Brokerage Privacy Information Bulletin
BINKS is in business to provide you with a broad variety of insurance and financial services. To meet your needs and serve you well, BINKS needs to know about your personal information, the details of which can differ depending on the types of insurance and financial services you require.
By purchasing insurance or financial services, you are providing your consent to the collection, use, and disclosure of certain personal information. You, as an individual, have a right to know how your broker collects, uses, and discloses personal information. You have a right to expect that, to the best of our ability, your personal information held by us remains accurate, confidential and secure.
BINKS is proud of its reputation in maintaining the confidentiality and security of personal information. We’ve provided this information bulletin to explain to you how we protect the privacy of individual client’s personal information.
The need for confidentiality
As professional brokers we are committed to holding our clients personal information in strict confidence, and we shall not disclose any such information unless authorized by our clients, required by law to do so or required to do so in conducting negotiations with underwriters or insurers on behalf of the client.
Except as outlined below, a record is kept each time personal information is disclosed, noting the nature of the disclosure, the date and the identity of the party to whom the disclosure was made. Individual records of disclosure are not maintained for regular or routine actions such as transfers of information to insurers, underwriters and claims adjusters.
The Brokerage’s Privacy Declaration: “Putting the Client First” is based on the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information and the Federal Personal Information Protection and Electronic Documents Act. A copy of our brokerage’s Privacy Declaration is available on request or can be viewed below.
The need for trust
Trust comes with confidence. The more you know about us, the more confident you can feel about dealing with BINKS. Similarly, the more we know about you, the better we can serve you.
BINKS collects and uses information about you for only the following purposes:
- To understand your needs
- To analyze the suitability of our insurance and financial products or services for you
- To determine your eligibility for our products and services
- To set up, manage and offer products and services that meet your needs
- To provide you with ongoing service
- To meet our legal and regulatory requirements
- To facilitate the underwriting process and insurance claims.
Because it is important that we keep your trust, we will only ask for information we need, and when we ask you for information, we’ll let you know why we need it.
Subject to legal and contractual requirements, you can refuse to consent to our collection, use or disclosure of information about you, or withdraw your consent to our further collection, use or disclosure of information at any time by giving us reasonable notice in writing.
If you refuse or withdraw your consent to the collection, use or disclosure of information about you, we may not be able to provide or continue to provide you with some products, services or information of value to you.
With your consent and where the laws allow, a broker may share your personal information (other than health information) with other brokers within the brokerage so that they may directly tell you about their products and services.
The need for accuracy
While BINKS tries to ensure that the information we hold about you is accurate, complete and up-to-date, it is in your obligation to inform your broker, promptly of a change of name, address or any other relevant information.
If you believe that personal factual information in your records may be inaccurate, we make it easy for you to access, verify and update it. If information has been provided to third parties, we will convey the corrected information to them, if necessary.
If we do not agree to change your personal information, you may challenge our decision. We will make a record of this challenge and, if necessary disclose the challenge to third parties who also possess the information.
The need for access
To review the personal information, which BINKS has about you, simply notify your broker. Basic personal information can be verified on the spot, at no charge. If you wish to review more extensive information, you’ll be asked to provide details regarding the nature of the information you wish to check.
The information will be obtained from our files and will normally be provided within 30 days of your request. There may be a charge for retrieving this information, in which case you will be notified in advance and may, if you like, withdraw your request. You may also challenge the reasonableness of the charge.
Sometimes we may not provide you with information about you that is within our control. This can occur if your right of access is constrained pursuant to the provisions of the Federal Personal Information Protection and Electronic Documents Act. For example, we will not provide you with personal information in our control if:
- It would reveal personal information about another party and your personal information cannot be separated.
- The information is subject to solicitor/client or litigation privilege
- It contains the brokerage’s confidential commercial or proprietary information, or if it cannot be disclosed for legal reasons.
- The information is used for the detection and prevention of criminal activity and dealings in the proceeds of crime.
If we deny your request for access to your personal information, you will be told why, unless prohibited by law. You may challenge that decision.
Once you have the information, all you have to do is check it for accuracy and let us know if there are any corrections required. We will correct our records or make note of any differences. If information has been provided to third parties, we will convey the corrected information or the note of any differences to them, if necessary.
