Our Privacy Promise describes in clear language how Topley, Sanders Jepson ensures the protection of the personal information you entrust to us. We have always felt we had a Privacy Promise prior to it being now a legal obligation.

 When you become a Topley Sanders Jepson client, you share important personal information with us. You do this so that we can serve you better and in return knowing we would honor and respect your privacy. Your trust will not be misplaced. At Topley Sanders Jepson we are committed to offering you insurance products and services, therefore it should come as no surprise that we are also committed to meeting the privacy standards applicable to you.

What is "personal information"?

"Personal information" is the information about an identifiable individual, but does not include the name, or business contract information of an employee of an organization.

What information are we responsible for protecting?

Topley Sanders Jepson is responsible for protecting your personal information in its custody or under is control, including personal information that has been transferred to, or received from a third party.

Collecting, using and disclosing your personal information, why do we do it?

We collect use and disclose personal information for one reason, to serve you better. Knowing you better helps us understand your insurance needs, communicate effectively with you, and provide you with the services and products you want.

We collect use and disclose your personal information to:

- verify your identity

- determine eligibility for Topley Sanders Jepson Insurance products and services

- assess and underwrite your insurance needs

- determine premiums

- determine suitability of your insurance requirements to the markets we represent

- comply with the law

Personal information may be collected, used or disclosed for any of these "identified purposes" set out above, if personal information is not needed for one of the identified purposes, we will not use or disclose it without obtaining additional consent from you.

How do we gather your personal information?

 The collection, use and disclosure of your personal information depend on how you do business with us. We may gather information from the following sources:

- From you personally, on applications or on other forms for insurance filled out by telephone,  through e-mails or face-to-face interviews. For example your name, address, phone number, e-mail address, occupation and banking information.

- From your interactions with us. For example through your payment, underwriting and claims history.

- From the government and other entities that have information on your driving record and claims history.

What you are committing to when you share personal information with us.

If you provide personal information to us through any of the previously mentioned sources, you do so with the understanding that your personal information may be used or disclosed for the identified purposes amongst us. The previously mentioned sources, or third parties and that Topley Sanders Jepson may verify such information or obtain additional personal information about you by checking with government agencies, credit bureaus, motor vehicle agencies and other fact collecting and verifying entities to assist us for the identified purposes.

You're Consent

Your knowledge and consent is required before we may collect, use or disclose any of your personal information, except in special circumstances. These special circumstances include such times when your consent is deemed by law or not required by law. Circumstances may include fraud investigation, a investigation by the police, or other investigations where your personal information is publicly available or in situations otherwise permitted by the law.

If any of the personal information that we collect is sensitive, we will obtain additional written or oral consent from you before collecting, using or disclosing the information.

When collecting personal information about you from the third parties for which you have provided us your consent, we will ensure that the third party is notified of your consent to our collection of your personal information.

How do you provide us with your consent?

We accept any of the following as your consent for Topley Sanders Jepson existing use and future collection, use and disclosure of your personal information for the identified purposes:

- your express written or oral consent obtained through an application process

- consent provided by an authorized representative, such as a legal guardian or power of attorney

Consent may not be required for:

- If you obtain insurance for your family, or anyone else, you represent that you have obtained consent from them to the collection, use and disclosure of their personal information for the identified purposes, even though they might not be present during the application process.

- If you have an existing insurance policy with us and you request amendments to the policy, it is assumed that the consent which you gave to use when buying the original policy remain in effect.

- If you voluntarily provide personal information either orally or in writing if it is reasonable that a person would voluntarily provide that information.

- In the event that Topley Sanders Jepson proceeds with a business transaction such as the purchase, sale, lease, transfer, merger or amalgamation or any other type of acquisition, or disposal, or taking of a security interest in respect of, an organization or a portion of an organization or any business asset of an organization, your personal information may be shared with such prospective party to complete the business transaction.

