This policy document formalises an existing Firm policy in compliance with Federal legislation Personal Information Protection and Electronic Documents Act (PIPEDA) which took effect January 1, 2004. A copy of PIPEDA is available at www.privcom.gc.ca.
While the new legislation only applies to personal information about an identifiable individual, Mills Insurance Brokers will continue to diligently safeguard all sensitive information received from our clients.
The following details 10 privacy principles that comprise the policy, augmented by comment on their application.
Mills Insurance is responsible for personal information under its control and shall designate an individual or individuals responsible for compliance.
Amy Mills| firstname.lastname@example.org
1201 Dundas St. E. Unit 204
Toronto, Ontario M4M 1S2
2. Identifying Purposes
The purposes for which personal information is collected shall be identified by Mills Insurance at or before the time the information is collected.
We will collect information for purposes that a reasonable person would consider appropriate. We may require information to:
Verify customer identity
Understand insurance needs and determine eligibility for products and services
Recommend products and services to meet those insurance needs
Provide continuing service
Establish and maintain communications
Respond to requests on an appropriate and timely basis
Enable us to acquire or renew an insurance policy
Investigate and settle claims
Protect customers and this firm from error or fraud
Comply with legal requirements
3. Obtaining Consent
Before or when we collect, use or disclose personal information about an individual we will obtain the consent of the individual for such action. The consent may be given expressly (oral or written), implicitly or through an authorised representative. Consent can be withdrawn at any time. If this should occur, we will explain any implications arising from withdrawal of consent.
For existing customers, personal information voluntarily given prior January 1, 2004 will be regarded by us as implicit consent unless a customer advises they wish to withdraw such consent.
Express Consent (oral or written) to the collection, use and disclosure of personal information will be obtained from all new customers and from existing customers acquiring a new policy or insurer.
Consent can be withdrawn with a telephone call to the office of Mills Insurance Brokers.
4. Limiting the Collection of Personal Information
We will limit the collection of personal information to serving identified purposes. Information will be collected by fair and lawful means.
Examples of types of information often required to serve customer insurance needs are:
Name, address, telephone and fax numbers, and e-mail address
Previous insurance history and claims experience
Details of property to be insured
Banking information, credit standing, payment history
5. Limiting the Use, Disclosure and Retention of Personal Information
We will use or disclose personal information only for the purpose for which the information was collected, unless an individual gives consent to use or disclosure for another purpose. We will keep personal information only as long as necessary for the identified use, or, as required by law.
We do not sell customer information to anyone. Nor do we share customer information with any third parties not directly involved in the provision of insurance products and services to you, unless you so consent.
6. Keeping Personal Information Accurate
To the best of our ability, we will keep the personal information in our possession and control complete, current and relevant relying on the owner of such information (customer) advising as to any changes. Any individual (customer) may question the accuracy and completeness of the personal information we have on file for them, at any time and may have it amended as appropriate.
7. Safeguarding Information
We will protect the storage of personal information with safeguards appropriate to the sensitivity of the information. We will protect personal information, regardless of its format, against unauthorised access, disclosure, copying, use or modification.
We will be open about the policies and procedures used to manage personal information. Such policies and procedures are readily available by contacting Mills Insurance Brokers.
9. Providing Access to Personal Information
Upon request, we will advise individuals (customers) of the existence, nature, use and disclosure of their personal information in our keeping and control. Individuals can have their information amended or corrected. We will respond to an access to personal information request within 30 days.
10. Questions and/or Complaints About Privacy
Individuals (customers) may challenge the Mills Insurance Brokers personal information handling practices and/or the firm’s compliance with privacy legislation. Complaints and inquiries should be directed to the Privacy Officer.
When an individual calls us, we may confirm their identity by asking them to confirm certain personal information of which we have knowledge. Depending on the complexity of the request, we may ask that it be submitted in writing.