At Certas Direct Insurance Company (Certas Direct), an important part of our Company’s commitment to provide our customers with service excellence is our respect for their right to privacy. Keeping our customers’ personal information in strict confidence is a cornerstone of Certas Direct’s business. Accordingly, Certas Direct has adopted this Privacy Code which details the privacy principles that are to be followed.
Some definitions of terms used in this Privacy Code:
- “Personal Information” means any factual or subjective information in any form about an identifiable individual but does not include the name, title or business address or telephone number of an employee.
- “Third Party” means an individual or corporate entities outside of and not affiliated with Certas Direct.
- “We” means Certas Direct and its affiliated general insurance companies.
- “You” means individuals about whom We collect Personal Information in order to carry out the business of property and casualty insurance. It includes our insureds, former insureds, applicants, claimants and individuals involved in a claim. It does not include commercial and corporate entities, or individuals carrying on business in sole proprietorships, in partnerships or in other associations.
We are responsible for all Personal Information under our control and We have designated a Privacy Officer who is accountable for our compliance with this Privacy Code.
Our Privacy Officer will be assisted in this role by other individuals within our company who have responsibility for the day-to-day collection and processing of Personal Information.
If We are required to send Personal Information to a Third Party, We will use contractual or other means to provide a comparable level of protection by the Third Party.
We have established and implemented policies and procedures to give effect to this Privacy Code in order to protect your Personal Information and to receive and respond to customer complaints and inquiries.
We collect, use and disclose a customer’s Personal Information for the Purposes of providing general insurance products and services. More specifically, We collect, use and disclose necessary Personal Information for communicating with You, and Third Parties in order to: assess your application for insurance; underwrite and service your insurance policies; process claims involving You; analyze business results; and act as required or authorized by law.
We will state the Purposes, orally or in writing, to You either at or before the time We collect your Personal Information or as soon thereafter as is reasonably possible.
If We intend to use or disclose your Personal Information for a different purpose, We will obtain your consent first, unless the new purpose is required by law.
Under no circumstances will your Personal Information be sold or inappropriately disclosed to Third Parties.
Your consent is required for the collection, use or disclosure of your Personal Information by us.
When You voluntarily provide certain Personal Information to us, You are also giving your implied consent (if express verbal or written consent has not otherwise been requested) for us to collect, use and disclose that Personal Information to fulfill the identified Purposes.
Rarely, and in very specific circumstances as allowed under the law, We may collect, use or disclose Personal Information without your consent.
You may withdraw your consent at any time, with reasonable notice, subject to legal or contractual obligations which must be fulfilled by us. Withdrawal of consent may prevent us from providing You with the requested insurance products or services including processing an application for insurance and processing a claim.
The amount and the type of information We collect shall be limited to that which is necessary to fulfill the identified Purposes. We will obtain Personal Information primarily from our customers. We may also collect Personal Information from other external sources including other property and casualty insurers, public and private sector underwriting or claims information databases, and credit reporting agencies.
Limiting Use, Disclosure and Retention
We will not use or disclose your Personal Information for purposes other than those for which it was collected, except with your consent or as may be required or permitted by law.
We may be required to disclose Personal Information to external sources in accordance with legal and insurance regulatory reporting requirements or standard accepted insurance practices.
Personal Information that We have about You will be retained only as long as it is required to fulfill the identified Purposes. Where Personal Information is no longer required to fulfil the identified Purposes, or for any other legal requirements under the law or otherwise, it will be destroyed, erased or made anonymous.
We will use our best efforts to keep your Personal Information as accurate, complete and up-to-date as is necessary for the identified Purposes for which it is to be used.
We will generally rely on You to provide updated information, such as changes to your address and other contact information.
If You successfully demonstrate to us that Personal Information on file is inaccurate, We will revise or correct the Personal Information on file. Personal Information which includes a matter of opinion will not be considered inaccurate information and will not be subject to correction or amendment.
We will protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, with appropriate safeguards.
You have a right to access and correct the Personal Information We have on file about You. To get access to your Personal Information on file with us contact Customer Relationship Services in writing at the address listed below. Upon receipt of your written request, We will respond to you within (30) days or such later date as may be permitted or required under the law.
Your access to Personal Information may be limited or denied, but only under those circumstances permitted or where We are required under the law.
If you have any inquiries about this Privacy Code, contact Customer Relationship Services:
Customer Relationship Services
Certas Direct Insurance Company
P.O. Box 7065
Mississauga, ON, L5A 4K7
By phone: 1-888-696-8947
By fax: 1-877-818-8863
If You believe that We are not complying with this Privacy Code, please contact Customer Relationship Services. We will investigate all complaints, and if a complaint is found to be justified, We will take appropriate measures to correct the situation.
If your complaint cannot be resolved through our internal complaint review process, You have the right to file a complaint through the Office of the Privacy Commissioner of Canada Web site.