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Protecting the confidentiality of your personal information
has always been an important part of the way we do business.
To ensure that we protect your privacy, the Kent & Essex
Mutual Insurance Company has adopted a Privacy Code. This Code
sets out how and why we collect and use personal information
about our customers. It also explains limited circumstances under
which we may need or be required to disclose it.
"Personal information" means information that identifies
you as a specific individual. It does not include the sort of
general information that could be found in a business directory
or a telephone book.
Effective January 1, 2004, the Government of Canada will implement
the last phase of the Personal Information Protection and Electronic
Documents Act (PIPEDA). This federal statute will then apply
to insurance companies and many other industry sectors.
This legislation establishes rules and principles for the
use and disclosure of personal information based on the ten privacy
principles developed by the Canadian Standards Association. These
principles recognize that we live in an era when commercial information
is exchanged and circulated by electronic means. It balances
the individual's right to privacy in their personal information
with the reasonable need of organizations to collect, use or
disclose personal information.
Under the new legislation, an organization may collect, use
or disclose personal information only for limited purposes that
a reasonable person would consider to be appropriate in the circumstances.
The Personal Information Protection and Electronic Documents
Act requires us to provide the same safeguards for your privacy
that we have always provided on a voluntary basis. Our Privacy
Code sets out these principles in simple terms. It explains how
we ensure that your privacy and the confidentiality of your personal
information are protected.
OUR PRIVACY CODE
The Kent & Essex Mutual Insurance Company's Privacy Code
is based on the following ten principles adopted by the Personal
Information Protection and Electronic Documents Act (PIPEDA).
PRINCIPLE #1: OUR ACCOUNTABILITY FOR THE COLLECTION,
USE OR DISCLOSURE OF PERSONAL INFORMATION
As a customer of the Kent & Essex Mutual Insurance Company,
you have a right to expect that your insurer is accountable for
the personal information it collects and uses. "Customer"
means a current and former insured, an applicant for insurance,
a claimant under one of our policies as well as an individual
insured as part of a group or corporate policy.
We are responsible for maintaining and protecting your personal
information while it is under our control. This includes any
personal information that may need to be disclosed to third parties
for processing or other administrative functions.
To help ensure the confidentiality of your personal information,
we have established policies and procedures to ensure that we
comply with the Personal Information Protection and Electronic
Documents Act.
We have designated a privacy officer who is responsible for
our company's compliance with the ten privacy principles developed
by the Canadian Standards Association.
If you have any questions or inquiries about how your personal
information is stored, or when it may need to be disclosed to
others, our privacy officer is there to assist and explain our
policies to you.
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PRINCIPLE#2: IDENTIFYING OUR PURPOSE FOR THE COLLECTION,
USE OR DISCLOSURE OF PERSONAL INFORMATION
Before or when we collect information about you, we will explain
how we intend to use it. The Kent ~ Essex Mutual Insurance Company
collects personal information only for the following purposes:
a) establishing and maintaining communications with customers;
b) underwriting risks on a prudent basis;
c) investigating and paying claims; d) detecting and preventing
fraud;
e) offering and providing products and services to meet customer
needs; f) compiling statistics;
g) complying with the law; and
h) a business or activity which it may undertake under applicable
federal, provincial or territorial legislation.
Unless we are required by law, the Kent & Essex Mutual
Insurance Company will not use or disclose any personal information
that has been collected without documenting the new purpose and
obtaining your consent. If you have any questions about these
purposes, our privacy officer will be pleased to explain them
to you.
PRINCIPLE#3: OBTAINING YOUR CONSENT FOR THE COLLECTION,
USE OR DISCLOSURE OF PERSONAL INFORMATION
The Kent & Essex Mutual Insurance Company will make a
reasonable effort to make sure that our customers understand
and consent to how their personal information will be used by
the Company.
In certain circumstances, consent with respect to use or disclosure
may be sought after the information has been collected but before
use.
Personal information may need to be collected, used or disclosed
without the knowledge and consent of the individual. For example,
legal, medical or security reasons may make it impossible or
impractical to seek consent.
The Personal Information Protection and Electronic Documents
Act recognizes that when information is being collected for the
detection and prevention of fraud or for law enforcement, seeking
the consent of an individual may defeat the purpose of collecting
the information. Seeking consent may also be impossible or inappropriate
when the individual is a minor, seriously ill, or mentally incapacitated.
In obtaining your consent, we will always use reasonable efforts
to ensure that you are advised of the identified purposes for
which any personal information collected will be used or disclosed.
PRINCIPLE #4: LIMITING OUR COLLECTION OF PERSONAL INFORMATION
We will always limit the collection of personal information
to that which is necessary for the identified purposes. Typically,
this is information that is required to enable us to underwrite
your policy of insurance and charge a fair premium. We may need
to collect personal information from other sources including
credit bureaus.
Under certain circumstances we need to collect information
to assist us in adjusting or investigating a claim. This may
involve the use of licensed and regulated independent insurance
adjusters or investigators. We will always collect personal information
by fair and lawful means.
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PRINCIPLE #5: LIMITING THE USE, DISCLOSURE AND RETENTION
OF PERSONAL INFORMATION
Personal information will not be used or disclosed for purposes
other than for which it was collected, except with your consent
or as permitted or required by law. Your personal information
will be retained only as long as it is necessary to fulfill those
purposes.
