Privacy
Policy
A
Summary Of Our Personal Information
Protection Policy
Protecting the confidentiality of your personal information
has always been an important part of the way we do business.
To ensure that we protect your privacy, Colley, Borland & Vale
(“
CBV
”) has recently adopted the
Insurance Bureau of Canada Model Personal Information Code.
This Code sets out how and why we collect and use personal
information about our policyholders. It also explains limited
circumstances under which we may need or be required to
disclose it.
"Personal information" means information that
identifies you as a specific individual, including (but not
limited to):
·
age, gender,
family and marital status
·
driving record
·
previous
insurance and claims experience
·
medical and
health information
·
employment
information (including occupation and income)
·
banking
information, credit rating, payment records
·
identification
numbers (e.g. driver’s license or social insurance numbers)
·
assets and
liabilities
It does not include the sort of general information that could
be found in a business directory or a telephone book.
Effective
January 1, 2004
, the Government of Canada
will implement the last phase of the Personal Information
Protection and Electronic Documents Act (PIPEDA). This federal
statute applies not only to insurance companies but also many
other industry sectors.
This legislation establishes rules and principles for the use
and disclosure of personal information based on the ten
privacy principles developed by the Canadian Standards
Association. These principles recognize that we live in an era
when commercial information is exchanged and circulated by
electronic means. It balances the individual's right to
privacy in their personal information with the reasonable need
of organizations to collect, use or disclose
personal information.
Under the new legislation, an organization may collect, use or
disclose personal information only for limited purposes that a
reasonable person would consider to be appropriate in the
circumstances.
The Personal Information Protection and Electronic Documents
Act requires us to provide the same
safeguards for your privacy that we have always provided on a
voluntary basis. Our Personal Information Protection Policy
sets out these principles in simple terms. It explains how we
ensure that your privacy and the confidentiality of your
personal information are protected.
The
Ten Privacy Principles
Colley, Borland & Vale’s
Personal Information Protection Policy is based on the
following ten principles of privacy accountability:
Principle
#1: Our Accountability for the Collection, Use or Disclosure
of Personal Information
As a policyholder or customer of
Colley, Borland & Vale
, you have a right to expect
that your insurer is accountable for the personal information
it collects and uses. "Policyholders" and
"customers" mean our current and former insureds,
applicants for insurance and claimants under one of our
policies.
We are responsible for maintaining and protecting your
personal information while it is under our control. This
includes any personal information that may need to be
disclosed to third parties for processing or other
administrative functions.
To help ensure the confidentiality of your personal
information, we have established policies and procedures to
ensure that we comply with the Personal Information Protection
and Electronic Documents Act. We have designated a privacy
officer who is responsible for our company's compliance with
the ten privacy principles developed by the Canadian Standards
Association.
If you have any questions or inquiries about how your personal
information is stored, or when it may need to be disclosed to
others, our privacy officer is there to assist and explain our
policies to you.
Principle #2: Identifying Our Purpose for the Collection, Use
or Disclosure of Personal Information
Before or when we collect information about you, we will
explain how we intend to use it.
CBV
collects personal
information only for the following purposes:
a) to
provide ongoing communication and customer service to our
policyholder;
b) to
help us understand our customer's needs better;
c) to
develop, enhance, market or provide insurance products and
services;
d) to
enable us to underwrite your policy of insurance on a prudent
basis and set a fair premium;
e) to
provide us with the information that we need to adjust a claim
in a fair and expeditious way;
f) to
meet our legal and regulatory requirements under the Insurance
Act and other statutes.
Unless we are required by law,
Colley, Borland & Vale
will not use or disclose any
personal information that has been collected without
documenting the new purpose and obtaining your consent. If you
have any questions about these purposes, our privacy officer
will be pleased to explain them to you.
Principle
#3: Obtaining Your Consent for the Collection, Use or
Disclosure of Personal Information
CBV
will make a reasonable
effort to make sure that our policyholders understand and
consent to how their personal information will be used by
CBV
.
We will obtain your consent if we need to use your information
for any other purpose and before collecting information from
third parties such as other insurers and insurance service
companies.
In certain circumstances, however, personal information may
need to be collected, used or disclosed without the knowledge
and consent of the individual. For example, legal, medical, or
security reasons may make it impossible or impractical to seek
consent.
The Personal Information Protection and Electronic Documents
Act recognizes that when information is being collected for
the detection and prevention of fraud or for law enforcement,
seeking the consent of an individual may defeat the purpose of
collecting the information. Seeking consent may also be
impossible or inappropriate when the individual is a minor,
seriously ill, or mentally incapacitated.
In obtaining your consent, we will always use reasonable
efforts to ensure that you are advised of the identified
purposes for which any personal information collected will be
used or disclosed.
Principle
#4: Limiting Our Collection of Personal Information
We will always limit the collection of personal information to
that which is necessary for the identified purposes.
Typically, this is information that is required to enable us
to prudently underwrite your policy of insurance and charge a
fair premium. We may need to collect personal information from
other sources including credit bureaus.
Under certain circumstances we need to collect information to
assist us in adjusting or investigating a claim. This may
involve the use of licensed and regulated independent
insurance adjusters or investigators. We will always collect
personal information by fair and lawful means.
Principle
#5: Limiting the Use, Disclosure and Retention of Personal
Information
Personal information will not be used or disclosed for
purposes other than for which it was collected, except with
your consent or as permitted or required by law. Your personal
information will be retained only as long as it is necessary
to fulfill those purposes.
