Privacy Policy

Nova Mutual Insurance Company

Protecting the confidentiality of your personal information has always been an important part of the way we do business. To ensure that we protect your privacy, Nova Mutual Insurance Company has adopted the Insurance Bureau of Canada Model Personal Information Code. This Code sets out how and why we collect and use personal information about our policyholders. It also explains limited circumstances under which we may need or be required to disclose it.

“Personal information” means information that identifies you as a specific individual. It may include an individual’s date of birth, family status, marital status, occupation, medical and health records, assets, liabilities, income, credit and payment records of the individual, an individual’s previous insurance experience including claims history, and an individual’s driving record. It does not include the sort of general information that could be found in a business directory or a telephone book.

Effective January 1, 2004, the Government of Canada implemented the last phase of the Personal Information Protection and Electronic Documents Act (PIPEDA). This federal statute applies to insurance companies and to many other industry sectors.

This legislation establishes rules and principles for the use and disclosure of personal information based on the ten privacy principles developed by the Canadian Standards Association. These principles recognize that we live in an era when commercial information is exchanged and circulated by electronic means. It balances the individual’s right to privacy in their personal information with the reasonable need of organizations to collect, use or disclose personal information.

Under the new legislation, an organization may collect, use or disclose personal information only for limited purposes that a reasonable person would consider to be appropriate in the circumstances.

PIPEDA requires us to provide the same safeguards for your privacy that we have always provided on a voluntary basis. Our Privacy Code sets out these principles in simple terms. It explains how we ensure that your privacy and the confidentiality of your personal information are protected.

Our Privacy Code

Nova Mutual Insurance Company’s Privacy Code is based on the following ten principles set out in PIPEDA.

Principle #1: Our Accountability for the Collection, Use or Disclosure of Personal Information

As a policyholder or customer of Nova Mutual Insurance Company, you have a right to expect that your insurer is accountable for the personal information it collects and uses. “Policyholders” and “customers” mean our current and former insured’s, applicants for insurance and claimants under one of our policies.

We are responsible for maintaining and protecting your personal information while it is under our control. This includes any personal information that may need to be disclosed to third parties for processing or other administrative functions.

To help ensure the confidentiality of your personal information, we have established policies and procedures to ensure that we comply with PIPEDA. We have designated a Privacy Officer who is responsible for our company’s compliance with the ten privacy principles by the Canadian Standards Association.

If you have any questions or inquiries about how your personal information is stored, or when it may need to be disclosed to others, our privacy officer is there to assist and explain our policies to you.

Principle #2: Identifying Our Purpose for the Collection, Use or Disclosure of Personal Information

Before, or when, we collect information about you; we will explain how we intend to use it. Nova Mutual Insurance Company collects personal information only for the following purposes:

to provide ongoing customer service to our policyholders;
to help us understand our customers’ needs better;
to develop, enhance, market or provide insurance products and services;
to enable us to underwrite your policy of insurance and set a fair premium;
to provide us with the information that we need to adjust a claim in a fair and expeditious way;
to meet our legal and regulatory requirements under the Insurance Act and other statutes.

Unless we are required by law, Nova Mutual Insurance Company will not use or disclose any personal information that has been collected without documenting the new purpose and obtaining your consent. If you have any questions about these purposes, our Privacy Officer will be pleased to explain them to you.

Principle #3: Obtaining Your Consent for the Collection, Use or Disclosure of Personal Information

Nova Mutual Insurance Company will make a reasonable effort to make sure that our policyholders understand and consent to how their personal information will be ‘used by the Company. By providing this information to us, we assume your consent to use this information in an appropriate manner.

We will obtain your consent if we need to use your information for any other purpose and before collecting information from third parties such as other insurers and insurance service companies.

In certain circumstances, however, personal information may need to be collected, used or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent.

PIPEDA recognizes that when information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of an individual may defeat the purpose of collecting the information. Seeking consent may also be impossible or inappropriate when the individual is a minor, seriously ill, or mentally incapacitated.

