This policy is amended from time to time. The most current version of this policy was updated January 5th 2022. For more information, you can make a request to the Privacy Office at firstname.lastname@example.org
At Co-operators, we recognize and respect the importance of privacy. When you do business with us, we will ask you for your consent to collect, use and disclose your personal information. We will explain what personal information we need, what we will use and disclose it for, and who we will share it with. We will not share your personal information except with your consent or as required or permitted by law.
You can withdraw your consent at any time. You may access and correct, if needed, the personal information we have about you by sending us a request in writing at email@example.com or the mailing address below.
We limit access to your personal information to our employees and other authorized personnel who need to use it to perform their duties. This may include third-party service providers, including those that are located outside of Canada. To protect your personal information, we ensure that appropriate privacy and security requirements are included in our contracts with our third-party service providers, as well as review their compliance with those requirements.
With your permission, we may tell you about products and services that may be of interest to you. You can tell us what information you want to receive from us, and you can change your preferences at any time.
For more details about Co-operators privacy practices, please refer to the information below.
We have built client relationships based on a foundation of trust. We are committed to protecting the privacy, confidentiality, accuracy, and security of the personal information collected, used, retained, and disclosed while doing business with you. We are responsible for all personal information under our control, whether supplied to us directly by you or by a third party or that we have provided to our third-party service providers for processing. We take our privacy obligations seriously and strive to implement privacy practices guided by the highest standards of ethical conduct.
We do not sell your personal information.
We will obtain your consent prior to collecting, using, retaining, or disclosing your personal information for specific purposes, except where we are specifically permitted by law to collect, use, retain or disclose your personal information without your consent such as when we are required by law to disclose your personal information to a government institution. If we wish to collect, use, retain or disclose your personal information for a new purpose, we will seek your consent before doing so.
Your consent can be implied or express. Implied consent refers to consent that is inferred from your actions, for example, when you provide personal information to us to obtain an insurance quote, in which case we would infer that you are consenting to our collection and use of the personal information you provide to produce a quote. Express consent is consent that is given specifically, either verbally or in writing. When we ask for your express consent, we will explain what personal information we need, what we will use and disclose it for, and who we will share it with.
You may withdraw your consent at any time, and, subject to any applicable legal or contractual restrictions which we must fulfill, we will cease to collect, use and disclose your personal information after the withdrawal of your consent. If you withdraw your consent, or do not provide us with all necessary personal information, we will still do our best to provide you with our products or services; however, it may not be possible for us to do so.
Personal information we may collect
We only collect personal information that we need for the specific purposes described in the consent provided by you.
Depending on the type of products or services we provide to you, we may collect personal information including:
- name, contact information
- demographic information (age, gender, family and marital status, income, education, and employment)
- driving records and history
- previous insurance and claims history
- medical and health information
- financial and payment information, including credit card and bank account numbers
- identification numbers (e.g., driver’s license number)
- Social Insurance Number (SIN) for tax reporting purposes, or other Canada Revenue Agency reporting, as well as verification of non-permanent Canadian residency
- financial and insurance needs
- information about your assets (home inventory, cars), investments, debts, expenses
- personal information publicly available from external sources as permitted by applicable laws
- credit information (including credit score and other information contained in your credit file) obtained from credit reporting agencies
- information contained in legal documents (death certificates, court orders, powers of attorney etc.)
- information related to a specific claim or investigation (including information contained in police reports, officer notes, photographs, videos, voice recordings, investigation reports, and mobile phone records)
- your marketing preferences
Purposes for which we may collect, use, or disclose your personal information
The following are some of the purposes for which we may, with your prior consent, collect, use, or disclose your personal information:
- To conduct a needs analysis, including:
- determining and evaluating your insurance coverage or investment needs
- conducting financial planning
- determining the suitability of and recommend insurance and investment products and services tailored for you
- To provide a quote, including:
- evaluating your insurability and determining premiums for insurance products you are interested in
- detecting, investigating, suppressing, and preventing fraud
- To evaluate your insurability, process your application and issue a policy, including:
- confirming your identity
- verifying the information you disclose (for example verifying your address or your phone number, and your driving records, where applicable, by accessing your provincial Motor Vehicle Report (MVR))
- detecting, investigating, suppressing, and preventing errors and omissions and/or fraud (for example for online purchases we may verify the location you are transacting from, the unique identity of the device you are using or the email address). Where permitted by law, we may obtain and share information with other organizations for these purposes.
