Last updated January 2018
Privacy of personal information is an important principle to Asselin Insurance Brokers Limited and asselininsurance.com. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, and health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
WHO WE ARE
Our organization, Asselin Insurance Brokers Limited, includes at the time of writing 10 employees. We use a number of licensed insurance companies that may, in the course of their duties, have access to personal information we hold. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
We will obtain the appropriate consent form individuals for the collection, use, or disclosure of their personal information, except where the law provides an exemption.
WE COLLECT PERSONAL INFORMATION:
From our Clients
Like all Registered Insurance Brokers, we collect, use and disclose personal information in order to serve our clients. Our primary purpose for collecting personal information is to provide Property & Casualty Insurance to our clients. For example, we collect information about a client’s address, age, driving record, and claims history in order to help us assess what our client’s insurance needs are, to advise them of their coverage options and then to provide them with insurance coverage they choose to have. Other purposes include enabling the Broker to renew an insurance policy, assisting the client and assessing his/her ongoing needs for insurance, assessing the Client’s need for other products, such as financial products, ensuring that Client information is accurate and up-to-date, and protecting the Broker and / or insure against inaccuracy.
From our Contract Staff, Volunteers or Students
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paychecks, yearend tax receipts, etc.). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in our office). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.
WE COLLECT PERSONAL INFORMATION:
Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
To invoice clients for goods or services not paid for at the time, to process credit card payments or to collect unpaid accounts.
To advise clients and others of special events or opportunities (e.g., a seminar, development of a new products, arrival of a new product line, etc.) that we have available.
Our office reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, insurance companies, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our office, including reviewing client files and interviewing our staff.
Registered Insurance Brokers are regulated by the Registered Insurance Brokers of Ontario (RIBO) who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other Brokers, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behavior to the authorities. External regulators have their own strict privacy obligations.
Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
Clients or other individuals we deal with may have questions about our goods or services after they have been received. We also provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful. We retain our client information for a minimum of seven to ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our client records).
If Asselin Insurance Brokers Limited or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the offices records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.
You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities, by paying for your services in advance, etc.). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information is either under supervision or secured in a locked or restricted area.
- Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted either through a direct line or is anonymized or encrypted.
- External consultants and agencies with access to personal information must enter into privacy agreements with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
We keep our client files for about seven to ten years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence (i.e., with people who are not clients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire client file to our client.
YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., policy forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
- If there is a problem we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
- If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
ONLINE QUOTE REQUESTS –
Consumers wishing to request a quote online through www.asselininsurance.com will be required to complete a contact us or a fillable quote request form. Information collected is required to estimate the insurance premium, with reasonable accuracy, for insurance products that cover your specific insurance needs. If you send us a quote request generated through asselininsurance.com, we collect and use this information for the sole purpose of providing an insurance quote.
Like other website owners, Asselin Insurance Brokers Limited uses Google Analytics to track website activity on our website (www.asselininsurance.com). Google Analytics collects information on the visitors operating system, computer type, demographic information, what pages the user visited, how long they stayed, what website they came from and their geographic information. This information is used to target appropriate products and services to our visitors and help to improve the users overall website experience. All activity fall within Google Analytics Term of Service . Asselin Insurance Brokers Limited have enabled the demographic reporting feature on Google Analytics to enable us to track the users age, gender and interests. Visitors can opt out of Google Analytics Advertising Features we use by downloading the Google Analytic Opt-out Browser Add-on.
IF YOU HAVE A QUESTION OR CONCERNS?
Our Information Officer:
Rene Asselin (President), can be reached at:
Asselin Insurance Brokers Limited
15 Robert Street West
Penetanguishene, ON. L9M 1M5
He will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
Registered Insurance Brokers of Ontario (RIBO)
401 Bay Street
Suite 1200, P.O. Box 45
Toronto, ON. M5H 2Y4
This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street