Privacy

Industrial Alliance Pacific Insurance and Financial Services Inc. Privacy Policy

To serve your insurance and financial service needs, and in compliance with applicable privacy laws, we collect sensitive personal information concerning you, the people whom you choose to insure and your beneficiaries. Each of you has a right to have your personal information maintained in an accurate and strictly confidential manner, retained by us only to the extent necessary for only as long as necessary. We respect that right. This policy tells you how we do that and what you can do to help us ensure proper use of your information. We know that our company's success depends on maintaining your trust.

"Personal information" is defined by the law to mean information concerning an identifiable individual. In the insurance business, this means information such as health, lifestyle and financial information concerning group and individual policyholders, lives insured, beneficiaries, employees, brokers and agents. Personal information is contained in many forms, such as correspondence, memoranda, electronic communications, video or audio recordings, photographs or any other documentary material. Personal information does not include the name, title or business address, telephone number or e-mail address of an employee at work.

Accountability

We are legally responsible for personal information in our possession or control, including information that has been transferred by us to be processed by a third party service provider (e.g. an off-site storage supplier). We require such third party to keep your personal information under strict standards of privacy and protection.

We do not sell client lists under any circumstance.

In our commitment to you, we adhere to rules, legislated and self-imposed, to safeguard your privacy. The rules are established by this Privacy Policy, the Code of Business Conduct (applying to our directors, officers and employees), the Market Conduct Standards (applying to our agents and brokers) as well as insurance industry guidelines and applicable law. Each of our business divisions develops and maintains procedures which implement these rules.

Staff are trained and provided with information about the privacy laws which affect IAP and about our policies and procedures.

Purpose of Information

The purpose for which personal information is collected and used is identified at or before the time the information is collected. We generally do this through our application or claim forms. When you choose to place your business with us, we only ask for information necessary to provide the service or product suited to your needs. Sometimes, we ask for information required to satisfy legal requirements imposed on us (such as your social insurance number where investment income is generated by a chosen product). When we request information, we explain why we need the information where not self evident. If anything remains unclear to you, however, please ask.

 

Consent to Collection, Use and Disclosure

We seek consent at the same time (or before) we collect, use or disclose any personal information. Usually, we ask for express consent in written form (e.g. in our application or claim form). For sensitive personal information such as medical history, we always seek your written consent. Where information is less sensitive, we may seek only your verbal consent. Occasionally, we may imply consent where we can reasonably infer consent from your action or inaction. We record any decision not to grant such consent. Consent can be given by an authorized representative (such as a legal guardian or a person having power of attorney), although the authority of such a representative may be restricted by law or company policy.

Generally, you can choose at any time during our relationship to withdraw your consent, subject to reasonable notice as well as legal and contractual restrictions which may apply. We will explain to you the implications of such withdrawal, which may include termination of a policy or the inability to process a claim. For example, your right to withdraw consent is necessarily limited where we have extended a loan against the value of a policy issued by us.

If after obtaining your initial consent, we wish to change the purpose for which information is to be used, we will first obtain further consent. If you choose not to consent, we will not use the information for the new purpose and will record the decision in our files.

Most of your personal information is directly provided by you or where appropriate, by the individual to be insured. This is not always the case however. For example, sometimes we ask for consent permitting a family doctor to provide information to determine eligibility for a product.

Use and Disclosure of your Personal Information

In limited circumstances, we have the right (or obligation) to collect, use or disclose personal information without the knowledge and consent of the individual. This occurs when legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud or for law enforcement purposes, seeking consent might defeat the purpose of the information collection. Similarly, seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill or otherwise incapacitated.

Unless prohibited by law, you have a right to know on request to whom we have disclosed your information. Only in the rare instance are we prevented by law from making such disclosure. We maintain accurate records recording to whom we disclose your personal information.

Safeguards

Personal information is protected by security safeguards appropriate to the sensitivity of the information. As we deal with highly sensitive information concerning the health and finances of our clients, this is of paramount importance to us. Our safeguards protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The methods of protection include:

1. organizational measures (e.g. impressing upon each employee the position of trust that we hold, security clearances and limiting access on a "need-to-know'' basis);
2. physical measures (e.g. building access cards for employees, visitor registration and identification cards, off-site backups and archiving);
3. technological measures (e.g. the use of routinely changing passwords, firewalls and segmented operator access).

Duration of Retention of Personal Information

Generally, your personal information is retained only as long as it is needed for the purpose it was obtained. It is then destroyed in compliance with our Records Retention Policy. Note that we are required to keep the information long enough to comply with insurance law, taxation law and the statute of limitations respecting the periods within which claims can be made. We are also required to keep personal information for the duration of any investigation respecting a concern about privacy that you have expressed to us.

Your Right of Access to your Personal Information

You have a right to full access to the existence, use and disclosure by us of personal information about you contained in our records, provided there is no legal or ethical reason not to do so. We may charge a minimal or reasonable administration fee to supply the information requested by you.

Exceptions to the access right are limited and specific; unless prevented by law, reasons for denying access are given to you upon request. Exceptions can 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 has been obtained in the course of an investigation of a potential breach of contract or fraud, and information that is subject to solicitor-client or litigation privilege. Additionally, we may choose to disclose certain medical information only through the designated family doctor.

Accuracy of your Personal Information

We make best efforts to ensure that personal information about you is maintained by us in as accurate, complete and current manner as is necessary for the identified purpose for which such information is used. We do not routinely update personal information, unless such a process is necessary to fulfil the purposes for which the information was collected. Please help us in our commitment by letting us know of any changes to information provided by you and of any inadvertent errors which you may come upon. If you disagree with us about a change, we record your position in our records.

Who can Answer your Questions on Privacy

At the outset or from time to time, you may have questions or concerns relating to your personal information. Voice them as early as possible. We are committed to safeguarding your privacy and we want you to feel confident in entrusting your personal information to us.

If you have a concern or query about your privacy, the person with whom you are directly dealing may be able to satisfy such concern. Our customer representatives are also trained to assist in this regard. Such representative may refer you to the manager of the relevant department or alternatively, the company's Privacy Officer.

The Privacy Officer is the person with overall accountability for maintaining the privacy of personal information within our company. The Privacy Officer may be directly contacted by you by telephoning our toll-free customer service number in Canada (1-800-363-2166) and asking to speak to such officer.