At Acera Insurance we understand that privacy is a critical issue for all our Clients. Our privacy code outlines our principles and procedures regarding the confidentiality and security of Client personal information.
This code is based on regulation for the protection of personal Information and we have tailored
our own ten privacy principles to meet the specific needs and expectations of our Clients.
This code applies to Acera Insurance. It outlines the principles and commitments we make to you, our Client, to protect the privacy of your personal information.
This code does not apply to the information collected, used or disclosed with respect to corporate or commercial entities that are Clients. However, Acera Insurance exercises the same care and diligence in protecting the confidentiality of this information.
Acera Insurance Services Ltd., a subsidiary or an affiliate. “Acera Insurance Group of Companies” means Acera Insurance Insurance Services Ltd. and all its subsidiaries or affiliates from time to time including; Acera Benefits Ltd.
The act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.
The treatment and handling of personal information by and within Acera Insurance.
Information about an identifiable individual that is recorded in any form; excluding the individual’s name, business title, business address and business phone number.
Involves voluntary agreement with what is being done orproposed. Consent may be expressed or implied. Express
consent can be given orally or in writing, it is unequivocal, and does not require any inference on the part of Acera Insurance. Implied consent exists when Acera Insurance can reasonably infer consent based upon the action or inaction of the Client.
Is any individual who uses, or applies to use, financial services with Acera Insurance.
The act of making personal information available to others outside of Acera Insurance.
An individual or organization other than Acera Insurance and the Client.
Section 1: Acera Insurance’s Accountability
1.0 Acera Insurance is accountable for the protection of Clients’ personal information. While senior management is ultimately accountable for the protection of personal information, the day-to-day monitoring for compliance may be delegated to other staff.
1.1 The overall responsibility for the protection of personal information, and compliance with this code rests with Acera Insurance’s Privacy Officer Oksana Fodor
1.2 Acera Insurance is committed to ensuring that the appropriate security measures are employed in the transfer of sensitive information. However, when using e-mail or wireless communication, Acera Insurance advises Clients that complete confidentiality and security are not assured.
1.3 Acera Insurance is not accountable for any damages suffered when a Client transmits personal information through e-mail or wireless communication or when Acera Insurance transmits information at the request of the Client.
1.4 Acera Insurance has developed policies and procedures to: protect personal information; receive and respond to complaints and inquiries; train staff regarding the policies and procedures; communicate the policies and procedures to our Clients.
Section 2: Identifying the Purposes of Personal Information
2.0 Acera Insurance will communicate the purposes for which information is being collected, either orally or in writing
2.1 Acera Insurance collects Client personal information for the following reasons only:
- To provide financial services;
- To understand the financial needs of our Clients;
- To develop and manage products and services to meet the needs of our Clients;
- To contact our Clients directly for products and services that may be of interest:
- To determine the eligibility of our Clients for different products and services;
- To ensure a high standard of service to our Clients;
- To meet regulatory requirements
- To verify a client’s identity
Personal information we may collect includes:
- Name, address, email address, telephone number, and other contact information;
- Age, birth date, social insurance number, ID numbers, gender, driver’s license number, credit card numbers or license plate numbers;
- Information about your preferences, income, assets or personal finances;
- Medical records, credit records, loan records, driving record, employment records, insurance or transaction history;
- Information about your insurance claims or claims history; and
- Such other information we may collect with your consent or as permitted or required by law.
We generally collect personal information directly from you offline and online from forms that you complete for our products and services, or when you communicate with us. We may also collect personal information about you offline and online from third party sources, such as other insurance brokers, insurance companies, consumer reporting agencies, industry associations, data banks, product suppliers, marketing agencies, government agencies, claims adjusters, employers and inspectors.
Section 3: Client Consent
3.0 Acera Insurance will obtain Client consent to collect, use or disclose any personal information except where detailed in this code. Acera Insurance will make reasonable efforts to ensure that Clients understand how their personal information will be used and disclosed.
3.1 A Client’s consent can be express, implied, or given through an authorized representative such as a lawyer, agent or broker.
A Client can withdraw consent at any time, with certain exceptions (see section 3.3).Acera Insurance, however, may collect, use or disclose personal information without the Client’s knowledge or consent in exceptional circumstances:
- When such collection, use or disclosure is permitted or
- required by law
- When use of information is for acting in an emergency that threatens an individual’s life, health, or personal security
- When certain information is publicly available
- When we require legal advice from a lawyer
- When we need to collect a debt from a Client
- When we need to deal with an anticipated breach of law
3.2 Consent may be given orally, in writing, or electronically. For example, depending on the sensitivity of the information, consent can be expressed over the telephone when information is being collected; electronically when submitting an agreement, application, or other information; in writing when signing an agreement or application form; when using a product or service; when indicating by means of a check-off box whether or not consent is granted.
3.3 Subject to contractual or legal arrangements, Clients may withdraw or refuse consent provided that Acera Insurance is given reasonable notice. Refusal or withdrawal of consent may prevent Acera Insurance from providing a product or service to the Client as in the case where a Client is applying for credit and will not provide relevant credit information. Acera Insurance will not unreasonably withhold products or services from Clients who refuse or withdraw consent, but if information is required by law or required to operate banking systems, Acera Insurance may decline to deal with a Client or person who will not consent to the use of such information.
Section 4: Limits for Collecting Personal Information
4.0 Acera Insurance will only collect personal information for the purpose identified. Acera Insurance will use methods that are lawful and will not collect information indiscriminately.
