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Privacy Code - A Summary
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 Norfolk 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 Ten Privacy
Principles
The Norfolk Mutual Insurance
Company’s Code of Business Conduct & Practice is based on the following
ten principals of privacy accountability.
Principal #1: Our
Accountability for the Collection, Use or Disclosure of Personal
Information
As a policyholder or customer of Norfolk
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 assigned 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.
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. Norfolk 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 Norfolk 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.
Principle #3: Obtaining Your
Consent for the Collection, Use or Disclosure of Personal Information
Norfolk 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.
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 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 licenced
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.
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 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 right and 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 and services. This may
include an insurance broker or agent.
g)
An agent used by Norfolk 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.
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 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 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
Norfolk
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 is 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.
Principle #7: Safeguarding
Your Personal Information
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
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.
Principle #8: Openness
Concerning our Privacy Practices
Norfolk 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 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.
Principle #9: Policyholder
Access to Personal Information
Norfolk 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 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, Norfolk 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
privacy officer at the address described below.
Principle #10: Challenging
Compliance
A policyholder has the right to
challenge Norfolk Mutual Insurance Company’s compliance with the above
principles by contacting the privacy officer accountable for our compliance
with the policy.
Norfolk Mutual Insurance Company maintains
strict procedures for addressing and responding to all inquires 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 advise where appropriate before providing a final
response to individual complaints.
For Further Information
Form more information, please contact
our privacy officer directly by:
Mail: 33 Park Road, PO
Box 515, Simcoe, Ontario N3Y 4L5
Email: norins@norfolkmutualinsco.on.ca
Telephone: 519-426-1294
Fax: 519-426-7594
Copyright
2003, Canadian Association of Mutual Insurance Company (CAMIC)
Association
Canadienne des Compagnies D’Assurance Mutuelles (ACCAM)
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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