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The Lanark Mutual Insurance
Privacy Code
The following information can be viewed & downloaded in Adobe Acrobat pdf
format (right-click the file and select 'Save Target As to download the file): Privacy Brochure
Introduction
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 Lanark 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
Document Act (PIPEDA). This federal statute will then apply to insurance
companies and many other industry sectors.
This legislation establishes rules and principles 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 Document 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.
Our Privacy Code
The Lanark Mutual Insurance Company’s Privacy Code is based on
the following ten principles adopted by the Personal Information Protection and
Electronic Document Act (PIPEDA).
Principle #1: Our Accountability for the Collection, Use or Disclosure of Personal Information
As a customer of the Lanark Mutual Insurance Company, you have a
right to expect that your insurer is accountable for the personal information it
collects and uses. “Customer” means a current and former insured, an
applicant for insurance, a claimant under one of our policies as well as an
individual insured as part of a group or corporate policy.
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 Document Act. We have designated
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. The Lanark Mutual Insurance Company collects personal
information only for the following purposes:
a) to provide ongoing service to our customer;
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 Lanark 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
The Lanark Mutual Insurance Company will make a reasonable
effort to make sure that our customers 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 Document 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 licensed 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.
The Lanark 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
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 Lanark 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 Lanark 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 customer consents to such
disclosure or disclosure is required by law or emergency.
The Lanark 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.
Principle #6: Keeping Your Personal Information Accurate
The Lanark Mutual Insurance Company makes every effort to ensure
that personal information about its customers 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.
Principle #7: Safeguarding Your Personal Information
The Lanark 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 Lanark 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
The Lanark 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 customers 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
Lanark Mutual Insurance Company, including a general account of its use.
The Lanark Mutual Insurance Company makes information available
to help our policyholders exercise informed choices regarding the use of their
personal information.
Principle #9: Customer Access to personal Information
The Lanark Mutual Insurance Company informs its customers 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 exeptional 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 Lanark
Mutual Insurance Company 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
described below.
Principle #10: Challenging Compliance
A customer has the right to challenge the Lanark Mutual
Insurance Company’s compliance with the above principles by contacting the
privacy officer accountable for our compliance with the policy.
The Lanark 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 Further Information
For more information, please contact our privacy officer
directly through our Website at www.LanarkMutual.com
or by calling the Toll-free number.
Lanark Mutual Insurance Company
16 Gore St., W., Perth, Ontario
K7H 2L6
Email: privacy@lanarkmutual.com
Telephone: 1-800-267-7908 / (613) 267-5554
Fax: (613) 267-6793
Copyright 2004, Canadian Association of Mutual Insurance
Companies (CAMIC)
Association Canadienne des Compagnies d’Assurance Mutuelles (ACCAM)
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