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St. Paul Fire and Marine Company Privacy Policy

 

The nature of St. Paul Fire and Marine Insurance Company (St. Paul) business requires a relationship of trust with our clients. In order to provide client’s with the right products, fair adjustment and claim settlement, the requisite level of service, and to ensure we make informed underwriting decisions, it is necessary that we obtain information about our clients and/or their businesses.

Although St. Paul in Canada primarily provides commercial property and casualty insurance to businesses and organizations, there is occasion where the information with which we are entrusted is sometimes of a personal nature. Our clients have a right to expect that any personal information that they provide to us or that we obtain from other sources in order to make underwriting or business decisions will be kept in the strictest confidence and that access to personal information will be restricted to those having a legitimate need to review or use that information.

Personal Information: Personal Information is information about an identifiable individual or information that permits the identification of the individual. St. Paul may also collect aggregated data, which is data from which the identity of an individual cannot be determined. Information that is not personal may be used in any way appropriate.

Personal information includes name, address, home telephone number, marital status, work history, liabilities, assets, income, banking records, health records, claims history, criminal records, driving history and other information of a personal nature.

The type of personal information St. Paul collects about an individual is dependent upon the type of insurance product. We will restrict the personal information we collect from each client to the minimum required to make underwriting, claim and business decisions.

How We Collect Personal Information: We may obtain personal information directly from the client, claimant and through insurance brokers, other insurers, credit bureaus, applications, consumer reports or by other lawful means.

How We Use Personal Information: St. Paul uses personal information to make underwriting decisions, or policy management (which shall include all extensions, renewals, and modifications of a policy), protect against fraud, claims administration, to investigate and pay claims and for recovering loss payments or expenses that an individual may be liable to reimburse to St. Paul, and to comply with federal and provincial legal requirements and/or to provide where required to our auditors and or legal advisors.

Consent: Your provision of Personal Information means that you agree and consent to the collection, use and disclosure of your Personal Information for such purposes as indicated to you, as required to provide your insurance services, as well as the purposes set out in this Policy statement and in accordance with the practices described in this Policy Statement. Your provision of Personal Information about other individuals (e.g. employees) means that you represent that those persons have consented to the collection, use and disclosure of their Personal Information for the purposes of underwriting, or policy management and claims administration in accordance with the practices described in this Policy Statement.

Withdrawal of Consent: If an individual refuses to consent to the collection, use or disclosure of his or her personal information, St. Paul may be unable to provide the product or service requested.

You may withdraw your consent to the collection, use and disclosure of your personal information for purposes not related to the delivery of the St. Paul products and services, including the receipt of marketing information and materials from St Paul.

Protection of Personal Information: St. Paul endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of the personal information entrusted to us by our clients and others. St. Paul only allows access to an individual’s personal information to those employees who need to use it in their work. St. Paul’s employees who have access to personal information are made aware of the responsibility they have for protecting that personal information and are required to make proper use of the manual and electronic controls available to them for that purpose. Our employees are subject to disciplinary procedures for the unauthorized use or disclosure of an individual’s personal information.

Disclosure of Personal Information: Given the type of the products and services that St. Paul provides in the normal course of business, it is sometimes necessary to provide an individual’s personal information to a third party, such as a broker, reinsurer, legal counsel, regulator, adjuster, repairer or administrator. We will only disclose an individual’s personal information with the individual’s consent, except where to do so would cause undue delay in providing requested services or where St. Paul is legally required to disclose the information. When it is necessary to provide an individual’s personal information to a third party, St. Paul provides only the information necessary for the third party to provide the service. St. Paul advises each third party to whom it provides an individual’s personal information that St. Paul expects that it will comply with the Canada’s privacy laws, and have the manual and/or electronic controls in place to protect that personal information.

St. Paul may disclose your Personal Information to individuals or organizations who are our advisers or service providers; and individuals or organizations who are, or may be, involved in (i) a transfer of all or part of the assets or business of St. Paul; or (ii) maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems.

Where St. Paul discloses Personal Information to organizations that perform services on its behalf, St. Paul will require those service providers to use such information solely for the purposes of providing services to St. Paul, our clients or the person concerned and to have appropriate safeguards for the protection of that Personal Information.

Retention of Personal Information: St. Paul will only retain an individual’s personal information for as long as is necessary to fulfill the purposes for which it was collected or as required by law. Currently, the principal places in Canada wherewhich St. Paul holds Personal Information is in the City of Toronto, Halifax, Montreal, and Vancouver, Calgary and Edmonton and nearby municipalities where off-site storage facilities may be located. Information held in databases and e-mail received or generated by St Paul may be maintained and stored at data centers in the United States. Information held outside of Canada is subject to the laws of the jurisdiction where it is maintained and stored.

Accessing Your Personal Information: An individual may access and rectify his or her personal information subject to any legal restrictions. For example, if to allow access would reveal personal information about a third party then access may be limited or denied. If there are reasons why access is denied, the individual will be advised of those reasons in writing. When an individual demonstrates that any information held is inaccurate or incomplete, St. Paul will make the appropriate changes to that information.

Any concerns regarding information that St. Paul maintains, or concerns regarding the manner in which St. Paul has dealt with his or her Personal Information should be addressed to our Privacy Officer:

 Graham J. Lloyd
 AVP, General Counsel and Privacy Officer
 St. Paul Fire and Marine Insurance Company
 20 Queen Street West
 Suite 200, P.O. Box 5
 Toronto, ON M5H 3R3
 E-mail: glloyd@travelers.com
Tel No: (800) 268-8481 or (416) 601-4410
 Fax No.: (416) 601-4462
 

If we are unable to resolve your concerns to your satisfaction, we will provide you with contact information with the appropriate Provincial or Privacy Commissioner, you may contact the Privacy Commissioner of Canada by writing to:

 The Privacy Commissioner of Canada
 Place de Ville, Tower B, 3rd Floor
 112 Kent Street
 Ottawa, Ontario K1A 1H3
 Tel No.: (800) 282-1376
 Fax No.: (613) 947-6850

 

 

 

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