As a responsible insurer, Palliser Insurance has always adopted appropriate guidelines regarding the privacy and confidentiality of information pertaining to our clients.
On January 1, 2004, the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) came into force and began to apply broadly to businesses, including Palliser. PIPEDA requires business organizations to establish rules to govern the collection, use and disclosure of personal information in a manner that recognizes the right of privacy of individuals with respect to their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances. This Policy and Palliser’s internal procedures incorporate the principles and rules set out in PIPEDA.
Purposes for Personal Information
Palliser Insurance collects, uses and discloses Personal Information for the following Identified Purposes:
- Offering customers insurance products and contracting for these products; and, maintaining communication with customers for such purposes and for the purpose of administrating insurance policies, including the determination and payment of fees and premiums;
- Verification of the accuracy of Personal Information with appropriate persons including government agencies, brokers, agents and other insurance companies;
- Analyzing, assessing and underwriting risks including verification of insurance in force with other insurers;
- Investigating and adjusting claims, conducting appraisals and obtaining reinsurance;
- Detection and prevention of improper conduct, fraud or other illegal conduct;
- Compiling statistics for the industry;
- Purposes required by law; and
- Other purposes reasonably considered by Palliser to be relevant to policies of insurance and those purposes which have been specifically consented to by customers.
Customer knowledge of the uses and disclosures intended for the Personal Information collected by Palliser, and customer consent for the identified Purposes is important to Palliser. The company will rely on various actions for the purpose of confirming customer consent to use and disclosure of Personal Information provided to Palliser or currently in the company’s possession, including:
- The provision of Personal Information to Palliser whether directly or through an insurance broker or agent, adjuster or other representative for the purposes of acquiring an insurance contract or in the course of the administration of the company’s obligations to customers under such policy.
- Customer express consent or acknowledgement in connection with a written, verbal or electronic application process.
- Customer consent given through an authorized representative including an agent or power of attorney.
Palliser is entitled to assume customer consent to the use and disclosure of Personal Information for Identified Purposes for Information in the company’s possession prior to the date of any application, including that in possession prior to January 1st, 2004, from the fact that making an application for insurance expresses a desire to conduct business with Palliser.
Palliser will limit the collection of Personal Information to that required for the Identified Purposes, or required or otherwise permitted by law. If Palliser requires Personal Information for additional purposes other than Identified Purposes or those disclosures permitted by law, notification will be provided for such purposes, and consent will be obtained prior to use or disclosure for such purposes.
Palliser will only retain Personal Information so along as it is relevant to the Identified Purposes. For clarity, Palliser reserves the right to retain Personal Information until the expiration of the customer’s right in law to enforce a right of claim under a policy or insurance with Palliser.
A customer has the right to withdraw consent at any time by informing Palliser’s Privacy Officer to such effect in such manner as may be reasonably requested. Such withdrawal of consent may result in the company’s inability to provide insurance coverage and customers will be so informed if this is the case. Additionally, in conjunction with an application for insurance it is agreed that withdrawal of consent cannot be effective with respect to Personal Information relevant to an existing policy of insurance until the expiration of the right in law to enforce a right of claim under a policy of insurance with Palliser.
Palliser does not sell data to third parties.
Palliser will protect customer Personal Information by adopting and implementing security procedures appropriate to the sensitivity of the particular Personal Information, which may include such measures as insuring the information is kept under lock and key, restricted access to those personnel who for valid business purposes require access and restricting access to electronic storage by employment of technological safeguards. Appropriate security measures will be adopted in regard to the removal or disposal of Personal Information retained by Palliser for accuracy and completeness and have it amended as appropriate.
Privacy Officer and Compliance
Palliser Insurance has designated Scott McQueen, Chief Operating Officer, as the Privacy Officer for the company. The following types of inquiry will be directed to the Privacy Officer:
- Additional information on policy, practices and procedures;
- Requests by individuals for access to their Personal Information in company possession;
- Concerns related to the accuracy or completeness of Personal Information held by Palliser and the provision of clarifications and updates;
- The filing of complaints concerning compliance by Palliser with PIPEDA, and information concerning the appropriate procedures related to such complaints;
- Procedures employed by Palliser in connection with any of the foregoing; and
In addition, the Privacy Officer is responsible for insuring compliance with this Policy and the requirements of PIPEDA, including adopting procedures designed to insure compliance, investigating and responding to a challenge that there is a perceived failure to comply with PIPEDA’s requirements. The Privacy Office reports directly to executive management.
This policy will be reviewed every two years by Palliser Insurance.