In obtaining your consent, we will always use reasonable efforts to ensure that you are advised of the identified purposes for which any personal information collected will be used or disclosed. If you renew your insurance policy with our company, then you will be re-confirming your permission allowing Nova Mutual Insurance Company to collect, use and disclose your personal information in accordance with the principles detailed in this privacy code notice.

Who Can Give Consent

Consent may be given by the individual or by an authorized representative (such as a person having power of attorney, or a legal guardian). Nova Mutual will verify authorization by requesting identification of the representative, the reason for representation, and if applicable, the approval of representation by the applicable individual.

Withdrawing Your Consent

Subject to certain Legal and contractual restrictions and reasonable notice, you may refuse or withdraw consent to the collection, use or disclosure of Personal Information at any time by notifying our Privacy Officer in writing. In addition, you may also opt out of certain communications we may send you regarding other products and services. However, you should be aware that withdrawing your consent may affect our ability to respond to your insurance needs.

Principle #4: Limiting Our Collection of Personal Information

We will always Limit the collection of personal information to that which is necessary for the identified purposes. Typically, this is information that is required to enable us to underwrite your policy of insurance and charge a fair premium. We may need to collect personal information from other sources including credit bureaus.

Under certain circumstances we need to collect information to assist us in adjusting or investigating a claim. This may involve the use of licensed and regulated independent insurance adjusters or investigators. We will always collect personal information by fair and lawful means.

Principle #5: Limiting the Use, Disclosure and Retention of Personal Information

Personal information will not be used or disclosed for purposes other than for which it was collected, except with your consent or as permitted or required by law. Your personal information will be retained only as long as it is necessary to fulfill those purposes.

Nova Mutual Insurance Company may disclose a customer’s personal information to the following organizations:

Another insurance company for the reasonable provision of insurance services. This may include another insurance company that is subscribing to the risk insured under our policy;
Another person or corporation as part of conducting business. This may include a reinsurance company, subject to that corporation agreeing to manage personal information in accordance with these privacy principles;
A person or corporation that is involved in supplying us with claims support services. This may include a licensed independent insurance claims adjuster or investigator, or a fire or forensic expert or engineer;
A medical or rehabilitation specialist or assessment clinic that is providing an opinion to us pursuant to our rights and obligations under the Insurance Act;
A company or an individual employed by Nova Mutual Insurance Company to perform data processing, accounting, actuarial or statistical functions on our behalf;
A person or corporation involved in the development, enhancement, marketing or provision of

our insurance products and services. This may include an insurance broker or agent;

An agent used by the Nova Mutual Insurance Company to evaluate your creditworthiness or

to collect an outstanding account. This may include credit grantors and reporting agencies;

A public authority or agent of a public authority, if the information is required to comply with a provincial or federal statute or regulation;
A Law enforcement agency, where our policyholder consents to such disclosure or disclosure is required by law or emergency.

Nova Mutual Insurance Company does not provide or sell its customer lists to any outside company for use in marketing or solicitation. Only employees with a business “need to know”, or those whose duties require it, are granted access to personal information about our policyholders.

We keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Personal information that is no Longer necessary or relevant for the identified purposes or required to be retained by law is destroyed, erased or made anonymous.

Principle #6: Keeping Your Personal Information Accurate

Nova Mutual Insurance Company makes every effort to ensure that personal information about its policyholders is as accurate, complete, and up-to-date as is necessary for the purposes for which it was collected.

This may require contact with your insurance broker to confirm or update personal information required for underwriting purposes. In addition, the Insurance Act and the terms and conditions of your policy of insurance may require you to notify us of material changes to your personal information.

If you have any questions about the accuracy and completeness of the personal information that we have collected or retained, please do not hesitate to contact our Privacy Officer. If you need to update some aspect of your personal information, please contact your insurance broker or agent directly.

Principle #7: Safeguarding Your Personal Information

Nova Mutual Insurance Company takes steps to protect personal information with security safeguards appropriate to the sensitivity of the information. We protect your personal information regardless of the format in which it is held.

Specifically, we have stringent security measures in place to protect personal information against such risks as loss or theft, computer hackers, unauthorized access, disclosure, copying, use, modification or destruction.

