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Our mission at South Easthope Mutual Insurance Company is to
provide our policyholder members insurance coverage at cost. To
do that, our policyholders provide us with certain personal information.
We have always taken seriously our responsibility to protect and
keep confidential the information you share with us.
You provide personal information to us when you purchase insurance
and sometimes at the time of a claim. By sharing this information
with us, we assume your consent for our Company to use this information
appropriately - that is, rating and issuing your policy and settling
claims in a fair and expedient manner. We do not share your information
with organizations outside of our member companies that would
use it to contact you about their own products or services.
We may also use the information as required to provide you with ongoing
service; to help us understand our policyholder members needs
better; to develop, enhance, market or provide insurance products
and services; and to meet our legal and regulatory requirements
under the Insurance Act and other statutes.
Access to your personal information is restricted to those employees
and independent representatives who need it to do their jobs.
These individuals may only use the information in the files for
work-related purposes. This expectation is clearly understood.
We've also established physical and electronic safeguards, along
with the proper processes, to protect customer information from
unauthorized access or use.
As a member of South Easthope Mutual you may access the personal
information contained in your file. You can ask that information
be corrected or amended, or that obsolete information be deleted.
For more information about our privacy policies and procedures,
please read The South
Easthope Mutual Insurance Company Privacy Code or contact
our Privacy Officer.
Email: privacy@seins.on.ca
Telephone: 1-800-263-9987
Company
Privacy Code
Introduction
Protecting the confidentiality
of personal information provided by our policyholder members,
employees and customers has always been an important part of the
way we do business. To reaffirm our commitment to protecting personal
information, South Easthope 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 may include an individual's date of birth, family status, marital
status, occupation, medical and health records, assets, liabilities,
income, credit ratings, whether or not credit was extended or
refused to the individual, credit and payment records of the individual,
an individual's previous insurance experience including claims
history, and an individual's driving record. 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 statue 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 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
South Easthope Mutual
Insurance Company's Privacy Code is based on the following ten
principles adopted by the Personal Information Protection and
Electronic Documents Act (PIPEDA).
Principle
#1: Our Accountability for the Collection, Use or Disclosure of
Personal Information
As a customer of South
Easthope Mutual Insurance Company, you have a right to expect
we are accountable for the personal information we collect and
use. "Customer" means a current policyholder member,
a former insured, an applicant for insurance, a claimant under
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 administration 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 Documents 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.
South Easthope 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, South Easthope 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
South Easthope Mutual Insurance Company will make a reasonable
effort to make sure that its customers understand and consent
to how their personal information will be used by the Company.
By providing this information to us, we assume your consent to
use this information in an appropriate manner.
We will have obtained
your consent by virtue of a signed application 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 Documents 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.
South Easthope 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 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 South Easthope 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 South Easthope 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 statue or regulation.
i) A law enforcement
agency, where our customer consents to such disclosure or disclosure
is required by law or emergency.
South Easthope 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
South Easthope 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 or agent 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
South Easthope 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.
South Easthope 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
South Easthope 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
South Easthope Mutual Insurance Company, including a general
account of its use.
South Easthope Mutual
Insurance Company makes information available to help its customers
exercise informed choices regarding the use of their personal
information.
Principle
#9: Customer Access to Personal Information
South Easthope 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 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, the South Easthope 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 South Easthope Mutual Insurance Company's compliance
with the above principles by contacting the privacy officer accountable
for our compliance with the policy.
South Easthope 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 more information,
please contact our Privacy Officer directly through our Website
or by calling the toll-free number.
Email: privacy@seins.on.ca
Telephone: 1-800-263-9987
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