Dear Valued Customer,
Due to the nature of our
business, it is often
necessary for our clients to
supply us with information
that he or she would discuss
with few other people.
In most instances, it is
necessary information
requested by the Insurance
Company that we represent to
enable them to properly
assess a risk. Consequently
we will always respect the
confidentiality of the
information. What takes
place in our offices during
the course of operating our
businesses will always
remain there. In our
position of professional
trust we will always have
the utmost regard for this
confidentiality.
Crain & Schooley Insurance
Brokers Ltd. and Crain &
Schooley Financial
Corporation have made a
commitment to respect the
privacy rights of our
customers by insuring that
their personal information
is collected, used, and
disclosed in such a manner
that a reasonable person
would consider appropriate
in the circumstances.
The federal Personal
Information Protection and
Electronic Documents Act (PIPEDA)
came into force on January
1, 2001 and began to apply
to certain business and
activities on that date. On
January 1, 2004, this Act
will apply to all insurance
brokerages not otherwise
subject to another
“substantially similar”
piece of provincial
legislation. This overview
is based on the principles
and rules set out in that
Act.
I hope you find it useful.
Yours truly,
Richard Schooley, CRM, FCIP
President,
Crain & Schooley Insurance
Brokers Ltd.
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Crain & Schooley
Commitment to Your Privacy
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Accountability
Crain & Schooley takes
your privacy very seriously.
With this in mind, we have
appointed a Privacy Officer
within our organization to
ensure our accountability
and compliance with this
Privacy Policy. You may
reach our Privacy Office via
our Perth office at (613)
267-1194 or through
inquiry@crainschooley.on.ca
Our Commitment To You
1. Crain & Schooley makes
this privacy commitment to
its customers:
-
We will protect your
personal information;
-
We will allow our
customers to request
information, seek amendments
to their personal
information; and file
complaints against the
Broker with our Privacy
Officer;
-
We will train and educate
staff about the importance
of your privacy
-
We will provide
information which explains
our privacy procedures to
our customers at their
request
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2. We will use all
reasonable means to ensure
that client personal
information is given a
comparable level of
protection while being
processed by a third party.
If it is not practical to
obtain written assurances,
we may choose to make a
written notation in our own
file(s).
3. We will identify the
purposes for which we
collect personal information
at or before the time the
information is collected.
Why We Collect Your
Information
In order to provide
excellent service to our
clients, we often need to
collect personal
information. We do this in
order to:
-
enable us to
acquire or renew
an insurance
policy;
-
assist you in assessing
his/her ongoing needs for
insurance;
-
assess your need for other
products, such as financial
products;
-
protect
Crain & Schooley
and / or insurer against
inaccuracy.
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We may choose to orally
explain to our clients the
purposes for which personal
information is being
collected and then simply
place a note in the client’s
file indicating that this
has been done.
Alternatively, we may ask
you to fill in an
application form.
Changes In Purpose
We will identify any new
purposes that arise during
the course of dealing with
personal information, and
obtain prior consent for
this new use, even if we
have already identified
certain initial purposes.
However, we will only do
this when the intended new
purpose truly constitutes a
“new” use, i.e., when the
purpose now being proposed
is sufficiently different
from the purpose initially
identified.
Your Consent
We will obtain the
appropriate consent from our
customers for the
collection, use, or
disclosure of their personal
information, except where
the law provides an
exemption.
Limiting Collection of
Information
The personal information we
collect will be limited to
that which is necessary for
the purposes we have
identified.
Our policies and procedures
relating to the limitations
on collection of personal
information will be
regularly communicated to
our staff members who deal
with personal information.
Personal information will
not be used or disclosed for
purposes other than those
for which it was collected,
except with the consent of
the individual or as
required by law. We will
only retain personal
information as long as
necessary for the
fulfillment of those
purposes.
We will retain personal
information only as long as
necessary for the
fulfillment of the purposes
for which it was collected.
We will abide by industry
standards applicable in the
province(s) in which we are
located, regarding minimum
and maximum retention
periods.
Personal information that
has been used to make a
decision about an individual
will only be retained long
enough to allow the
individual access to the
information after the
decision has been made. This
period will not exceed
applicable industry
standards.
Personal information that is
no longer required to
fulfill identified purposes
will be destroyed, erased,
or made anonymous.
Accuracy
The personal information we
collect will be as accurate,
complete and up-to-date as
is necessary for the
purposes for which it is to
used.
We consider a regular
updating of client personal
information to be necessary
to ensure the accuracy of
client files and to provide
appropriate insurance
coverage for clients.
Our goal is to minimize the
possibility that
inappropriate information
may be used to make a
decision about any
individual whose personal
information we process.
