To provide personalized counseling and support based on your needs.

• To ensure that our services are tailored to address specific challenges and goals.

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3.2 Workplace Mediation and Consultation

• To facilitate conflict resolution and mediation within organizations.

• To consult with employers and HR teams on diversity, inclusion, and employee well-being.

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3.3 Service Improvement

• To assess and improve the quality of our programs and offerings.

• To conduct research and gather data (with your consent) to enhance our services.

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3.4 Legal and Regulatory Compliance

• To comply with legal requirements, such as reporting obligations under applicable laws.

• To protect the rights and safety of our clients, employees, and partners.

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4. Consent for Data Collection and Use

By engaging with EAP Bermuda, you provide consent for the collection, use, and processing of your personal and sensitive information for the purposes listed above.

For sensitive personal information, we will obtain explicit consent, as required under PIPA Section 7(2). This ensures that your information is handled transparently and with your full understanding of its use.

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5. Data Protection and Security

EAP Bermuda employs rigorous security measures to safeguard your personal information, including:

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5.1 Administrative Measures

• Access to sensitive information is restricted to authorized personnel who have undergone confidentiality training.

• Regular internal audits to ensure compliance with data protection standards.

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5.2 Technical Measures

• Secure servers with encryption protocols for electronic data storage.

• Regular updates to security software to prevent unauthorized access.

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5.3 Physical Measures

• Secure storage of physical records in locked cabinets with controlled access.

In the unlikely event of a data breach that may cause significant harm, we will notify affected individuals and the Privacy Commissioner, in compliance with PIPA Section 14.

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6. Sharing of Information

We respect the confidentiality of your personal information and will only share it in the following circumstances:

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1. With Your Consent: When you explicitly authorize us to share information with specific individuals or organizations (e.g., healthcare providers, employers).

2. Service Providers: With third-party providers who assist in delivering our services, such as IT support or analytics platforms. These providers are bound by strict confidentiality agreements.

3. Legal Requirements: When disclosure is mandated by law, court order, or regulatory authorities (PIPA Section 6(3)(d)).

Any transfer of personal information to overseas entities will comply with PIPA Section 15, ensuring comparable levels of protection.

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7. Retention of Information

Personal information is retained only as long as necessary to:

• Fulfill the purposes for which it was collected.

• Comply with legal and regulatory requirements.

• Ensure the availability of historical data for ongoing services, as applicable.

Once the retention period expires, personal information is securely deleted or anonymized, in accordance with PIPA Section 12.

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8. Your Rights

Under PIPA, you have the following rights:

• Access: Request access to your personal information held by us.

• Correction: Request corrections to inaccurate or incomplete information.

• Erasure: Request deletion of personal information that is no longer needed for its original purpose.

• Withdrawal of Consent: Revoke consent for specific uses of your personal data.

To exercise these rights, please contact our Privacy Officer, Ms. Daniels at info@eap.bm. We will respond to your request within the timelines set by PIPA Sections 17–19.

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9. Cookies and Website Usage

Our website (www.eap.bm) uses cookies to enhance your browsing experience and analyze traffic. Cookies collect non-personal information and can be managed or disabled through your browser settings. Disabling cookies may affect website functionality.

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10. Children’s Privacy

EAP Bermuda does not knowingly collect personal information from individuals under 14 years of age without parental or guardian consent, in compliance with PIPA Section 16.

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11. Updates to This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in our operations, legal requirements, or services. Updates will be posted on our website and will indicate the effective date of the revision.

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12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal information, please contact our Privacy Officer, Ms. Daniels at info@eap.bm.