| Privacy
 |
Industrial-Alliance Pacific Life Insurance
Company ("IAP")
Privacy Policy |
To serve your insurance and financial service needs, 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.
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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.
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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.
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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.
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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.
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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).
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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.
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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.
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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.
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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. |