The need for security
Every Brokerage employee, as a condition of employment, takes responsibility for protecting client privacy, confidentiality and security. This obligation remains in effect even after an employee leaves the Brokerage.
Suppliers of services to the brokerage such as software vendors are required to sign contracts obligating them to protect the privacy and confidentiality of personal information provided to them to enable them to perform their function.
Appropriate controls are in place over computer systems and data processing procedures and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy policies.
The brokerage destroys or erases any personal information when it is no longer needed. When information is destroyed or erased, the brokerage takes care that there is no unauthorized access.
In short, our people are committed, and our systems are designed, to protect your privacy and confidentiality.
Questions or Concerns
Questions or concerns about personal information held by the brokerage, or brokers compliance with the Brokerage Privacy Code, can be answered readily by the brokerage Privacy Officer who can be reached at (613) 226-1350 or 1-877-302-4657. However, should the privacy officer be unable to resolve your concerns you may contact the:
Federal Privacy Commissioner
112 Kent Street Ottawa,
Toll free: 1-800-282-1376
A Declaration of Client Privacy Rights: Putting The Client First
As professional brokers we at BINKS are committed to holding our client’s personal information in strict confidence, and we shall not disclose any such information unless authorized by our clients, required by law to do so, or required to do so in conducting negotiations with underwriters or insurers on behalf of the client. Our Privacy Code builds on this commitment.
Principle # 1: BINKS is Accountable
BINKS is accountable for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions. BINKS has established policies and procedures to comply with this declaration, and has designated a privacy officer to be accountable for compliance.
Principle # 2: BINKS will Identify Purposes
BINKS will identify the purposes for which it collects personal information, before or when the information is collected.
Principle # 3: BINKS and the Client’s Consent
BINKS will make a reasonable effort to make sure customers understand how their personal information will be used by the brokerage and insurers.
A customer’s consent can be expressed, implied, or given through an authorized representative. A customer can withdraw consent at any time, with certain exceptions by requesting us to do so in writing.
By purchasing insurance or financial services, the client is providing an implied consent to BINKS, to the collection, use, and disclosure of certain personal information.
Principle # 4: BINKS Limits the Collection of Personal Information
BINKS limits the amount and type of personal information it collects. Each broker will collect personal information for the purposes identified to the customer. BINKS collects personal information using policies and procedures that are fair and lawful.
Principle # 5: BINKS Limits the Use, Disclosure and Retention of Personal Information
BINKS will use or disclose personal information only for the reasons it was collected, unless a customer gives consent to use or disclose it for another reason, or it is permitted or required by law.
Under certain exceptional circumstances, BINKS may have a legal duty or right to disclose personal information without the customer’s knowledge or consent to protect the interests of insurers or the public interest.
BINKS will keep personal information only as long as necessary for the identified purposes for which it was collected.
Principle # 6: BINKS will keep Personal Information Accurate
BINKS will keep personal information as accurate, complete and current as necessary for the identified purposes for which it was collected.
Customers may, in writing, challenge the accuracy and completeness of their personal information and request that it be amended as appropriate.
Principle # 7: BINKS Safeguards Client Information
BINKS protects personal information with safeguards appropriate to the sensitivity of the information.
Principle # 8: BINKS makes its Information Policies Available to its Clients
BINKS is open about the policies and procedures it uses to manage personal information. Customers have access to information about these policies and procedures. The information will be made available in a manner that is generally easy to understand.
Principle # 9: BINKS makes Personal Information Accessible
When customers make a request in writing, BINKS will within a reasonable time tell them what personal information it has, what it is being used for, and to whom it has been disclosed.
When customers request it in writing, BINKS will give them access to their personal information. BINKS will respond to the written request in a timely fashion. In certain situations, however, BINKS may not be able to give customers access to all their personal information. BINKS will explain the reasons for this lack of access and any recourse the customer may have, except where prohibited by law.
Principle # 10: BINKS is Committed to Addressing Client Complaints and Concerns
Customers may challenge BINKS’s compliance with this declaration. BINKS has policies and procedures to receive, investigate, and respond to customer complaints and questions. Customers may learn about these polices and procedures by contacting the brokerage privacy officer at (613) 226-1350.