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Family
Insurance Privacy Policy
Family Insurance is committed
to respecting the privacy rights of individuals by
ensuring that their personal information is
collected, used, and disclosed in an appropriate
manner. We have designated a Privacy Officer on
behalf of Family Insurance (Stuart Cox, Manager
of Claims) who has sufficient authority within
the company to ensure compliance.
We will use reasonable means
to ensure that personal information is given a level
of protection while being processed by a third
party. Common purposes for collection include:
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Enabling the Broker to
acquire or renew an insurance policy;
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Assisting the customer
with their claim
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Assisting a 3 rd party
dealing with our customer's claim
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Personal information on
our employees for the purposes of employment
(address, telephone, etc.)
We may obtain express consent
for the collection, use, or disclosure of personal
information OR we may determine that consent has
been implied by the circumstances.
Express consent is specific
authorization given to us by the Insureds, either
orally or in writing. Implied consent is one in
which we have not received oral or written
authorization from the Insureds, but the
circumstances allow us to collect, use, or disclose
the personal information.
Consent may be withdrawn at
any time, however, we would require such withdrawal
to be in writing.
There are circumstances
wherein we are not required to obtain an
individual's consent or explain the purpose for
collection, use or disclosure of their personal
information:
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We may collect personal
information without consent where it is in the
individual's interest and timely consent is
unavailable, or to investigate a breach of an
agreement or a contravention of a law;
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In an emergency situation
where an individual's life, health or security
is threatened;
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We may disclose personal
information without consent for law enforcement,
national security, debt collection, to a lawyer
representing our company or in an emergency
position (see above)
We will only use or disclose
personal information for legitimate purposes. We
will retain the personal information only as long as
necessary for the fulfillment of why we collected
the information initially.
Insured's who have a claim
will have their personal information retained on our
software system indefinitely. Insured's personal
information in a hard copy claims file will be
stored in an off-site, secure facility for seven
years and will then be destroyed.
Family will ensure the
accuracy and completeness of personal information
under our care and control.
Family will also protect the
personal information, regardless of the format,
against loss, theft, unauthorized access,
disclosure, copying, use, or modification. When we
transfer client information to a third party, we
will mask any information that is not needed by the
third party. Our methods include:
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Locked filing cabinets;
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Floor alarm system with
motion detectors
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All computer-based data is
protected by passwords, encryption and firewalls
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All computer-based data is
regularly backed-up and stored off-site in both
on-line and off-line formats. Data is purged
from Family's computer systems after seven
years.
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All closed claims files of
our Insureds are stored in a secure off-site
facility. Those records are destroyed seven
years after their closed date. All paper
documentation is placed in recycling bins -
either shredded or not. The recycling vendor we
use takes the bins to their warehouse and all
paper goes through a shredder.
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Family also has a paper
shredder on site.
Family's Privacy Officer held
a Privacy Act seminar for all staff in the company
on January 6, 2004. A "Privacy Act" package was
handed out to each employee. All new employees will
also receive this package.
All staff are aware of who our
Privacy Officer is so if any member of the public or
our brokers call, they can be directed to our
Officer. We have also posted information on the
Privacy Act, with helpful links, on our website.
Upon written request, an
individual will be informed as to whether or not we
hold personal information about him/her. If Family
does hold such information, we will provide access
to that information and how we use it to that
individual. We will respond to all written requests
within 30 days (unless we explain we need a longer
period).
We may refuse the request and, in that regard, our
refusal will be explained in writing.
We will not be providing
access to information to an individual if that
personal information reveals information about
someone else, someone's life or security might be
threatened, the information was collected without
consent for the purposes of an investigation of a
breach of an agreement or contravention of the law.
Our Privacy Officer will keep
a Privacy Log in which each request or complaint is
logged as to name, time, date, request or complaint,
Family's answer or resolution.
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