PERSONAL INFORMATION PROTECTION POLICY
Principles in Summary
Red River Mutual is conscious of the importance of maintaining the privacy of the personal information of our customers. This is a responsibility that we take very seriously. The Federal Government has passed the Personal Information Protection and Electronic Documents Act (commonly referred to as PIPEDA) in order to ensure that an individual’s personal information is not misused. This legislation applies to Insurance Companies effective January 1/2004.
The following ten principles embody the intent of this legislation and have been adopted by us:
- Accountability—We are responsible for personal information under our control and have designated a Privacy Officer to ensure that our entire operation complies with the requirements of the privacy legislation.
- Identifying Purposes—We will identify the purposes for which personal information is collected at or before the time the information is collected.
- Consent—We will only collect, use or disclose your personal information with your knowledge and consent, as defined in the legislation.
- Limiting Collection—We will only collect personal information that is necessary for our defined purposes. This information will be collected by fair and lawful means.
- Limiting Use, Disclosure and Retention—Personal information will not be used or disclosed for purposes other than for which it was collected, except with your consent or as required by law. We will keep your personal information only as long as necessary for the fulfillment of those purposes.
- Accuracy—Personal information shall be as accurate, complete and up-to-date as is necessary for the purpose for which it is used.
- Safeguards—Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
- Openness—We will make specific information about our policies and practices relating to the management of personal information readily available to our customers.
- Customer Access—Upon request, a customer shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. A customer shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
- Challenging Compliance—A customer shall be able to challenge compliance with the above principles with our designated Privacy Officer.
Collecting, Using and Disclosing Information About You
We collect, use and disclose your personal information in order to provide you with the insurance protection that you have requested or in the case of a claimant to provide you with the compensation to which you are entitled. In order to do this, we use your personal information for the purposes of: establishing and maintaining communications with you; underwriting risks on a prudent basis; investigating and paying claims; detecting and preventing fraud; offering and providing products and services to meet your needs; compiling statistics and acting as required or authorized by law (the “Identified Purposes”).
We take a global view of the Identified Purposes. In other words, we are not collecting personal information just for any one of the purposes, e.g. underwriting your policy. We are collecting the personal information for all of the Identified Purposes, so in effect you can expect that although we may initially use the data for underwriting your policy, we may later use it for claims purposes, and vice versa.
We only collect personal information that we require to provide you with the insurance protection that you have requested and to administer any claims that you may have. The type of personal information that we hold depends upon the type of your dealings with us, but may include: name, address, telephone number, date of birth, family status, marital status, occupation, medical and health records, assets, liabilities, income, credit rating, whether or not credit was extended or refused, credit and payment records, an individual’s previous insurance experience including claims history, and an individual’s previous driving record. We only use such information for the Identified Purposes.
By providing your broker or us with personal information, we consider that you do so with the knowledge and understanding that it is collected, used and disclosed for the Identified Purposes.
Given the nature of the general insurance industry, consent may be implied in some circumstances. For example, we sometimes provide insurance or amendments to existing policies over the telephone, on short notice or with little written documentation. In these circumstances, it is impossible to obtain express written consent from you. Another example is that consent can also be given by you on behalf of another individual. For example, where an individual applies for auto insurance for him/herself and their family, the applicant is giving consent for the collection, use and disclosure of personal information both for him/herself and their family members even though the family members are not present during the application process. By dealing with us on insurance related matters, we infer that we have your consent for the collection, use and disclosure of personal information necessary for the Identified Purposes.
You may withdraw your consent subject to legal or contractual obligations and on reasonable notice. Withdrawal of consent may limit our ability to provide you with the requested product or service. If you want to withdraw your consent, you should contact our designated Privacy Officer first to understand the implications of such withdrawal, and then if you choose to proceed, to give the requisite notice.
Protecting Your Privacy
Your personal information is kept in strict confidence. We maintain physical, electronic and procedural safeguards to protect your information from unauthorized access. We review our policies and practices, monitor our computer networks, test the strength of our security and monitor our compliance with relevant laws in order to help us ensure the safety of your personal information. Personal information is retained only as long as it is needed or to meet any legal, regulatory or tax requirements.
There are situations specific to the general insurance industry where we will disclose personal information as dictated by prudent insurance practices. For example: As part of the underwriting handling process, we may transfer personal information to other insurance companies including reinsurance companies which share in the risk. We may disclose personal information to information services for underwriting, claims, classification and rating purposes. We may also disclose personal information to businesses that provide goods and services to insurance companies and their customers, such as claims adjusters, appraisers and repair shops. As well, we may disclose personal information to insurance intermediaries, such as your broker. Only the information necessary for these services will be provided by us to these services providers, and it is done on the basis that they will maintain the confidentiality of the information.
We do not make any personal information available to affiliated organizations, such as subsidiaries, without your consent.
Accessing Your Personal Information
You have a right to submit a written request to access your personal information that is in our possession and make corrections to it. Such a request is to be made to our designated Privacy Officer, at the address listed below. We will respond to your request within 30 days or advise you if additional time is required to respond to your request.
There may be situations in which we are legally prohibited from allowing you access to your personal information. For example, we would be so prohibited if allowing you access to your personal information would likely reveal personal information about another person or other confidential information. If this is the case, we will advise you why, subject to any legal restrictions.
We may also charge you for providing access to personal information, however we will only do so after advising you of the approximate cost.
We will amend personal information that is demonstrated to be inaccurate or incomplete.
Further Information and Contact
If you have a question or complaint regarding our privacy policies or procedures, you may contact the individual accountable for our personal information protection compliance:
Red River Mutual
245 Centre Avenue East
P.O. Box 940
Altona, Manitoba R0G 0B0
Phone: (204) 324-6434
If you make an inquiry or lodge a complaint, and are not satisfied with the outcome of that, you may challenge that outcome by writing a letter to our President, Box 940, 245 Centre Avenue East, Altona, Manitoba R0G 0B0, requesting reconsideration of your matter. Our commitment is to promptly open a dialogue with you. If your concern remains unresolved to your satisfaction, you may address your concerns to the Privacy Commissioner of Canada, 112 Kent Street, Ottawa, Ontario K1A 1H3.