Section 5: Limits for Using, Disclosing, and Keeping Personal Information
5.0 Client information will only be used or disclosed for the purpose for which it was collected. Acera Insurance will not use personal information for any additional purpose unless Acera Insurance seeks Client consent to do so.
5.1 Acera Insurance may periodically use Client personal information to conduct Client surveys in order to enhance our provision of financial services. If an outside body is employed to conduct research on behalf of Acera Insurance, or provide other services that require access to Client information, Acera Insurance will ensure that appropriate security under-takings, such as confidentiality clauses in contractual arrangements, are employed to protect the transfer and use of personal in formation.
5.2 Subject to applicable law, each Client of the Acera Insurance Group of Companies may transfer information between each other.
5.3 Acera Insurance will retain Client personal information only as long as necessary or expected to be necessary for the identified purposes, or as required by legislation.
5.4 Acera Insurance may disclose personal information related to a financial asset of Acera Insurance along with transfer of the financial asset.
Section 6: Accuracy
6.0 Acera Insurance will make reasonable efforts to ensure that Client personal information is as accurate, complete, and current as required for the purposes for which it was collected. In some cases, Acera Insurance relies on its Clients to ensure that certain information, such as the Client’s address or telephone number, is current, complete, and accurate.
6.1 Acera Insurance will not routinely update information unless it is necessary to fulfill the purposes for which it was collected or if it is required to maintain an active account.
6.2 Clients may request amendments to the records at Acera Insurance in order to ensure the accuracy and completeness of their personal information. If the amendment request pertains to information that remains in dispute, Acera Insurance will note the Client’s opinion in the file.
Section 7: Safeguarding Personal Information
7.0 Acera Insurance is committed to the safekeeping of Client personal information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use, or modification.
7.1 Depending on the sensitivity of the information, Acera Insurance will employ appropriate security measures to protect the information. The measures may include, for example, the physical security of offices and data centers, and electronic security measures such as passwords, encryption, and personal identification numbers.
7.2 Acera Insurance will use appropriate security measures when disposing of Client personal information.
7.3 The development of Acera Insurance’s policies and procedures for the protection of personal information is an ongoing process. Changes in technology necessitate that Acera Insurance continually develops, updates, and reviews information protection guidelines and controls to ensure ongoing information security.
Section 8: Availability of Policies and Procedures
8.0 Acera Insurance is open about the policies and procedures it uses to protect Client personal information. Information about these policies and procedures will be made available to Clients either electronically or in written format in plain language. However, to ensure the integrity of our security procedures and business methods, Acera Insurance may refuse to publicly disclose certain information.
- Acera Insurance will make the following information available:
- The name, title and address of the person accountable for the policies and procedures and to whom complaints or inquiries can be forwarded;
- A description of the type of personal information held by Acera Insurance, including a general account of its use;
- A copy of any brochures or other information that explain the policies and procedures; and
- An explanation of what personal information is made available to related organizations such as affiliated companies.
Section 9: Providing Client Access to Personal Information
9.0 Clients have a right to access their personal information held by Acera Insurance. Upon request, Acera Insurance will, within a reasonable time period, tell the Client what personal information it has, what it is being used for, and to whom it has been disclosed if applicable and within the time period for which records are available. The information will be made available in an appropriate format for Clients with a sensory disability.
9.1 Clients may be asked to be specific about the information they would like to access and to submit their request in writing to their contact at any Acera Insurance branch.
9.2 Clients will be required to provide personal information to identify them to enable Acera Insurance to provide an account of the existence, use, and disclosure of personal information.
9.3 Acera Insurance will make the information available within 30 days, or provide written notice of extension where additional time is required to fulfill the request. When information is not provided within 30 days of the request, Acera Insurance will, no later than 30 days after the date of the request, send a notice of extension to the Client, advising of the new time limit, the reasons for extending the time limit and of the right of the Client to make a complaint to the Commissioner regarding the extension.
9.4 The information will be made available at a cost that will vary with the type and amount of information requested. Where a cost will be incurred by the Client, Acera Insurance will inform the Client of the cost and request further direction from the Client on whether or not Acera Insurance should proceed with the request.
9.5 When reporting to Clients to whom their information has been disclosed, Acera Insurance will not document information transfers necessary for the daily provision of products and services to Clients. For example, transfers to organizations that process debit card purchases, cheque clearing, credit card transactions, and automated banking transactions will not be documented. Upon request, Acera Insurance will provide a list of organizations where Client personal information may have been sent.
9.6 If a request is refused, Acera Insurance will notify the Client in writing, documenting the reasons for refusal and resources for redress available to the Client.
9.7 In certain situations, Acera Insurance may not be able to provide access to any or all personal information about a Client. In such cases, Acera Insurance will explain the reasons it will not provide the requested information, and identify resources for recourse available to the Client. The reasons for not providing information may include that it is unreasonably costly to provide, information that would threaten the life or security of another individual, information generated in a formal dispute resolution process, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor client or litigation privilege.
9.8 If the information is demonstrated to be inaccurate or incomplete, Acera Insurance will amend the information as required. Where appropriate, Acera Insurance will transmit the amended information to Third Parties having access to the information in question.
Section 10: Compliance and Complaints
10.0 Clients are to direct any complaints, concerns or questions regarding this privacy code in writing to the Privacy Officer. If the Privacy Officer is unable to address the Client’s concerns, the issue can be referred to the office of the CEO. At any point in this process the Client may also write to the Privacy Commissioner.
10.1 Contact Information:
Acera Insurance Services Ltd.