OUR COMMITMENT TO PRIVACY
SCOPE OF POLICY
This Policy applies to Auxilium Insurance Services about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. However, such information is protected by other Auxilium Insurance Services policies and practices and through contractual arrangements. This Policy does not impose any limits on the collection, use or disclosure of the following information by Auxilium Insurance Services: your business contact information, and publicly available information recognized under PIPA.
In this Policy:
“collection” means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement to the collection, use and disclosure of personal information for specified purposes. Consent may be express or implied. Express consent can be given orally or in writing, it is unequivocal and does not require any inference on the part of Auxilium Insurance Services. Implied consent exists when Auxilium Insurance Services can reasonably infer consent based upon your action or inaction.
“disclosure” means making personal information available to a third party.
“personal information” means information about an identifiable individual but does not include business contact information of an individual. Personal information does not include information that is about corporate or commercial entities. It also does not include information that cannot be associated with a specific individual.
“PIPA” means the British Columbia Personal Information Protection Act S.B.C. 2003, c.63.
“third party” means an individual or organization other than Auxilium Insurance Services and you.
“Privacy Officer” means an individual designated by Auxilium Insurance Services who is accountable for Auxilium Insurance Services compliance with this Policy and who can be contacted as set out at the end of this Policy.
“use” means the treatment and handling of personal information by and within Auxilium Insurance Services.
Auxilium Insurance Services is accountable and responsible for personal information under its control. Auxilium Insurance Services has designated a Privacy Officer who is accountable for Auxilium Insurance Services compliance with this Policy. Accountability for Auxilium Insurance Services compliance rests with the Auxilium Insurance Services Management who may delegate the day-to-day accountability to the Privacy Officer. Other individuals within Auxilium Insurance Services may be accountable for the day-to-day collection and processing of personal information or to act on behalf of the Privacy Officer. Auxilium Insurance Services will adopt procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding policies and procedures and communicate policies and procedures to you.
When collecting information, Auxilium Insurance Services will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection. Auxilium Insurance Services collects your personal information for the following reasons:
to provide and administer products and services requested and to use/disclose the information for any purpose related to the provision of requested products and services; to determine your financial situation including obtaining credit reports to provide information to third party suppliers of products and services, such as data service providers, etc.; to provide the information to credit bureaus and other financial institutions to update credit information; to protect Auxilium Insurance Services, yourself and others from fraud and error and to safeguard the financial interests of Auxilium Insurance Services; to authenticate your identity; to provide information to anyone working with or for Auxilium Insurance Services as needed for the provision of requested products and services; to collect debts owed to Auxilium Insurance Services; to manage or transfer assets or liabilities of Auxilium Insurance Services, such as in the case of acquisitions and mergers; and to comply with legal and regulatory requirements;
The above collections, uses and disclosures are a necessary part of your relationship with Auxilium Insurance Services.
Auxilium Insurance Services may use your personal information to offer their additional or alternative services to you and may add it to client lists which they prepare and use for this purpose; Auxilium Insurance Services may contact you for survey purposes.
You may instruct Auxilium Insurance Services to refrain from using or sharing information in the two ways described above at any time by providing written notification to the Auxilium Insurance Services Privacy Officer. Auxilium Insurance Services acknowledges that the sharing of information in the two ways described above is at your option and you will not be refused services merely because you advised Auxilium Insurance Services to stop using or sharing information in these ways. When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified prior to use and consent for same shall be obtained from you unless the use is authorized or required by PIPA or other law.
Auxilium Insurance Services will obtain your consent to collect, use or disclose personal information except where Auxilium Insurance Services is authorized or required by PIPA or other law to do so without consent. For example, Auxilium Insurance Services may collect, use or disclose personal information without your knowledge or consent where:
Auxilium Insurance Services is collecting or paying a debt; or Auxilium Insurance Services is obtaining legal advice; or Auxilium Insurance Services reasonably expects that obtaining consent would compromise an investigation or proceeding; or Auxilium Insurance Services is obtaining information under circumstances where a person is seriously ill or mentally incapacitated.
Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify Auxilium Insurance Services that you do not wish your personal information collected/used/disclosed for optional purposes following reasonable notice of same), action, or otherwise. For example, oral consent could be expressed over the telephone when information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application form. You may withdraw consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is given to Auxilium Insurance Services. On receipt of notice of withdrawal of consent, Auxilium Insurance Services will inform you of the likely consequences of the withdrawal of consent, which may include the inability of Auxilium Insurance Services to provide certain products or services for which that information is necessary.
4. LIMITS ON COLLECTION OF PERSONAL INFORMATION
Auxilium Insurance Services will limit collection of information to that which is reasonable and necessary to provide a product or service and which is reasonable and necessary for the purposes consented to by you. Auxilium Insurance Services will also collect information as authorized by PIPA or other law.
5. LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL INFORMATION
Your personal information will only be used or disclosed for the purposes set out above and as authorized by PIPA and other law. Auxilium Insurance Services will keep personal information used to make a decision affecting an individual for at least one year after using it to make the decision. Auxilium Insurance Services will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. Auxilium Insurance Services will take due care when destroying personal information so as to prevent unauthorized access to the information.
Auxilium Insurance Services will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. In some cases, Auxilium Insurance Services relies on you to ensure that certain information, such as your address or telephone number, is current, complete and accurate. If you demonstrate the inaccuracy or incompleteness of personal information, Auxilium Insurance Services will amend the information as required. If appropriate, Auxilium Insurance Services will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, Auxilium Insurance Services will annotate the personal information under its control with a note that the correction was requested but not made.
7. SAFEGUARDING PERSONAL INFORMATION
Auxilium Insurance Services protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Auxilium Insurance Services will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to you. Some specific safeguards include:
physical measures such as locked filing cabinets; organizational measures such as restricting employee access to files and databases as appropriate; electronic measures such as passwords and firewalls; regular reviews of processes in place to safeguard personal information; and investigative measures where Auxilium Insurance Services has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Auxilium Insurance Services will not be responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when you transmit information to Auxilium Insurance Services by e-mail or other wireless communication or when Auxilium Insurance Services transmits such information by such means at your request.
Auxilium Insurance Services is open about the policies and procedures it uses to protect your personal information. Information about these policies and procedures will be made available in writing and electronically. However, to ensure the integrity of our security procedures and business methods, Auxilium Insurance Services will not disclose sensitive information about its policies and procedures. Auxilium Insurance Services will make available a description of the type of personal information held by Auxilium Insurance Services, and a general description of its use and disclosure.
9. PROVIDING ACCESS
You have a right to access your personal information held by Auxilium Insurance Services. Your information, such as copies of statements, transaction slips and account agreements will be provided upon request and authentication of identity. Upon written request and authentication of identity, Auxilium Insurance Services will provide you with your other personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. Auxilium Insurance Services may charge a reasonable fee for providing information in response to a PIPA access request and will provide an estimate of any such fee upon receiving an access to information request. Auxilium Insurance Services may require a deposit for all or part of the fee. Auxilium Insurance Services will make the information available within 30 days or provide written notice where additional time is required to fulfill the request. In some situations, Auxilium Insurance Services may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm the competitive position of Auxilium Insurance Services. Auxilium Insurance Services may also be prevented by law from providing access to certain personal information. Where an access request is refused, Auxilium Insurance Services will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
Auxilium Insurance Services will, on request, provide information regarding its complaint procedures. Any inquiries, complaints or questions regarding this Policy should be directed in writing to the Auxilium Insurance Services Privacy Officer. Auxilium Insurance Services will give appropriate notice of any amendments to this Policy.
Privacy Officer, Auxilium Insurance Services, Administration Office
307 Goldstream Avenue, Victoria, BC V9B 2W4