Access to Personal Information Policy
Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and various provincial legislation ("privacy legislation") govern the protection of Personal Information. St. Paul Fire and Marine Insurance Company (Canada Branch), Travelers Insurance Company of Canada, and The Dominion of Canada General Insurance Company (collectively, "Travelers Canada") are committed to protecting the privacy and confidentiality of your Personal Information in accordance with privacy legislation and the ten privacy principles set out in PIPEDA.
"Personal Information" means any information about an identifiable individual and includes name, address, home telephone number, marital status, work history, liabilities, assets, income, banking records, health records, claims history and other information of a personal nature.
Travelers Canada is responsible for the protection of Personal Information in its possession. Where Travelers Canada discloses or transfers Personal Information to our affiliates, subsidiaries or third party providers, we use contractual or other safeguards to provide comparable levels of protection.
Compliance with the privacy principles rests with the Privacy Officer and all of the employees within the company responsible for the day to day collection and processing of Personal Information.
2. Identifying Purposes
Travelers Canada collects, uses, and discloses Personal Information (including to and from your broker, Travelers Canada's affiliates, subsidiaries and/or third parties) for the following purposes:
- to provide requested products or services;
- to accurately assess and determine which insurance products and related services will meet the needs and specific requirements of each of our customers;
- to establish and collect premiums and other amounts owing in relation to our products and services;
- to process applications for insurance;
- to communicate with a customer regarding an insurance policy;
- to investigate and adjust claims;
- to advise our customers of underwriting and other initiatives which they may find beneficial;
- to investigate, detect and prevent fraudulent insured transactions;
- to reinsure risks as required;
- to develop, enhance, market or provide products and services;
- to analyze risk and business results;
- to provide compensation and benefits to employees;
- to effectively manage customer complaints relating to an insurance policy;
- to manage and continually develop our businesses and operations, including personnel and employment matters; and
- as may be required or authorized by law.
Travelers Canada will collect, use, or disclose Personal Information with the knowledge and consent of the individual, except where inappropriate.
Consent can be implied (such as when you provide your name and address in order for us to provide you with products and services), express (express consent may be oral, in writing or electronic), and in some jurisdictions may be given by your authorized representative (such as your lawyer, a legal guardian or a person having a power of attorney).
Implied consent is inferred from the circumstances, including the relationship between the parties and the nature of the interaction. For example, when you contact an insurance broker to obtain automobile or property coverage, it is reasonable for the broker to presume your implied consent to share Personal Information with the insurer so that together they can assess and meet your insurance needs. Similarly, it is reasonable for the insurer to presume your implied consent to disclose your Personal Information to your broker, in order to assess your application or administer your insurance policy.
When Travelers Canada handles sensitive Personal Information, Travelers Canada obtains express consent. Sensitive information includes medical information or financial records for claims involving personal injury or income loss. In these circumstances, the sensitive Personal Information may not be collected until a claim is made and it becomes necessary to obtain such information to determine entitlement to benefits.
In certain circumstances, as permitted or required by law, Travelers Canada may collect, use or disclose Personal Information without the knowledge or consent of the individual, such as where Personal Information is subject to solicitor- client privilege or is publicly available as defined by regulation, where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way, to investigate a breach of an agreement or a contravention of a law, to act in response to an emergency that threatens the life, health or security of an individual, for debt collection or to comply with a subpoena, warrant or court order.
By providing information about a third party, such as a family member, director, officer, or employees, you represent that you have obtained that person's consent to the collection, use and disclosure in accordance with this policy. You may choose to withhold or withdraw consent; however, this may affect the ability of Travelers Canada to provide insurance or administer an insurance policy. Where the withdrawal or withholding of consent prevents Travelers Canada from providing adequate customer service, Travelers Canada may be unable to process your claim for payment or may cancel an existing policy.
4. Limiting Collection of Personal Information
Travelers Canada will only collect from you (or other sources) Personal Information that is necessary for the identified purposes. This information may be collected within Canada or the United States (see section 5 below in relation to security and confidentiality). Personal Information will only be collected by fair and lawful means.
Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information will be retained only as long as necessary to fulfill those purposes.
If you are purchasing insurance (or considering purchasing insurance) through an insurance broker, the broker collects your Personal Information to assess your insurance needs. The broker may recommend that you consider a number of products from different companies. In order to recommend products, the broker provides insurance companies with your Personal Information. The broker will explain that this exchange of Personal Information is necessary for insurers to assess your risk profile and provide an accurate quotation regarding the cost of the policy being considered.
The information collected by the broker will depend on the insurance coverage you want. For example, if you want to purchase automobile insurance, provincial governments require that you provide information requested on the Automobile Application form. This application form is used by all insurance companies and is approved by provincial insurance regulators. The Automobile Application form varies from province to province but all provincial governments require similar information, such as your name, address, how the vehicle will be used, and the applicant's and listed drivers' accident history and history of convictions arising from operating an automobile. In some provinces you will be required to answer questions about your health, with respect to your ability to safely operate a vehicle.
To provide property insurance, insurance companies require Personal Information such as your date of birth and occupation, your past experience renting and owning property, as well as information regarding the property. Where there is a mortgagee or any other person with a legal interest in the property, you must disclose this information. Also, Travelers Canada may require a home inspection for underwriting purposes, to be completed by a professional and independent firm, to ensure the property is adequately protected.
Travelers Canada also collects credit information about you, such as your credit based insurance score, to provide you with a more accurate premium on your Travelers Canada property insurance, to analyze business results and when required to enable pre-authorized payments on your policy. To obtain credit information about you, Travelers Canada will also collect and disclose personal information about you to Canadian credit reporting agencies. Travelers Canada may also obtain updated credit information about you when your property policy renews, or when you add, delete or change coverage on your property policy.
5. Limiting Use, Disclosure and Retention of Personal Information
Travelers Canada will not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
Travelers Canada discloses or transfers Personal Information to third parties, including related or unrelated companies ("service providers") that carry out certain functions on its behalf such as order fulfillment, data processing, the administration, investigation and processing of claims and storage. Some of the third parties are located outside of Canada, including the United States, India, Philippines, the United Kingdom and Ireland. Travelers Canada remains accountable for your information and contractual and other safeguards are employed to ensure service providers meet stringent security and confidentiality requirements; however, such information is subject to the laws of the other countries, including the United States, and may be accessible to law enforcement and national security authorities of those other countries, including the United States.
Travelers Canada retains Personal Information only as long as necessary to accomplish the identified purposes or satisfy our legal or business obligations.
Travelers Canada never sells Personal Information, or other information relating to you, to any organization, including charities or direct marketing groups.
Travelers Canada will use its best efforts to ensure that Personal Information is as accurate, complete and up-to-date as is necessary for the identified purposes.
Travelers Canada will protect Personal Information with safeguards appropriate to the sensitivity of the information.
The methods of protection will include physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example, security clearances and limiting access on a "need-to-know" basis) and technological measures (for example, the use of passwords and encryption). However, your use of the internet and electronic mail is at your own risk.
Travelers Canada will make the following information available: how to gain access to Personal Information, the type of Personal Information held by Travelers Canada and what Personal Information is made available to related entities, a general account of the use of Personal Information, general information concerning our policies respecting Personal Information and how to contact our Privacy Officer.
9. Individual Access
Upon written request, Travelers Canada will inform you of the existence, use and disclosure of your Personal Information and give you access to that Personal Information.
If you would like to make such a request, please contact the Privacy Officer of Travelers Canada at the address below. Please note that Travelers Canada may charge reasonable costs in providing access to and copies of Personal Information and will inform you if such costs arise.
Travelers Canada may refuse a request or be unable to provide access to all the Personal Information as permitted or required by law. Examples include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.
10. Challenging Compliance
If you have a complaint regarding Travelers Canada's compliance with privacy legislation or this policy, you may contact Travelers Canada's Privacy Officer at:
165 University Avenue
Toronto, Ontario M5H 3B9
Tel: 416.362.7231 or 1.800.268.8447
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner, if applicable.
Last reviewed August 11, 2020