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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,
the Grey & Bruce Mutual Insurance Company 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.
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 Act. (PIPEDA). This federal statute
applies to both the insurance companies and many other industry
sectors.
This legislation establishes rules and
principals 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 Act requires us to provide the same safeguards
for your privacy that we have always provided on a voluntary
basis. Our Privacy Code 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 Grey & Bruce Mutual Insurance
Company's Code of Business Conduct & Practice is based
on the following ten principles of privacy accountability.
As a policyholder or customer of the
Grey & Bruce Mutual Insurance Company, 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 insured's
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 Act. We have designed a privacy
officer who is responsible for our company's compliance with
the ten privacy principles 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.
Before or when we collect information
about you, we will explain how we intend to use it. The Grey
& Bruce Mutual Insurance Company collects personal information
only for the following purposes:
a) To provide ongoing 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 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, the Grey
& Bruce Mutual Insurance Company 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.
The Grey & Bruce Mutual Insurance
Company will make a reasonable effort to make sure that our
policyholders understand and consent to how their personal
information will be used by the Company.
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 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.
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 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.
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.
The Grey & Bruce Mutual Insurance
Company 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 licenced
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) A company or an individual employed by the Grey &
Bruce Mutual Insurance Company 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 or agent;
g) An agent used by the Grey & Bruce Mutual Insurance
Company 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.
The Grey & Bruce Mutual Insurance
Company does not provide or sell its customers 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.
The Grey & Bruce Mutual Insurance
Company 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 your insurance
broker 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 your insurance broker
or agent directly.
The Grey & Bruce Mutual Insurance
Company 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.
The Grey & Bruce Mutual Insurance
Company protects 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.
The Grey & Bruce Mutual Insurance
Company 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 our company; and
d) a description of the type of personal information held
by the Grey & Bruce Mutual Insurance Company, including
a general account of its use.
The Grey & Bruce Mutual Insurance
Company makes information available to help our policyholders
exercise informed choices regarding the use of their personal
information.
The Grey & Bruce Mutual Insurance
Company 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, the Grey & Bruce
Mutual Insurance Company will provide the reasons for denying
access upon request.
Policyholders can obtain information
or seek access to their individual files by contacting our
designed privacy officer at the address described below.
A policyholder has the right to challenge
the Grey & Bruce Mutual Insurance Company's compliance
with the above principles by contacting the privacy officer
accountable for our compliance with the policy.
The Grey & Bruce Mutual Insurance
Company 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 more information, please contact
our privacy officer directly through our email or by calling
the Toll-Free number or our local number.
Copyright 2003, Canadian Association
of Mutual Insurance Company (CAMIC)
Association canadienne des compagnies d'assurance mutuelles
(ACCAM)
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