- obtaining access to historical insurance policy and claim details through property and casualty industry databases
- performing medical and lifestyle assessments
- in some circumstances, obtaining a consumer report
- processing your application
- in some instances, determining if we need to place your coverage with another insurer or a reinsurer
- issuing your policy
- billing and processing payments, including debt collections and setting-up pre-authorized payments if you choose to do so
- To administer your insurance policy, including:
- processing policy changes, renewals and terminations
- validating who you are
- communicating with you regarding products and services you have with us
- recording and monitoring calls to ensure quality customer service, dispute resolution or training development of staff
- issuing surveys
- confirming your registration for our Online Services (OLS) secure site
- evaluating your insurability at your insurance policy renewal
- in some instances, placing your coverage with another insurer or reinsurer
- disclosing policy information to leaseholders, lienholders, mortgagees, and other persons with an insurable interest, employers and plan administrators in the context of group policies
- periodically reviewing your insurance needs and determining the suitability of our products and services for you
- performing monitoring and audit activities
- To assess and process claims, including:
- verifying client information and validating claim information provided
- reviewing previous claims, if applicable
- assessing eligibility for benefits payments
- assessing damage or injury and determining benefits
- obtaining compensation or contribution from third parties
- settling any disputes with third parties
- facilitating claim adjustment activities with the collaboration of third parties as required (e.g., property repairs, rehabilitation)
- detecting, investigating, and preventing errors and omissions
- detecting, investigating, suppressing and preventing fraud or illegal activities, including by pursuing criminal or civil actions. Claim information may be pooled with information from other sources and may be subject to analysis for the limited purposes of preventing and investigating. For this purpose, the information may be disclosed to fraud prevention organizations, other insurance companies, and the police, and databases or registers used by the insurance industry to analyze and check information provided against existing information.
- making claim payments
- coordinating payments
- To comply with regulatory obligations set out in applicable federal and provincial laws
- To conduct business analysis and data analytics, including:
- using your personal information in conjunction with advanced analytics and artificial intelligence techniques to perform business analysis and data analytics (for example to enable us to automate underwriting decisions to simplify and accelerate your insurance purchasing experience, or to enable us to detect patterns of fraud to reduce its impact and, ultimately, lower premiums)
- To offer you other products and services, and to invite you to participate in our contests and promotions, including:
- providing you with information regarding additional insurance-related and other financial products, services, or offers (including personalized information regarding our additional or enhanced insurance and financial services products or multi-product discounts)
- contacting you by various means (telephone, electronically, or by regular mail) regarding other products and services we offer, and contests and community events which you may be interested in
- conducting market research and surveys
- To test and troubleshoot our internal systems, and assess and enhance our security safeguards, business planning, and management, including assessing resource needs
Those we may disclose personal information to
We may disclose your personal information to others where necessary and appropriate, but only if we need to for the purposes that you have consented to. We may disclose your personal information to the following:
- third parties who provide services to us or perform services on our behalf, including payment processor, marketing communication agencies, external law firms, auditors, data processors, storage, analysis and disaster recovery services
- our independent financial advisors and their staff
- third parties that we need to provide you with the product or service you have requested from us, such as provincial driving and motor vehicle licensing authorities, property valuators, private investigating firms, physiotherapists, and occupational therapists etc.
- medical professionals, pharmacies and any other medical services providers, benefit providers and administrators, financial institutions
- other insurers and reinsurers
- credit reporting agencies
- operators of insurance industry databases (for example to analyze and verify information you have provided, such as previous policies and claims, against information contained in insurance industry databases)
- fraud detection & prevention organizations (including Équité Association)
- insurance eligibility and risk assessment organizations (for example MIB Inc.)
- other companies within the Co-operators group of companies
- parties involved in the sale, acquisition, disposition, merger, or amalgamation of companies or as part of other business arrangements, such as joint ventures
- government agencies, as required by law (for example for periodic regulatory filing, reporting in accordance with anti-money laundering or unclaimed property requirements or under other lawful authorities, and for income tax purposes)
- external auditors, legal counsel and other professionals
- any other parties you authorize
You have a choice
We want you to know that you can always:
- decline to provide us with some of your personal information. If you do not provide us with all necessary personal information, we will still do our best to provide you with our products or services, however it may not be possible to do so.
- withdraw your consent at any time by contacting us, and, subject to any applicable legal or contractual restrictions which we must fulfill, we will cease to collect, use, retain and disclose your personal information after the withdrawal of your consent. If you withdraw your consent, or do not provide us with all necessary personal information, we will still do our best to provide you with our products or services, however it may not be possible to do so.
- update your marketing permissions and contact preferences at any time by logging on to Online Services or by contacting us
- access your personal information and request updates or changes to it (if inaccurate) by contacting us
Credit information we may obtain and exchange with credit reporting agencies
Where applicable and permitted by law, we may ask for your consent to collect, use and disclose your credit file information (including your credit score). This is a common practice in the Canadian insurance industry. To access your credit file information from credit reporting agencies, we will need to share limited personal information with them to identify you, such as your name, address and date of birth.
At Co-operators, we may use your credit score to automatically generate a Co-operators credit band rating factor which is then used by our business areas as one of the risk factors involved in the assessment of risk of insurability associated with your application or policy. Typical items from a credit report that could affect a credit score include, but are not limited to, payment history, number of loans and credit cards, age of loans and credit cards, the presence of accounts that have been referred to collection agencies, and the presence of bankruptcies and foreclosures. For detailed information about which credit reporting agency we access, please contact us.