Colley, Borland & Vale
may disclose a customer's
personal information to the following organizations:
a) Another
insurance company for the reasonable provision of insurance
services. This may include another insurance company that is
subscribing to the risk insured under our policy;
b) Another
person or corporation as part of conducting business. This may
include a reinsurance company, subject to that corporation
agreeing to manage personal information in accordance with
these privacy principles;
c) A
person or corporation that is involved in
supplying us with claims support services. This may
include a licensed independent insurance claims adjuster or
investigator, or a fire or forensic expert or engineer;
d) A
medical or rehabilitation specialist or assessment clinic that
is providing an opinion to us pursuant to our rights and
obligations under the Insurance Act;
e) Another
company or an individual employed by Colley, Borland & Vale
to perform data processing, accounting, actuarial or
statistical functions on our behalf;
f)
A person or corporation involved in the development,
enhancement, marketing or provision of our insurance products
and services. This may include an insurance broker;
g)
An agent used by CBV
to evaluate your
creditworthiness or to collect an outstanding account. This
may include credit grantors and reporting agencies;
h)
A public authority or agent of a public authority, if
the information is required to comply with a provincial or
federal statute or regulation;
i)
A law enforcement agency, where our policyholder
consents to such disclosure or disclosure is required by law
or emergency.
CBV
does not provide or sell its
customer lists to any outside company for use in marketing or
solicitation. Only employees with a business "need to
know", or those whose duties require it, are granted
access to personal information about our policyholders.
We keep personal information only as long as it remains
necessary or relevant for the identified purposes or as
required by law. Personal information that is no longer
necessary or relevant for the identified purposes or required
to be retained by law is destroyed, erased or made anonymous.
Principle
#6: Keeping Your Personal Information Accurate
Colley, Borland & Vale
makes every effort to ensure
that personal information about its policyholders is as
accurate, complete, and up‑to‑date as is necessary
for the purposes for which it was collected.
This may require contact with you to confirm or update
personal information required for underwriting purposes. In
addition, the Insurance Act and the terms and conditions of
your policy of insurance may require you to notify us of
material changes to your personal information.
If you have any questions about the accuracy and completeness
of the personal information that we have collected or
retained, please do not hesitate to contact our privacy
officer. If you need to update some aspect of your personal
information, please contact us directly.
Principle
#7: Safeguarding Your Personal Information
Colley, Borland & Vale
takes steps to protect
personal information with security safeguards appropriate to
the sensitivity of the information.
Specifically, we have stringent security measures in place to
protect personal information against such risks as loss or
theft, computer hackers, unauthorized access, disclosure,
copying, use, modification or destruction.
We attempt to
protect your personal
information regardless of the format in which it is held. We
also protect personal information we disclose to third parties
by contractual agreements stipulating the confidentiality of
the information and the purposes for which it is to be used.
All our employees with access to personal information are
required as a condition of their employment to respect the
confidentiality of personal information.
Principle
#8: Openness Concerning our Privacy Practices
Colley, Borland & Vale
pursues a policy of openness
about the procedures it uses to manage personal information.
We will make specific information about our policies and
practices relating to the management of their personal
information available to policyholders upon request.
We ensure openness by providing you with the following
information:
a) the
title and address of the privacy officer accountable for our
compliance with the policy;
b) the
name of the individual to whom inquiries or complaints can be
forwarded;
c) the
means of gaining access to personal information held by
CBV
; and
d)
a description of the type of
personal information held by
CBV
, including a general account
of its use.
CBV
makes information available
to help our policyholders exercise informed choices regarding
the use of their personal information.
Principle
#9: Policyholder Access to Personal Information
CBV
informs its policyholders of
the existence, use, and disclosure of their personal
information upon request and provides access to that
information. Our customers are able to challenge or correct
the accuracy and completeness of their personal information
and have it amended when appropriate.
When a request is made in writing, we will inform you in a
timely fashion, of the existence, use, and disclosure of your
personal information and you will be given access to that
information. In order to safeguard your personal information,
we may require you to provide sufficient identification
information to permit us to authorize access to your file.
In certain exceptional situations, we may not be able to
provide you with access to all of the personal information we
hold. Exceptions may include information that is prohibitively
costly to provide, information that contains references to
other individuals, information that cannot be disclosed for
legal, security or commercial proprietary reasons, information
that is subject to solicitor‑client or litigation
privilege, or, in certain circumstances, information of a
medical nature. If this is the case,
Colley, Borland & Vale
will provide the reasons for
denying access upon request.
Policyholders can obtain information or seek access to their
individual files by contacting our designated privacy officer
at the address described below.
Principle
#10: Challenging Compliance
A policyholder has the right to challenge
our compliance with the above
principles by contacting the privacy officer accountable for
our compliance with the policy.
Colley, Borland & Vale
maintains strict procedures
for addressing and responding to all inquiries or complaints
from its customers about its handling of personal information.
We inform our customers about our privacy practices as well as
availability of complaint procedures, if necessary.
Our privacy officer will investigate all complaints concerning
compliance with the privacy policy. If a complaint is found to
be justified, we will take appropriate measures to resolve the
complaint including the amendment of our policies and
procedures.
In exceptional circumstances, the privacy officer accountable
for compliance with our privacy policy may seek external legal
advice where appropriate before providing a final response to
individual complaints.
For
Further Information
For more information, please refer to our Website www.colleyborlandvale.com
or by calling our office.
Our Privacy Officer is:
Mr.
Don S. Vale
Vice President and Secretary Treasurer
Colley, Borland & Vale Insurance Brokers Limited
4591
#7 Hwy East, Suite 200
Unionville,
Ontario
L3R 1M6
Email: cbvins@broker.csio.com
Telephone:
1 905 477.2720
|