All our employees with access to personal information are required as a condition of their employment to respect the confidentiality of personal information.

More sensitive information will be safeguarded by a higher level of protection.

In determining what safeguards are appropriate, we will consider the following factors:

The sensitivity of the information;
The amount of information held;
The parties to whom information will be disclosed;
The format in which the information is held; and
The way in which the information is physically stored.

When transferring insured/claimant information to a third party, we will remove or mask any information that is not reasonably needed by the third party.

Our methods of protection include:

Physical measures, such as storing policies on an electronic filing system, or in locked filing cabinets/vault and restricted access;
Organizational measures, such as limiting access on a “need-to-know” basis; and
Technological measures, such as the use of passwords and encryption.
Hard copy files removed from our offices will, during transport be kept in briefcases or similar. If left unattended during travel, they will be locked in vehicle trunks or a locked hotel room.
Computer files accessed from a home or remove computer system will not be copied or kept on such home or remote system. Temporary copies of files will be erased.
Passwords and log in information will be kept secure and not disclosed to any person. (Note: authorized IT personnel have access to the system and will never ask you to divulge passwords or log in information).

We will ensure that our policies and procedures on safeguarding personal information are clearly communicated and accessible to our employees by:

Training staff on the subject of personal information protection; and
Having regular staff meetings in which we will review our procedures and revise where appropriate.

We will take precautions in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information. These measures include:

Ensuring that no one may retrieve personal information after it has been disposed of;
Shredding documents before recycling them; and
Deleting electronically stored information.

Principle #8: Openness Concerning our Privacy Practices

Nova Mutual Insurance company pursues a policy of openness about the procedures it uses to manage personal information. We will make specific information about our policies and practices relating to the management of their personal information available to policyholders upon request.

We ensure openness by providing you with the following information:

the title and address of the Privacy Officer accountable for our compliance with the policy; • the name of the individual to whom inquiries or complaints can be forwarded;
the means of gaining access to personal information held by our company; and
a description of the type of personal information held by Nova Mutual Insurance Company,

including a general account of its use.

Nova Mutual Insurance Company makes information available to help our policyholders exercise informed choices regarding the use of their personal information.

Principle #9: Policyholder Access to personal Information

Nova Mutual Insurance Company informs its policyholders of the existence, use, and disclosure of their personal information upon request and provides access to that information. Our customers are able to challenge or correct the accuracy and completeness of their personal information and have it amended when appropriate.

When a request is made in writing, we will inform you in a timely fashion, of the existence, use, and disclosure of your personal information and you will be given access to that information. In order to safeguard your personal information, we may require you to provide sufficient identification information to permit us to authorize access to your file.

In certain exceptional situations, we may not be able to provide you with access to all of the personal information we hold. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that is subject to solicitor-client or litigation privilege, or, in certain circumstances, information of a medical nature. If this is the case, Nova Mutual Insurance Company will provide the reasons for denying access upon request.

Policyholders can obtain information or seek access to their individual files by contacting our designated Privacy Officer at the address described below.

Principle #10: Challenging Compliance

A policyholder has the right to challenge Nova Mutual Insurance Company’s compliance with the above principles by contacting the Privacy Officer accountable for our compliance with the policy.

Nova Mutual Insurance Company maintains strict procedures for addressing and responding to all inquiries or complaints from its customers about its handling of personal information. We inform our customers about our privacy practices as well as availability of complaint procedures, if necessary.

Our Privacy Officer will investigate all complaints concerning compliance with the privacy policy. If a complaint is found to be justified, we will take appropriate measures to resolve the complaint including the amendment of our policies and procedures.

In exceptional circumstances, the Privacy Officer accountable for compliance with our privacy policy may seek external legal advice where appropriate before providing a final response to individual complaints.

For more information, please contact our privacy officer directly: Toll-free number: 1-833-829-6682.

Email: privacy.officer@Novamutual.com

Mail: Nova Mutual Insurance Company

35 Talbot Street East, Jarvis, ON N0A 1J0

ATTENTION: Privacy Officer