This risk assessment allows us to:
- accurately determine the appropriate premium for the policy you have applied for
- determine your eligibility for automatic payment plans
- analyze and cede risks to our reinsurers, as needed
Our credit inquiries do not impact your credit score and your credit report will generally identify which companies have requested your credit file information.
We may also use your credit file information to confirm your identity and verify information about you, such as your current address, to detect fraud and misrepresentation.
We may retrieve your credit file information from time to time as needed to update our files. You can revoke your consent at any time by contacting us in writing.
Only those of our employees and other authorized personnel with a need to know may have access to your credit file information. Our independent financial advisors and their staff, and our licensed insurance representatives do not have access to your credit file information. For general information on this topic click this link Credit report and score basics by the Government of Canada.
Retention of Information
We retain personal information only as long as is necessary to fulfill the purposes for which it was collected, unless authorized or obligated by applicable laws to retain personal information for a longer period.
All our employees and financial representatives must annually abide by our Code of Ethics/Code of Conduct. In addition, we have developed and implemented privacy guidelines and practices which are reviewed, monitored and audited periodically.
To mitigate and manage our exposure to information security risks, our organization has implemented a security risk management program with both governance and operational components, including training and awareness at all levels, secure password protection, standard security practices and tools, and internal policies and practices such as limiting access on a need-to-know basis based on the consent you provided. Our internal technology governance has been designed to meet both regulatory requirements and industry best practices. Our program is also designed to protect systems with consideration of confidentiality, integrity, and availability of information. Key activities include monitoring our systems for events to detect and prevent system intrusions, as well as conducting scans of the internal and external environments to identify and remediate vulnerabilities. Along with an extensive business continuity management program, we continually assess our security program to ensure we are well-positioned to meet the needs of our business and clients.
We make every effort to ensure that the personal information we collect is accurate, complete, and as up to date as possible to properly satisfy the purposes for which it is to be used. It is important that you promptly notify us of any change to your contact information. If we are unable to verify your personal information or contact you, we may be limited in our ability to provide you with our products and services.
Access to Personal Information
Upon written request, and confirmation of your identity, we will provide you with a copy of, or give you access to, the personal information about you that we have obtained while doing business with you. However, there may be instances where we may, in accordance with applicable privacy laws, restrict access to your personal information, including where such information is subject to legal privilege, has previously been disclosed to law enforcement, contains confidential commercial information, or relates to other individuals. If applicable, we will advise of the reasons for restricting access and inform you of any recourse that you may have. A response to your request will be provided within 30 days after we receive a written request, and we have sufficient information to permit us to identify the existence of the personal information. In Alberta, a response will be provided within 45 days after receipt of a written request, and sufficient information to permit us to identify the existence of the personal information. Where permitted by applicable law, if we need more time to fulfill your request, we will notify you of such delay. There may be instances where medical information obtained about you from a third party can only be released to you through a physician.
If you believe that the information in our files is inaccurate or incomplete, you have the right to ask us to correct it. We will review your request and, if we agree, will promptly make the necessary corrections.
To request access to or rectify your information contained in our file, contact our privacy office.
- Improve our website performance and functionality
- Create a better experience for our visitors (for example, by storing your preferences and settings locally on your device, and allowing you to sign in faster)
- Measure the response to marketing campaigns (for example, by tracking which emails you opened, and which links you clicked, and tracking your visits to our websites, all of which enables us to create an engaging and personalized marketing experience for you)
- Offer you products and services that meet your needs
- Combat fraud
We use Google reCaptcha v3 to secure our website and to help prevent fraud. We have also enabled Google Analytics (which includes the following features: Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting). Google Analytics captures metrics related to the usage of our websites. These metrics may include how many times a link or an area on a website is clicked, the number of new and repeat visitors, where on the website a visitor explores, how long they visit and where they are geographically located. We may also share site visit information obtained using cookies, web beacons and other similar technologies with Google Analytics or other agents (for example marketing agencies) to analyze online activity on our websites or in reaction to our online advertisements.
You are in control
You have a variety of tools to control cookies, web beacons, web analytics tools and similar technologies, including browser controls to block and delete cookies, and controls provided by some third-party analytics service providers that allow you to opt out of data collection through web beacons:
- Each browser allows you to set your cookie preferences. Check the "Help" menu of your browser to learn how to update your cookie preferences. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of the website may not function fully.
- You can opt out of Google Analytics for Display Advertising and customize Google Display Network ads, by changing your Ads Settings. To view the currently available opt-outs for the web, please visit Google Analytics Opt-out Browser Add-on.
Register a privacy concern
Our goal is to help you meet your needs and provide the best service we possibly can. If you ever have a privacy-related concern, do not hesitate to contact us to discuss it. We take your privacy concerns seriously and we will investigate all privacy-related complaints, and where necessary we will take appropriate measures to address your complaint. Should you remain unsatisfied with our complaint process, we will inform you of what other complaint procedures are available to you.
Co-operators Privacy Office
130 Macdonell Street, Guelph, ON, N1H 6P8