Our Privacy Pledge to You
Your Privacy is Important to Us
Canada’s national privacy legislation, the Personal Information Protection and Electronic Documents Act came into force on January 1, 2001. Since January 1, 2004, this privacy legislation applies to all businesses that collect, use or disclose Personal Information. Personal Information means information about you that can be used to identify you. Depending on the province you live in, you may have rights under similar provincial laws.
At Combined Insurance Company of America and its Worksite Solutions unit, we pledge to protect your privacy and safeguard your personal information. As part of our pledge, we have established 10 Privacy Principles to govern our actions in collecting, using and disclosing our customers’ Personal Information. The 10 Privacy Principles build upon earlier work by the Canadian Standards Association's Model Code for the Protection of Personal Information and the national privacy law.
Combined Insurance Company of America's 10 Privacy Principles
Principle 1 - Accountability
Combined Insurance Company of America accepts responsibility for maintaining and protecting Personal Information under its control. To meet this responsibility, Combined has appointed a Privacy Officer to ensure we meet the 10 Privacy Principles.
Principle 2 - Identifying Purposes
Generally, we will identify the purposes for which we collect Personal Information from customers before or as we collect the information. In some instances, Worksite Solutions collects personal information from individuals before they become customers of Combined for the purposes of performing analyses for employers.
Principle 3 - Consent
We ask for your consent to collect, use or disclose Personal Information except where required or permitted by law.
Principle 4 - Limiting Collection
We do not collect Personal Information from customers other than the information necessary for the purposes we identified.
Principle 5 - Limiting Use, Disclosure and Retention
We will only use or disclose your Personal Information for the purpose for which it was collected, unless you otherwise consent, or if it is required or permitted by law. We keep your Personal Information only for as long as we need to fulfill the purposes for which it was collected.
Principle 6 – Accuracy
We keep your Personal Information in as accurate, complete and up-to-date form as is needed to fulfill the purposes for which we use it.
Principle 7 - Safeguarding Information
We protect your Personal Information against loss or theft and safeguard it from unauthorized access.
Principle 8 - Openness
Combined will make information on the management and handling of customers’ Personal Information available to customers. This Policy is part of that commitment.
Principle 9 – Customer Access
If you ask us, we shall tell you whether we have your Personal Information and how we use it. We shall also give you reasonable access to the information. If you can show it is inaccurate or incomplete, you will have the opportunity to correct or amend your Personal Information.
Principle 10 - Customer Complaints and Suggestions
Customers may direct any questions or inquiries about our privacy practices to Combined’s Privacy Officer.
The following describes our Personal Information privacy practices and explains how we collect, use and disclose your Personal Information.
Kinds of Personal Information We Collect
At Worksite Solutions, we collect and maintain information that refers specifically to you. The types of Personal Information we collect and maintain may include your:
Name
Mailing Address
E-mail Address
Personal and Business Telephone Numbers
Social Insurance Number
Date of Birth
Names and Ages of Spouse and Children
Beneficiary Information
Occupation
Employer
Annual Income
Other General Financial Information
Health Information
Other Insurance Coverage
How We Use Your Personal Information
You can trust that your Personal Information is collected and shared only as is necessary to provide you with the very best support, service and product options. We will only collect and use information about you for the following purposes:
- To understand your product and service needs.
- To ensure that our products and services meet your needs.
- To determine eligibility for our products or services.
- To meet your ongoing service and product needs.
- To administer products and services (investigate and adjudicate claims, generate billing statements, change coverages, etc.).
- For internal, external and regulatory audit purposes.
- To fulfill our legal and regulatory responsibilities.
- To perform analyses for employers who contract with Worksite Solutions.
We will obtain your consent before using your Personal Information for any other purpose.
Where We Get Your Personal Information
While we get some personal information from your employer, we get most of our information directly from you. Usually, the insurance application and other standard industry forms give us the information we need. We may also get information about you from telephone calls with you, or from letters, e-mail and other correspondence we have with you.
But sometimes, more information is necessary. For example, we may ask your doctor for more details about your medical history. We may also verify or obtain more information about you from a credit bureau.
Who Has Access to Your Information
We employ physical, electronic and procedural safeguards to protect your Personal Information. In addition, we restrict access to your Personal Information to those employees and agents who use your Personal Information to deal with the purposes to which you consented. For example, an Underwriter would need access to your Personal Information to evaluate your application; a Claims Adjuster to settle your claim; or a Representative to answer your questions and offer you other types of coverage that may interest you.
Generally, Combined and Worksite Solutions will not collect or disclose your Personal Information without your consent, unless required or permitted by law. Sometimes, we must disclose information about you to an insurance regulatory authority, a government agency, a law enforcement agency or, if a court orders us to, to another third party.
We may also share your Personal Information with other businesses not officially connected to Combined and Worksite Solutions, but who work for us to provide our products or services. They will protect any Personal Information given to them, at the same level as we do.
Various industry and professional organizations may also ask us for aggregated customer information in order to conduct research studies. These studies assess conditions or trends in the market and never identify individuals.
We will not obtain additional consent before providing your Personal Information in any of these circumstances. But, if we do provide your information to any party outside of Combined and Worksite Solutions, we will record each time that a disclosure is made, including the relevant facts disclosed. As far as possible, we will require anyone who receives your Personal Information to meet the same privacy standards we do.
Accuracy of Your Personal Information
We will try to keep your Personal Information accurate, up-to-date and complete. However, circumstances may require a change to your information. If you need to update or correct your Personal Information that we have on file, simply contact us at the telephone number provided at the end of this page.
Access To Your Personal Information
To access and verify any of your Personal Information, simply call us at 1-888-815-3688. In most cases, your Personal Information will be provided promptly upon request and free of charge. We will provide in-depth Personal Information, which requires work for us to assemble, within 30 days of your request. We may charge you for the cost of providing such information.
Withdrawal of Consent
To withdraw your consent at any time, simply call us at 1-888-815-3688. You can refuse to consent to our collection, use or disclosure of your Personal Information. You can withdraw your consent to our continued collection, use or disclosure. We may require you to complete a form documenting your request.
Refusing or withdrawing consent is subject to applicable legal and contractual requirements. Withdrawing consent does not apply to Personal Information used in policy issuance or renewal, insurance underwriting or claims administration of your current policies. It may also may affect our ability to provide services to you. Federal and provincial laws may require us to collect and report Personal Information to government agencies and we will continue to do so.
If You Have Questions or Concerns
We hope this “Privacy Pledge to You” reassures you that Combined and Worksite Solutions is committed to protecting your privacy and safeguarding your Personal Information.
If you have any questions about our privacy policies and practices, please call us toll free at:
1-888-815-3688
If you do not wish to be made aware of new Worksite Solutions programs and services, please write to us at:
Worksite Solutions / Combined Insurance
Attention: Privacy Officer
300-7300 Warden Avenue
Markham, Ontario L3R 0X5
Worksite Solutions … Sensible Solutions for a Secure Tomorrow
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