The following is the Privacy Policy of James Insurance Broker Limited and Hamiltons insurance o/b James Insurance. This policy was last amended on December 30, 2013 and is reviewed on a continuing basis to ensure it adheres to internal, industry, and regulatory guidelines.

Introduction

During the course of our job as insurance brokers we are often presented with personal information of our clients. We strongly believe that our clients deserve the right to privacy when it comes to the voluntary disclosure of these personal details. It is important that this information is only obtained and shared with the consent of our clients and only with the insurance carriers and intermediaries that quote and issue insurance policies. Ultimately, this information should only be used for the original purposes for which it was collected.

We ensure that we only collect these personal details in accordance with the privacy responsibilities and guidelines outlined within the Personal Information Protection and Electronic Documents Act [1] (PIPEDA) and in accordance with all of our regulatory bodies. As insurance is an ever changing industry we must continuously review and update our procedures to ensure the security and proper usage of the personal information collected from our clients.

Often times we are presented with questions by our customers as to how their private information is handled when issuing an insurance policy. We have done our best to detail the most commonly asked questions and list the answers below to gain a better perspective of the steps My Insurance Broker has taken to protect your personal information. The security of this information, reasons for collecting, and methods for deleting data are all explained in further detail below.

Who is Our Privacy Officer?

We provide an avenue for an individual with a concern or complaint to contact our Privacy Officer should they be unhappy with our service provided. If you have any concerns please contact: 

Eleanor Damant, President,

26 King St. E. Bowmanville, Ontario  L1C 2H9

905-623-4406   

 

What information do we collect?

We only collect details that are both required and relevant to our insurance applications, endorsements, and questionnaires to issue, modify, and maintain insurance for our clients. One of our guiding principles is that of protecting our clients’ personal data. We promise to never share this information with any third parties unrelated to the process of issuing an insurance policy.

 

Why is it collected?

In order for the insurers we represent to calculate premium they often require personal details about your insurance history. What makes these details relevant to an insurance company are factors filed and approved by the Financial Services Commission of Ontario (FSCO). We collect this data on behalf of the insurer under a unique contract of utmost good faith. This simply means that we operate on the highest levels of honesty and integrity as an agent for both you and the insurance companies we represent. After collecting this information it is used to determine a rate. We collect information relevant to your policy [2], these include details like the vehicle you drive, your driving record, and where you live. This process is wholly regulated by the Financial Services Commission of Ontario.

 

How is it collected?

Like most businesses we collect data through phone, fax, e-mail, or Web Site requests. Other information may be gathered from insurance reporting systems common to all brokers. As an example, these reporting systems would include access with the Ontario Ministry of Transportation that may verify the accuracy of a driving record. We only collect this data with your consent and only if necessary to confirm application details or gather additional information.

 

Why is it kept?

Information is stored on encrypted terminal servers. After collection, some of this data is purged from our system after set periods of time when it is determined it is no longer relevant. Information is collected solely to assess risk and maintain contact with our clients.

At James Insurance we do not disclose your information to third parties for marketing purposes.

 

Who has access to this information?

Information gathered by brokers is to be held in the strictest confidence and is only ever referred to insurers or staff underwriters on the basis of determining a rate, coverage, or making a change to an existing policy. Only the broker who issues a quote and our staff has access to your private information. Should you wish to proceed with an insurance policy then your personal information is referred through the underwriting channel to do so.

 

To whom is it disclosed?

The information gathered by our brokers and underwriters is only shared with our insurance carriers. This form was drafted in accordance with our regulatory body, the Registered Insurance Brokers of Ontario (RIBO). This Client Consent Form was written to specifically meet the unique needs of consent requirements outlined in PIPEDA. It asks for our client’s permission to collect, use, and disclose personal information.

 

When is it disposed?

Private data is held only as long as it reasonably should. As an example, credit card data collected to pay for a policy is only to be kept for a very short period of time after which it is to be purged from our system.

As an example, where coverage is concerned, we may keep some policy coverage forms for up to ten years to ensure we have documented coverage should a claim arise in the future. This way we can reference a policy wording to show coverage if the need were to arise. Ultimately, our trusted staff understands that the collection of our client’s personal information should be disposed of regularly where it becomes no longer relevant to assess their insurance policy.

 

Our Commitment to Privacy

We are committed to protecting your privacy. In doing so we have taken certain measures to protect your personal information.

