The Companies have strict policies and procedures for protecting personal information as well as designated individuals who are responsible for monitoring the Companies’ compliance.

The Companies have a Privacy Officer who oversees privacy governance, including this Privacy Policy and related policies, dispute resolution, education, and communications and reporting to senior management and the Board of Directors. The Privacy Officer can be contacted as follows:

Privacy Officer
Canadian Premier Life Insurance Company
Legacy General Insurance Company
80 Tiverton Court, 5th Floor
Markham, Ontario L3R 0G4
1-888-968-4155

2. Identifying Purpose

When an individual becomes a CPLIC or LGIC customer, or applies for additional products and services, the Companies request that particular individual to provide personal information for the following business purposes:

3. Consent

When an individual applies for a new product or service, the Companies request that particular individual for his/her consent to collect, use or disclose his/her personal information. Consent may be oral or written, express (e.g. providing personal information on an application form or during a telemarketing or inbound telephone call) or implied (e.g. not withdrawing consent to a certain use of personal information when given the opportunity to do so).

A customer may, at any time, withdraw his/her consent so long as they:

4. Limiting Collection

The Companies collect the information they require only for business related purposes. The Companies may request customers to provide the following personal information:

An individual may choose not to provide the Companies with certain information in some situations. However, if he/she make this choice, the Companies may not be able to provide him/her with the product, service or information that he/she request.

The Companies may monitor or record incoming or outgoing telephone calls with their customers in order to ensure mutual protection (e.g. to ensure instructions are carried out, to document that required disclosures have been made and to ensure that customer service call quality standards are maintained).

The Companies will make certain that customers are informed of the purposes listed above when they apply for any of the products or services offered by CPLIC and/or LGIC. If a new purpose for the use of personal customer information develops, the Companies will request consent accordingly.

5. Limiting Use, Disclosure and Retention

The Companies will only use personal information for the purpose(s) for which it was initially collected (i.e. assessing eligibility for insurance, administering insurance coverage, including investigating and assessing claims, and creating and maintaining records). The Companies do not sell or give lists of customers to other companies for their own use; however if CPLIC or LGIC obtain customer lists from other organizations, the Companies require the organizations to confirm their compliance with all relevant privacy legislation applicable to CPLIC and LGIC.

The Companies do not share personal information with any related or affiliated companies for marketing purposes without consent.

The Companies may use service providers to provide services on their behalf, including data processing and administration. These service providers will be given only the information needed to perform those services. CPLIC and LGIC have contracts in place with these service providers holding them to the same high standards of confidentiality by which CPLIC and LGIC are governed. In some cases, the service providers may be located outside of Canada and are subject to the laws of the jurisdiction in which they are located. More information about the Companies’ use of service providers located outside of Canada may be obtained by contacting the Companies’ Privacy Officer at 1-888-968-4155.

Personal information may be released to legal or regulatory authorities in cases of suspected money laundering, terrorist financing, criminal activity, detection or prevention of fraud or when required to satisfy legal or regulatory requirements (e.g. by court order). If the Companies release personal information for any of these reasons, the Companies will keep a record of what, when, why and to whom such information was released.

Pursuant to provincial and federal legislation, the Companies may also be required to notify provincial or federal Privacy Commissioners of any incident involving the loss of, or unauthorized access to, or disclosure of personal information.

CPLIC and LGIC have policies in place that govern the retention of personal information. Specifically, the Companies retain personal information as long as it fulfills its intended purpose or as legally required.

6. Accuracy

CPLIC and LGIC are committed to the accuracy of their customers’ personal information and ensuring that it is complete and up-to-date.

If a customer discovers inaccuracies in the Companies’ data, or unauthorized changes in their personal information, they should notify CPLIC and LGIC immediately in order to ensure that the changes are corrected. If the Companies do not agree to make the amendments that are requested, a customer may challenge the decision by contacting the Companies’ Privacy Officer.

7. Appropriate Safeguards

Customer personal information is secure when it is entrusted to CPLIC and LGIC, regardless of the format in which it is held. The Companies have comprehensive security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of personal information.

The Companies maintain physical, electronic and procedural safeguards to protect customer personal information, including restricted access to information processing and storage areas, limited access to relevant information by authorized employees only, use of passwords, firewalls and encryption of electronically transmitted information, the use of secure locks on filing cabinets and doors and the immediate retrieval of documents from the Companies’ printers.

CPLIC and LGIC have agreements and controls in place with third party service providers requiring that any information provided to them must be safeguarded and used only for the sole purpose of providing the services the Companies have requested from them.

8. Openness

CPLIC’s and LGIC’s Privacy Policy and any other policies and practices relating to the management of personal information are available to customers. From time to time, the Companies may make changes to the Privacy Policy. The most up-to-date Privacy Policy is available at www.canadianpermier.ca by accessing the privacy link located at the bottom of the page.

9. Access

If a customer would like to review or verify their personal information, or to whom it has been disclosed, they can submit a request to the Companies’ Privacy Officer. The Companies may require specific information from the customer in order to conduct a search for, and provide, the personal information to the requesting party.

There may be circumstances where CPLIC or LGIC may be unable to disclose certain personal information that has been collected with respect to a particular customer. If such a case arises, CPLIC and LGIC will provide the requesting party with supporting reasons for the refusal, as permitted by law.

10. Complaints

An individual may submit a complaint to the Companies’ Privacy Officer concerning compliance with the Privacy Policy. The Privacy Officer will fully investigate all complaints and will inform the complainant of the outcome of the investigation in a timely manner. If an individual wishes to pursue their privacy complaint further, he/she may contact:

Office of the Privacy Commissioner of Canada
Place de Ville, Tower B, 3rd Floor
112 Kent Street
Ottawa, Ontario K1A 1H3
Call: 1 800 282-1376
Fax: (613) 947-6850

If further details are required to clarify the Companies’ complaints policy, please refer to their Policy on Complaints.

CPLIC’s and LGIC’s Commitment

The Companies appreciate the opportunity to help customers with their insurance needs. Earning and keeping their trust is at the very core of their business. The Companies are committed to respecting and protecting the privacy and confidentiality of the personal information customers entrust to them. It is important customers understand what information the Companies collect, how the Companies use it and to whom it may be disclosed.