There are situations where Kent & Essex Mutual Insurance
Company may disclose a customer's personal information as dictated
by prudent insurance practices. For example:
a) Risk-Sharing: As part of the underwriting and claims handling
process, Property and Casualty insurers transfer personal information
to other insurance companies including reinsurance companies
which share in the risk. This would include situations where
the customer has made a fraudulent application for or renewal
of a policy of insurance.
b) Information Services: Property and Casualty insurers disclose
personal information for underwriting, claims, classification
and rating purposes.
c) Insurance Services: Property and Casualty insurers disclose
personal information to businesses that provide goods and services
to insurance companies and/or their customers, such as data processors,
loss control managers and claims adjusters.
d) Insurance Intermediaries: Property and Casualty insurers
may disclose personal information to their insurance intermediaries,
such as brokers and agents.
Only the information necessary for these services will be
provided by us to these service providers.
The Kent & Essex Mutual Insurance Company does not provide
or sell its customer lists to any outside company for use in
marketing or solicitation. Only employees with a business "need
to know", or those whose duties require it, are granted
access to personal information about our customers.
We keep personal information only as long as it remains necessary
or relevant for the identified purposes or as required by law.
Personal information that is no longer necessary or relevant
for the identified purposes or required to be retained by law
is destroyed, erased or made anonymous.
PRINCIPLE#6: KEEPING YOUR PERSONAL INFORMATION ACCURATE
The Kent & Essex Mutual Insurance Company makes every
effort to ensure that personal information about its customers
is as accurate, complete, and up-to-date as is necessary for
the purposes for which it was collected.
This may require contact with your insurance broker to confirm
or update personal information required for underwriting purposes.
In addition, the Insurance Act and the terms and conditions of
your policy of insurance may require you to notify us of material
changes to your personal information.
If you have any questions about the accuracy and completeness
of the personal information that we have collected or retained,
please do not hesitate to contact our privacy officer. If you
need to update some aspect of your personal information, please
contact your insurance broker or agent directly.
PRINCIPLE #7: SAFEGUARDING YOUR PERSONAL INFORMATION
The Kent & Essex Mutual Insurance Company takes steps
to protect personal information with security safeguards appropriate
to the sensitivity of the information.
Specifically, we have stringent security measures in place
to protect personal information against such risks as loss or
theft, computer hackers, unauthorized access, disclosure, copying,
use, modification or destruction.
The Kent & Essex Mutual Insurance Company protects your
personal information regardless of the format in which it is
held. We also protect personal information we disclose to third
parties by contractual agreements stipulating the confidentiality
of the information and the purposes for which it is to be used.
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All our employees with access to personal information are
required as a condition of their employment to respect the confidentiality
of personal information.
PRINCIPLE #8: OPENNESS CONCERNING OUR PRIVACY PRACTICES
The Kent & Essex Mutual Insurance Company pursues a policy
of openness about the procedures it uses to manage personal information.
We will make specific information about our policies and practices
relating to the management of their personal information available
to customers upon request.
We ensure openness by providing you with the following information:
a) the title and address of the privacy officer accountable
for our compliance with the policy; b) the name of the individual
to whom inquiries or complaints can be forwarded;
c) the means of gaining access to personal information held
by our company; and
d) a description of the type of personal information held
by the Kent & Essex Mutual Insurance Company, including a
general account of its use.
The Kent & Essex Mutual Insurance Company makes information
available to help our policyholders exercise informed choices
regarding the use of their personal information.
PRINCIPLE #9: CUSTOMER ACCESS TO PERSONAL INFORMATION
The Kent & Essex Mutual Insurance Company informs its
customers of the existence, use and disclosure of their personal
information upon request and provides access to that information.
Our customers are able to challenge or correct the accuracy and
completeness of their personal information and have it amended
when appropriate.
When a request is made in writing, we will inform you in a
timely fashion of the existence, use and disclosure of your personal
information and you will be given access to that information.
In order to safeguard your personal information, we may require
you to provide sufficient identification information to permit
us to authorize access to your file.
In certain exceptional situations, we may not be able to provide
you with access to all of the personal information we hold. Exceptions
may include information that is prohibitively costly to provide,
information that contains references to other individuals, information
that cannot be disclosed for legal, security or commercial proprietary
reasons, information that is subject to solicitor-client or litigation
privilege, or, in certain circumstances, information of a medical
nature. If this is the case, the Kent & Essex Mutual Insurance
Company will provide the reasons for denying access upon request.
Customers can obtain information or seek access to their individual
files by contacting our designated privacy officer at the address
described below.
PRINCIPLE #10: CHALLENGING COMPLIANCE
A customer has the right to challenge the Kent & Essex
Mutual Insurance Company's compliance with the above principles
by contacting the privacy officer accountable for our compliance
with the policy.
The Kent & Essex Mutual Insurance Company maintains strict
procedures for addressing and responding to all inquiries or
complaints from its customers about its handling of personal
information. We inform our customers about our privacy practices
as well as availability of complaint procedures.
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Our privacy officer will investigate all complaints concerning
compliance with the privacy policy. If a complaint is found to
be justified, we will take appropriate measures to resolve the
complaint including the amendment of our policies and procedures,
if necessary.
In exceptional circumstances, the privacy officer accountable
for compliance with our privacy policy may seek external legal
advice where appropriate before a final response to individual
complaints.
For Further Information
For more information, please contact our privacy officer directly
by:
Toll-free number: 1-800-265-5206
Email: kevink@kentessexmutual.com
Kent & Essex Mutual Insurance Company
250 St. Clair St.,
PO Box 356,
CHATHAM ON
N7M 5K4
ATTENTION: Kevin Konecny
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