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Privacy Code
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, Norfolk Mutual Insurance Company has adopted a Privacy Code.
This Code sets out how and why we collect and use personal information
about our customers. 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 will then apply to insurance companies and
many other industry sectors.
This legislation establishes rules & principles for the use &
disclosure of personal information based on the 10 privacy principles
developed by the Canadian Standards Association. These principles recognize
that we live in an era when commercial information is exchanged &
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 certain circumstances we need to collect information to assist us
in adjusting or investigating a claim. This may involve the use of licensed
& regulated independent insurance adjusters or investigators. We will
always collect personal information by fair & 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.
Norfolk 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 licensed independent insurance
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 to our rights & obligations under the
Insurance Act.
e) A company or an individual employed by Norfolk 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 & services. This may
include an insurance broker or agent.
g) An agent used by Norfolk Mutual to evaluate your creditworthiness or
to collect an outstanding account. This may include credit grantors &
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 customer consents to such
disclosure or disclosure is required by law or emergency.
Norfolk Mutual Insurance Company 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 customers.
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.
Norfolk Mutual Insurance Company makes every effort to ensure that
personal information about its customers is as accurate, complete &
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 & the terms & 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 & 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/agent
directly.
Norfolk 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.
Norfolk Mutual Insurance 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.
Norfolk Mutual Insurance pursues a policy of openness about the
procedures it uses to manage personal information. We will make specific
information about our policies & practices relating to the management
of their personal information available to customers upon request.
We ensure openness by providing you with the following information:
a) the title & 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 Norfolk
Mutual Insurance Company, including a general account of its use.
Norfolk Mutual Insurance Company makes information available to help our
policyholders exercise informed choices regarding the use of their personal
information.
Norfolk Mutual Insurance Company informs its customers of the existence,
use, and disclosure of their personal information upon requests &
provides access to that information. Our customers are able to challenge or
correct the accuracy & completeness of their personal information &
have it amended when appropriate. When a request is made in writing, we
will inform you in a timely fashion, of the existence, use & disclosure
of your personal information & 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, Norfolk Mutual will provide the reasons for denying
access upon request.
Customers can obtain information or seek access to their individual
files by contacting our designated privacy officer at the address of the
company.
A customer has the right to challenge Norfolk Mutual’s compliance with
the above principles by contacting the privacy officer accountable for our
compliance with the policy.
Norfolk Mutual maintains strict procedures for addressing &
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 & 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
by calling our office at (519) 426-1294
Copyright (2003), Canadian Association of Mutual Insurance Companies
(CAMIC)
NOTE: To enable us to underwrite your insurance policy
and set a fair premium Norfolk Mutual Insurance Company will obtain
personal information from CGI, the largest Canadian independent information
technology services firm.
For further information or to obtain any CGI report containing your
personal information, which you may wish to review, please contact the Help
Desk toll free at 1-888-430-9906.
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