Personal information means information about an identifiable individual. The personal information we collect depends on the services you obtain from us, but may include information such as your age, sex, personal contact information, credit card and banking information, employment information and history, licensing information, professional disciplinary information, information about your assets, and information about your insurance claims and claims history. We may also collect other personal information with your consent or as permitted or required by law.
Purposes for Collecting Personal Information
We collect, use and disclose personal information for insurance purposes, including arranging for insurance products and related services. Those purposes include:
- acting as your insurance broker;
- understanding your needs;
- communicating with you;
- determining if our products and services, or those of our partners, including insurance and claims processing and administration services, meet your needs, and recommending, offering and providing those products and services to you;
- verifying information and detecting and preventing fraud;
- collecting monies owing to us or permitting us to pursue available remedies or limit any damages we may sustain; and
- complying with all applicable laws.
We explain the purposes for which we intend to use personal information that we collect either before or at the time the information is collected. Our collection of personal information is limited to that which is necessary for those purposes, or for other purposes that are disclosed to you before or at the time the personal information is collected. Unless required by law, we will obtain your consent before using or disclosing your personal information for a purpose not previously identified.
We primarily collect personal information about you from you directly, but we may collect personal information about you from third parties. We only collect personal information by fair and lawful means and we do not collect information about you without your knowledge.
We will obtain your consent for the collection, use and/or disclosure of your personal information. Your consent may be express or implied. Express consent can be verbal or written. Implied consent arises when we can reasonably conclude that you have given consent by your action or inaction. Before deciding what form of consent is appropriate, we will consider the type of personal information we need and the reason for its use or disclosure.
You can withdraw your consent at any time after you have given it to us. If you do not consent to a certain use or disclosure of your personal information, or if you withdraw your consent, we may not be able to provide you with a particular product or service. If so, we will explain to you the consequences of refusing or withdrawing consent, and your options.
Use, Disclosure and Retention of Personal Information
We use and disclose various types of personal information as necessary and appropriate for the purposes outlined above. This includes, without limitation, disclosure:
- to insurers to arrange for insurance for you or your company;
- to mortgage providers and leasing and financing companies which have requested that we verify your insurance coverage;
- to third parties including insurers, lawyers, adjusters, experts, mediators and adjudicators involved in claims you have reported;
- to government agencies or regulatory bodies having jurisdiction over us to the extent we are legally required to provide such information;
- to other persons authorized or required by law;
- in emergency situations in which the life, health or security of you or someone else is in danger;
- to credit grantors and reporting agencies; and
- to other persons, where you authorize or consent to such disclosure.
We do not disclose your personal information to our affiliates, including The Financial Advisors Association of Canada (Advocis), without your express consent. However, we may aggregate and anonymize personal information such that it cannot be traced back to an individual person for statistical analysis and identification of trends and share that information with Advocis.
We will only retain your personal information for as long as necessary to fulfill the identified purposes. When personal information is no longer necessary, we destroy or anonymize such information. Given the ongoing possibility of claims, some personal information may be kept indefinitely.
Accessing your personal information
You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. We will need to verify your identity before providing you with access to your personal information.
We may not be able to provide access to personal information if the information cannot be separated from the records of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide access to personal information, we will advise of the reasons access is being denied, unless prohibited by law from doing so.
Where you demonstrate that personal information in our possession is inaccurate, we will update our records accordingly, and we will note any unresolved differences as to accuracy in your file. Where appropriate, we will send any amended personal information or the existence of any unresolved differences to third parties having access to the personal Information in question.