How to withdraw your consent

You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. If the withdrawal of consent would frustrate the performance of a legal obligation your consent may not be withdrawn unless agreed to by us. Please not that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive.

To withdraw your consent you should contact our Privacy Officer at the address or telephone number listed. Unless we hear otherwise from you then you are giving us your consent for the collection, use and disclosure of personal information as provided in this policy for the identified purposes.

How long do we keep your personal information?

Your personal information is retained only so long as we need it to effectively provide products and services to you and for a reasonable length of time thereafter in case we need to meet any legal or business purposes.

How do we protect your personal information?

Whether it is electronic or paper-base format, Topley Sanders Jepson maintains strict security systems to safeguard your personal information when in its custody or under its control from unauthorized access, collection, use, disclosure, copying, modification, or disposal. Even when we no longer need your personal information we take as much care to destroy it as we do when storing it.

In the event that we transfer your personal information to a third party for processing (for example, printing cheques, managing claims and client statement, or for data processing) we contractually require any person or organization providing products or services on our behalf to protect our customers confidentiality in a manner consistent with our own internal measures or as requires by law.

You're right to access your personal information.

You have a right to access your personal information that we have in our custody or under our control subject to any legal restrictions or rights of refusal of Topley Sanders Jepson Insurance. You also have a right to know which third parties have received your information from INC Canada, and under what circumstances.

How do you access your personal information?

Please make your request in writing to Topley Sanders Jepson's privacy officer, stating as specifically as possible which personal information you are requesting.

We will try to respond to requests as soon as possible, and will advise you if for some reason we cannot respond right away. Topley Sanders Jepson may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost, at which time a deposit may be requested for the preparation of your access request.

Topley Sanders Jepson Insurance has the right or legal obligation to refuse your request for access to personal information if:

- The information is protected by any legal privilege, granting access would reveal confidential commercial information                                                         

 - Doing so would reasonably be expected to threaten the life or security of another individual                                   

 - The information was collected for purposes related to an investigation or legal proceeding                           

- The disclosure of the information might result in that type of information no longer being provided to the organization when it is reasonable that that type of information would be provided    

- The information would reveal the identity of an individual who has provided an opinion about another individual providing the opinion does not consent to the disclosure of his or her identity                                      

- The information is generated in the course of a formal dispute resolution process; or                                      

- The information would likely reveal personal information about another individual

Keeping your information accurate

Topley Sanders Jepson strives to ensure that the personal information we have on file about you is as accurate and up-to-date as necessary for the identified purposes for which it is to be used for. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records. Topley Sanders Jepson shall amend personal information that is materially inaccurate or incomplete and, where appropriate, shall endeavor to advise other parties having access to the information in question.

How to contact us

You can direct any queries about this policy to Topley Sanders Jepson Privacy Officer at the telephone, e-mail address or mailing address listed on the contact page.

For more information to file a complaint, make enquiries or to opt out of all parts of this policy please contact Topley Sanders Jepson Privacy Officer

If you have a complaint related to this personal information policy or any of our procedures contact our Privacy Officer if your complaint is justified we will take the steps necessary to resolve the issue, including amending our Policy and practices necessary

If we are not able to resolve your concern or if you have any other concerns about Topley Sanders Jepson personal information policy and procedures you may contact the Privacy Commissioner of Canada, or if applicable the Provincial Privacy Commissioner. Topley Sanders Jepson Privacy Officer will provide you with this contact information upon request

Industry Terms and What They Mean

Adjuster: a representative of an insurance company who is licensed to investigate claims which are submitted and to negotiate the amount of the settlement, if any.

Power of attorney: the authority given to one person or a corporation to act on behalf of another person or corporation in legal and financial matters

Reinsurance risks: when an insurance company places all or part of the insurance with another insurance company, who will then be responsible for a percentage of the risk or loss. This does not affect you in any way

Third Party: Person other than you who is involved in a transaction.

Underwrite: to estimate the value and determine at what amount and on what terms the insurance company will provide insurance underwrite, it is another way of saying insure.