The process for ensuring
accuracy and completeness
will involve:
-
asking our
clients to
verify accuracy
and
completeness;
-
Regular reviews; and
-
Verifying accuracy by
contacting third parties
(e.g., motor vehicle and
driver licensing
authorities, etc.)
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Safeguards
We will safeguard the
security of personal
information under our
control in a manner that is
appropriate to the
sensitivity of the
information.
We will protect the security
of personal information,
regardless of the format in
which it is held, against
loss or theft, and against
unauthorized access,
disclosure, copying, use, or
modification.
More sensitive information
will be safeguarded by a
higher level of protection.
However, we will generally
seek to achieve the highest
level of security.
In determining what
safeguards are appropriate,
we will consider the
following factors:
-
The
sensitivity of
the information;
-
The amount of information
held;
-
The parties to whom
information will be
disclosed;
-
The format in which the
information is held; and
-
The way in which the
information is physically stored, asking
our clients to
verify accuracy
and
completeness;
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When transferring client
information to a third
party, we will remove or
mask any information that is
not strictly needed by the
third party.
Our methods of protection
include:
-
Physical measures, such as
locked filing cabinets and
restricted access;
-
Organizational measures,
such as security clearances
and limiting access on a “
need-to-know” basis; and
-
Technological measures,
such as the use of passwords
and encryption.
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We will ensure that our
policies and procedures on
safeguarding personal
information are clearly
communicated and accessible
to our employees by:
We will take precautions in
the disposal or destruction
of personal information to
prevent unauthorized parties
from gaining access to the
information. These measures
include:
-
Ensuring that no
one may retrieve
personal
information
after it has
been disposed
of;
-
Shredding documents before
recycling them; and
-
Deleting electronically
stored information.
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Openness
We will make readily
available to individuals
specific information about
our policies and procedures
relating to the management
of personal information,
which is under our control.
The manner in which access
will be given may vary,
depending on the format in
which the information is
held (i.e., hard copy or
electronic), the amount of
information held and other
factors. For example, if
there is a large volume of
information, instead of
providing a copy of the
entire file, we may simply
provide a summary of the
information.
Upon written request, we
will provide a list of third
parties to whom we may have
disclosed an individual’s
personal information. If we
are unsure exactly which
third parties may have
received the information, we
will provide a list of third
parties likely to have
received the information.
Individuals will be required
to provide sufficient
information to us to permit
us to provide an account of
the existence, use and
disclosure of personal
information.
The procedure for making a
request is as follows:
-
All requests must be made
in writing using a form such
as the Request/ Complaint
Form.
-
We will respond to a
request within 30 days after
receipt of the request,
unless we first advise you
that we need a longer period
to respond.
-
Reasons – If we refuse a
request, we will inform the
individual in writing of the
refusal, explaining the
reasons and any request, we
will inform the individual
in writing of the refusal,
explaining the reasons and
any recourse the individual
may have, including the
possibility that they may
file a complaint with the
Privacy Commissioner of
Canada.
-
Deemed refusal –
Notwithstanding
sub-paragraphs (2) and (3),
if we do not respond within
the above time limit, we
will be deemed to have
refused the request.
-
Costs for responding – The
Broker may require payment
of a modest fee to cover our
administrative costs
associated with preparing a
response.
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There are also exceptions
which will prevent us from
providing access, including
where:
-
Personal information about
another person might be
revealed;
-
Commercially confidential
information might be
revealed;
-
Someone’s life or security
might be threatened;
-
The information was
collected without consent
for the purposes related to
an investigation of a breach
of an agreement or
contravention of the law; or
-
The information was
generated during the course
of a formal dispute
resolution process.
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Challenging Compliance
An individual may address a
challenge concerning
compliance with the above
policies and procedures to
our Privacy Officer.
To file a complaint, an
individual must fill out a
Request / Complaint Form,
which requires basic
information and a
description of the nature of
the compliant.
The procedure for filing a
complaint about our
organization is as follows:
-
A
Request/ Complaint Form
must be filed with our
Privacy Officer;
-
We will acknowledge the
complaint right away;
-
We will assign someone to
investigate;
-
We will give the
investigator unfettered
access to files and
personnel, etc.;
-
We will clarify facts
directly with the
complainant, where
appropriate;
-
We will advise the
complainant in writing of
the outcome of our
investigation, including any
steps taken to rectify the
problem, if applicable.
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We will document all
complaints made by clients,
as well as our actions in
response to complaints, by
noting these details in the
individual’s file and also
in a master privacy file.
For More Information
Please contact our Perth
office, and ask to speak to
our Privacy Officer.
Crain & Schooley Insurance
Brokers Ltd.
81 Gore St. E.
Perth, ON
K7H 1J1
(613) 267-1194
fax (613) 267-2683
inquiry@crainschooley.on.ca
