Privacy Guidelines, Silvercrest Insurance Group INTERNET PRIVACY POLICY

It is the policy of Silvercrest Insurance Group. that personal information, such as your name, postal and e-mail address or telephone number is private and confidential. Because your privacy is important to us, Silvercrest Insurance Group. maintains an Internet privacy policy to protect your personal information on all are web sites. Personal information, such as your name, postal and e-mail address or telephone number is collected only when you voluntarily provide it. Such information is received by Silvercrest Insurance Group. Only when you send an e-mail through the site or make some other specific contact such as a response to an on-line item on this site. The personal information you provide to Silvercrest Insurance Group. is forwarded only to the person or business that is equipped to handle your request and is used only to respond to your inquiry.

Restriction On Use Of Information

Personal information will not be sold to any third parties, nor will such information be added to bulk e-mailing lists.

Silvercrest Insurance Group. Privacy Guidelines incorporate the provisions of Part 1 of the Personal Information and Electronic Documents Act (PIPEDA) and the ten principles of the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information.

 Application of Privacy Principles:

1.      ACCOUNTABILITY: 

•         Silvercrest Insurance Group. has appointed a Privacy Officer(s) who is accountable for ensuring compliance with Silvercrest Insurance Group. Privacy Policy and Guidelines.  Accountability rests with the Privacy Officer even though other individuals within Silvercrest Insurance Group. may take responsibility for the day-to-day collection and processing of personal information.

•         Silvercrest Insurance Group. will use contracts or other means to provide an appropriate level of protection when a third party processes information on behalf of the association.

•         Silvercrest Insurance Group. will, from time to time, establish procedures to implement its commitment to privacy, including:

•          Procedures to protect personal information

•          Procedures to receive and respond to complaints and inquiries

•          Communications and training programs to provide information to it's staff about privacy policies and practices.

2.      IDENTIFYING PURPOSES: 

•          Silvercrest Insurance Group. identifies the purposes for which personal information is collected at or before the time the information is collected, and documents those purposes.

•          Silvercrest Insurance Group. collects only that information necessary for the purposes that have been identified.

•          Silvercrest Insurance Group. specifies (verbally, electronically or in writing) and explains the identified purposes(s) to the individual at or before the personal information is collected.

•          When personal information is collected for a purpose not previously identified, the new purpose is communicated to the individual prior to use.  In such case, the consent of the individual is required before the information is re-used.

•          Silvercrest Insurance Group. collects personal information from individuals in order to:

•          Screen individuals for employment, volunteer or contracting suitability

•          Manage and administer personnel (including performance appraisal, security and access control and discipline)

•          Manage and administer compensation and benefits programs

•          Administer payroll

•          Administer occupational health and safety programs

•          Monitor and track skills and competency development

•          Meet legal and regulatory requirements (e.g. Employment Standards legislation, casino volunteer registration under provincial gaming laws, Canada Customs and Revenue Agency reporting requirements)

•       Provide Insurance Quotes/Rates

•       Provide Insurance Services, Policies and Products.

3.      CONSENT:

•          Silvercrest Insurance Group. uses reasonable efforts to ensure that individuals understand how their personal information will be used.  Silvercrest Insurance Group. obtains consent as required for the collection, use and disclosure of personal information, except where inappropriate.

•          When determining the form of consent, Silvercrest Insurance Group. considers the sensitivity of the information and the reasonable expectations of the individual.  Express consent will be obtained when the information is likely to be considered sensitive; implied consent may be appropriate when information is less sensitive.  Consent may also be given through an individual’s authorized representative (such as a legal guardian or a person having power of attorney).

•          Silvercrest Insurance Group. obtains consent for the collection, use or disclosure of information through various means, including verbal, written (e.g. signed forms) or electronic processes.

•          In rare circumstances, Silvercrest Insurance Group. may collect and use personal information without the individual’s knowledge or consent. For example:

•          If it is clearly in the interests of the individual and consent cannot be obtained in a timely way (e.g. when the individual is seriously ill)

•          If obtaining prior consent would defeat the purpose of collecting the information (e.g. in the investigation of alleged criminal activity)

•          In the case of an emergency where the life, health or security of the individual is threatened.

•          Silvercrest Insurance Group. generally seeks to obtain consent at the same time personal information is collected.  Silvercrest Insurance Group. may, however, seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose (e.g. before disclosing board member information to a funding organization if this purpose was not previously contemplated).

•          Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Silvercrest Insurance Group. and/or the Privacy Officer informs individuals of the implications for withdrawing consent

4.      LIMITING COLLECTION:

•          Silvercrest Insurance Group. limits the amount and type of personal information collected to that which is necessary for the identified purpose.

•          Silvercrest Insurance Group. collects information by fair and lawful means.

•          Silvercrest Insurance Group. may collect the following information from employees and contractors:

§         demographic and contact information including home address and telephone number, date of birth, social insurance number and gender

§         education and employment history

§         banking or financial information

§         health information

§         security background checks, as required.

