To meet their legal obligations to their clients under the Personal Information Protection & Electronic Documents Act, macnaughton & ward insurance will follow the Broker Guide created by the Insurance Brokers Association of Canada.
Policy & Procedures regarding the Privacy Act
The following policy statements will be adhered to by every individual employed by macnaughton & ward insurance:
- Accountability – employees are to be responsible for all client information under their control. Diane Frew has been appointed the Company’s Privacy Officer and will be accountable for the organization’s compliance.
- Identifying Purposes – employees will identify to the client the purpose for which we collect personal information at or before the time the information is collected. We will identify the purpose either orally or in writing.
- Consent – employees will obtain the appropriate consent from individuals for the collection, use, or disclosure of their personal information.
- Limiting Collection – the use of personal information collected will be limited to that which is necessary for the purpose identified by the employee. (i.e. quoting insurance, cross selling)
- Limiting Use, Disclosure & Retention – personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual. Information will only be retained for as long as necessary to fulfill the purpose.
- Accuracy – the personal information collected will be as accurate and up-to-date as is necessary for the purpose for which it is to be used.
- Safeguards – employees will safeguard the security of personal information under their control in a manner that is appropriate to the sensitivity of the information. The company will provide policies and procedures for employees to follow. All personal information will be shredded when no longer required. Concerning the access and protection of information, access is restricted to employees only. Premises will be locked at end of the business day. (All employee personal information will be locked in a cabinet at all times)
- Openness – individuals will be able to inquire about our policies and procedures (all employees will be given a copy of the company policy and will be asked to sign a copy for the office file.) Privacy brochures will be made available for staff and clients.
- Individual Access – upon request, an individual (client or employee) will be informed of the existence, use, and disclosure of his or her personal information which is under our control, and may be given access to, upon completion of the “Personal Information Request” form.
- Challenging Compliance – upon request an individual who wishes to inquire or file a complaint will be informed of our applicable complaint procedures (complete a Request/Complaint Form). All complaints will be documented.
Personal Information Consent Form
The consent forms that macnaughton & ward insurance will be using are as follows:
- CSIO Applications with the appropriate Consent and Disclosure statement.
- Short Consent Form
- Oral Consent Form
(The consent forms must be placed in the client’s file)
When to use the CSIO Applications
- When writing new Home, Tenants, Condo & rental policies
- When rewriting Personal lines renewal to new Insurance Company
- Employees must read the appropriate Consent & Disclosure statement so that the client and broker understand their obligations.
When to use the Short form (Personal Lines & Commercial Lines)
- The Short Form will be used in all situations other than those where CSIO forms are applicable.
- When it is Commercial new business, “Commercial Short form” is to be completed when policy has been issued.
- When a client’s policy has been renewed and the client has never provided any form of express consent in the past.
- When sensitive information is collected, used or disclosed from a new or existing client.
- When cross-selling other brokerage business – client has provided express written consent in the past, but wishes to change the terms of consent.
When to use the Oral form
Oral form will be used only in the following circumstances:
- when Short Form cannot be obtained at the time due to time restrictions. (Short Form must be completed after binding.)
When it is not necessary to use the form?
Where we already have the client’s signed consent form on file and we are renewing the policy at his/her request, and he/she does not express a wish to change the terms of a previous consent.
- information is collected in a generic way for the purpose of giving a quote
Who should sign the form?
The agent and every individual or entity covered by the particular policy.
- if client refuses to sign the form, you should take this matter up with Management.
I have read the policy & procedure set up by macnaughton & ward insurance regarding the Privacy Act and will adhere to these guidelines.