1. Accountability

As brokers we have access to much of our clients personal data in order to issue a policy. We must remain accountable for protecting the privacy of this sensitive data by having all staff and producers periodically sign off on privacy commitment in our internal policies and procedures and also through confidentiality and non-disclosure agreements. Our Privacy Officer will continually review our Privacy Policy on an ongoing basis to ensure as our business processes change our commitment to privacy does not.

2. Identifying purposes

We must explain the purposes for which we are collecting data (e.g. to complete an assessment of risk, issue a policy, process a claim, complete a quote) and we will be upfront when dealing with you.

3. Consent

We believe in informed consent. You must be informed that personal information will be used to determine a quote or issue a policy. We ask out clients for their consent to collect, use, and disclose personal information for these reasons before issuing a policy. Customers must be informed in a meaningful way of the purposes for the collection, use and disclosure of their personal information. We must then document their consent with their signature on a Client Consent Form, meeting guidelines outset by PIPEDA and our regulatory bodies.

4. Limiting collection

The collection of information should be limited to that which is only necessary in order to process an insurance application or endorsement. It should not be used outside of the intent for which is was originally disclosed. Information gathered can only be used for the disclosed purposes for which it was collected (generally only for insurance quotes, we must maintain the clients information strictly confidential and their personal details cannot be referred to third party businesses unless with their explicit written consent as per regulatory guidelines).

5. Limiting use, disclosure, and retention

We limit the use of your personal information to what is only necessary. It is retained for necessary periods of time and if not necessary it is purged from our systems (e.g. if collecting a credit card number to process policy payment, it should be disposed of after processing payment for the policy). We destroy, erase, or render anonymous information that is no longer required for an identified purpose or a legal requirement. We keep personal information used to make a decision about a person for a reasonable period of time. (e.g. when a client meets an underwriting declination rule this should be outlined in our agency manager notes and documented should the person request to obtain the information after a decision).

6. Accuracy

We are precise when collecting information, as a description of what personal information is made available to other organizations (including third parties and subsidiaries) and why it is disclosed. We allow access for our customers to update their personal records should they request them. Please contact our Privacy Officer for your personal records by referencing the contact information on the second page of this document.. We conduct a review of security procedures periodically to ensure updates are completed as our business changes.

7. Safeguards

We protect your information in encrypted servers that require password access. Our servers are located terminally away from our local desktops and laptops. We dispose of information that does not have a specific purpose or that no longer fulfils its intended purpose. All offices use paper shredders to destroy information that is no longer required that would be considered sensitive personal data. We protect personal information against loss or theft, the more data you collect the more secure the data should be kept (a reasonable amount of protection should be used to encrypt or securely connect computers sharing the sensitive data)

8. Openness and Honesty

We have organizational controls in place on a ‘need-to-know’ basis. Selected staff and brokers only have access to information that is pertinent to their jobs. We have a duty to inform our customers, clients, and employees of why we have our information collection practices in place. We operate on a contract of utmost good faith.

9. Individual access

Appropriate measures to correct all information handling practices will be handled immediately and policies should be updated based corrective actions dealt with in each formal complaint. Passwords to terminal servers are updated periodically.

10. Challenging compliance

When a customer has an issue with the security of their private data we handle all complaints seriously. It should also be noted that all complaints must be handled, regardless of their merit. Our goal is to make the process for challenging compliance simple and easy.

 

Our Complaint Process

We promise to acknowledge the complaint promptly and detail the time and date in a report. We will give the customer a timeframe for which they will get an official response from our company. We will contact the individual for clarification of the complaint if necessary.

We will assign the matter to a person with the skills necessary to review it fairly, impartially and provide that individual with full access to all records pertaining to the file.

If a customer has to make a complaint against James Insurance Broker please do so by contacting us directly. If you are unsatisfied with an initial decision from the brokerage:

• Escalate your complaint to a Manager or Underwriting Manager for review. This Manager will carefully

• review your concern and will do their best to resolve your complaint in a fair and professional manner.

• If you are dissatisfied with the decision of this Manager we will escalate your complaint to the Privacy Officer and President of the brokerage.

 

We have a process to record all complaints, the type of complaint, the date received, and when the complaint was resolved. We track these processes carefully to ensure that we can prevent future complaints from occurring.