1. About Your Privacy
(1) Your privacy is, and always has been, very important to us. We are dedicated to providing you with superior service while protecting your privacy and safeguarding your personal information.
(2) “Personal Information” is defined in Canada’s Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), as information about an identifiable individual, though it does not include the name, business title, business address or telephone number of employees of organizations.
2. Our Ten Privacy Principles
(1) We are committed to maintaining the accuracy, confidentiality and security of your personal information. As part of this commitment, we have adopted the following 10 principles, based on the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and PIPEDA.
(a) Accountability: we are responsible for maintaining and protecting the personal information under its control and shall designate one or more individuals to be accountable for that company’s compliance with these principles.
(b) Identifying Purposes: The purposes for which personal information is collected shall be identified before or at the time the personal information is collected.
(c) Consent: Individual’s consent will be obtained for the collection, use or disclosure of personal information, except where the law provides an exemption.
(d) Limiting Collection: The personal information we collect shall be limited only to that which is necessary for the purposes identified.
(e) Limiting Use, Disclosure and Retention: Personal information shall only be used or disclosed for the purposes for which it was collected, unless an individual has otherwise consented or when it is required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
(f) Accuracy: We shall keep personal information as accurate, complete and up-to-date as may be necessary to fulfill the purposes for which it is to be used.
(g) Safeguards: We shall protect personal information using security safeguards that are appropriate to the sensitivity level of the personal information received.
(h) Openness: we shall provide information to individuals about our policies and procedures relating to the management of personal information that is under our control.
(i) Individual’s Access: On written request to our Privacy Officer, an individual will be informed of the existence, use and disclosure of their personal information that is under our control, and may be given access to that personal information as required and permitted by law. Individuals are entitled to challenge the accuracy and completeness of that personal information and request that it be amended, if appropriate.
(j) Handling Enquiries or Complaints: Any questions or enquiries concerning compliance with our privacy policies and procedures may be addressed to our Privacy Officer, as set out below.
3. Why We Collect and Use Personal Information
(1) Collecting personal information about you is essential to our being able to provide the products and services that best meet the needs of both yourself and/or authorized third parties (“Client”). 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, insurance brokers or agents, credit organizations, motor vehicle and driver licensing authorities, financial institutions, medical professionals etc.).
(2) Personal Information may be used by us for the following purposes:
(a) to understand your health and fitness and other related needs and objectives and to assist you in achieving them;
(b) to determine eligibility for products and services;
(c) to process applications for Clients, and provide requested information, products or services;
(d) to inform you of various matters relating to your application and about our products and services that we believe may be of interest to you;
(e) for billing and accounting services relating to our products and services;
(f) for Client communication, service and administration;
(g) for claims administration;
(h) for internal, external and regulatory audit purposes;
(i) to comply with legal and regulatory requirements; or
(j) to share or exchange reports and information with credit reporting agencies, credit bureaus, and any other person, corporation, firm or enterprise to verify the accuracy of personal information.
(3) Personal information may also be used for other purposes, subject to obtaining your prior consent for such use.
4. Consent to Use Personal Information
(1) Consent may be obtained in various ways. We may obtain your express consent or we may determine that consent has been implied by the circumstances. Express consent could be in writing (for example in a signed consent, e-mail or Web site application form), or verbally in person or over the telephone. When we receive personal information from you that enables us to provide you with a requested product or service, your consent to allow us to deal with that personal information in a reasonable manner would be implied. If you need to provide personal information about other individuals (such as employees, dependants, etc.), you must first obtain their consent for these purposes prior to your disclosure to us.
(2) Providing us with your personal information is always your choice. When you request services from us, we ask that you provide information that enables us to respond to your request. In doing so, your 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 your 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. 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.
(3) In certain circumstances, consent cannot be withdrawn, such as where personal information is required for policy issuance or renewal, insurance underwriting or claims administration of current policies. There are also legal exceptions where 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, or if we must comply with a court order.
5. Sharing Personal Information With Others
(1) We are not in the business of selling client lists or personal information to others. In providing our services, we may need to disclose the personal information we collect to affiliates, subsidiaries, successors and other such service providers or agents who perform various functions for us (such as underwriters and claims adjusters).
(2) As we continue 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.
(3) In certain circumstances, we may be required to provide personal information to third parties for legal or regulatory purposes.
(4) 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 below in the contact information section.
6. Keeping Information Accurate
(1) It is important that your personal information is accurate and complete. Having accurate information about you enables us to give you the best possible service. You have the right to access, verify and amend the information we have about you. We rely on you to keep us informed of any changes, such as change of address, telephone number or any other circumstances – simply contact your local office representative.
(2) Despite our best efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know and we will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from us.
7. How We Safeguard Personal Information
(1) We employ physical, electronic and procedural safeguards to protect our systems and all personal information under our control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected.
(2) Our service providers and agents are required to maintain Client confidentiality, and may not use the information for any unauthorized purposes.
(3) Employees are governed by strict standards and policies to ensure that personal information is secure and treated with the utmost care and respect.
8. Privacy and the Internet
(1) We may collect user information from its Web sites (for example, via cookies which are alphanumeric identifiers transmitted from a Web site to a visitor’s browser and IP address). This information is used solely for enabling us to provide you with a customized online experience and to find ways to improve our site. Although cookies are widely used, it may be possible to disable cookies via your browser settings. However, in so doing, some Web sites may not function properly or optimally.
9. Contact Information
Please contact our Privacy Officer to obtain further information about our policies and procedures or if you have any unresolved enquiries or concerns. Our Privacy Officer can be contacted as follows:
Privacy Officer, Christopher Neary