•          Silvercrest Insurance Group. may collect the following personal information from board members and other volunteers:

§         demographic and contact information including home address and telephone number, business name, address and telephone number

§         education and employment history

§         areas of interest and expertise

§        

•          Silvercrest Insurance Group. may collect personal information through the following means:

§         solicited and unsolicited resumes and correspondence

§         completed application forms (paper or on-line format) for employment, benefits, quotes, etc.

§         in person and through telephone interviews

§         on-line forms through the websites.

5.  LIMITING USE, DISCLOSURE AND RETENTION

•          Silvercrest Insurance Group. does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

•          Notwithstanding the above, Silvercrest Insurance Group. may disclose personal information without consent:

•          to a lawyer representing the CA

•          to a company or individual employed by Silvercrest Insurance Group. to perform functions on its behalf (e.g. outsourced information processing function, administration of health services plan)

•          in order to collect a debt owed by the individual to Silvercrest Insurance Group.

•          to comply with a subpoena, warrant, or court order

•          as required or authorized by law (e.g. Employment Standards legislation)

•          when the information is publicly available (e.g. telephone directory information)

•          to a public authority in the event of imminent danger to any individual.

•          Silvercrest Insurance Group. obtains consent for all other disclosures of personal information for purposes other than those for which the information was initially collected (e.g. to provide references regarding current or former employees. Silvercrest Insurance Group. does not require consent to confirm an individual’s employment record (e.g. confirm years of employment, and position held)).

•          Silvercrest Insurance Group. has developed guidelines and implemented procedures with respect to the retention of personal information.  Silvercrest Insurance Group. retains personal information only as long as it is necessary for the identified purpose, or as required by law.  Where personal information is used to make a decision about an individual, Silvercrest Insurance Group. retains the information, or the rationale for making the decision, long enough to allow the individual access to the information after the decision has been made.

•          Personal information that is no longer required to fulfil the identified purposes or required by law to be retained is destroyed, erased or made anonymous.

6.  ACCURACY

•          Silvercrest Insurance Group. ensures that personal information collected, used and disclosed is as accurate, complete and up-to-date as necessary for the intended purpose.

•          Personal information is kept sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the subject individual.

•          Silvercrest Insurance Group. updates personal information as and when necessary to fulfill the identified purpose or upon notification by the individual who is the subject of the information.

7.  SAFEGUARDS

•          Silvercrest Insurance Group. protects personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, regardless of the format in which it is held.

•          Silvercrest Insurance Group. has developed and implemented information security policies and procedures that outline physical, organizational, and technological measures in place to protect personal information as appropriate to the sensitivity of the information.

•          Silvercrest Insurance Group. protects personal information disclosed to, or processed by third parties by contractual agreements which address the following as necessary:

•          identifying the types of records provided, collected, created, or maintained in order to deliver the service, and specifying any applicable privacy legislation;

•          stipulating the confidentiality of the information and the purposes for which it is to be used (requiring the third party provides at least the same level of protection that Silvercrest Insurance Group. does);

•          identifying the organization(s) having custody and control of the records, including the responsibility and process for handling requests for access to information;

•          ensuring that Silvercrest Insurance Group.has access to information produced, developed, recorded or acquired by third parties as a result of the contract, including timely access in response to requests for information, and specifying that third parties shall not deny access to, or retain custody of, personal information because of late or disputed payment for services;

•          requiring third parties to report breaches of confidentiality and privacy to the Silvercrest Insurance Groups Privacy Officer within 48 hours of knowing that the breach occurred;

•          addressing disaster recovery and backup of any information assets and systems in the custody of the third party;

•          addressing the disposition (e.g. destruction or return) of all of the Silvercrest Insurance Groups information assets (e.g. records, hardware, system documentation) upon termination of the contract;

•          specifying any audit or enforcement measures that Silvercrest Insurance Group.will undertake to ensure that third parties comply with information handling and security provisions outlined in contractual agreements (for example, non-disclosure agreements, audit trails, regular review of third party access requirements, inspection of third party premises).

•          Silvercrest Insurance Group. ensures that all employees and volunteers are aware of its privacy policies and procedures, and understand the importance of maintaining the confidentiality of personal information.

•          Care shall be taken in the disposal or destruction of personal information to prevent unauthorized parties from obtaining access to the information.

8.  OPENNESS

•          Upon request, Silvercrest Insurance Group. makes available specific information about its policies and practices relating to the management of personal information, including:

•          the means of gaining access to personal information held by Silvercrest Insurance Group.

•          identification of personal information held by Silvercrest Insurance Group, and a general account of its use;

•          a copy of any brochures or other information explaining the Silvercrest Insurance Groups Privacy Policy, Guidelines and related procedures;

•          reference to the statement of Silvercrest Insurance Group. Privacy Policy on Silvercrest Insurance Group. website, if applicable.

•          To make an inquiry or lodge a complaint about the Silvercrest Insurance Group personal information handling  policies and procedures, contact Silvercrest Insurance Group. Privacy Officer by mail at Silvercrest Insurance Group., Suite 106, 1212 - 1St. S.E., Calgary, Alberta, Canada, by e-mail at info@silvercrestinsurance.ca 

9.  INDIVIDUAL ACCESS

•          Upon request, Silvercrest Insurance Group. provides individuals with access to their personal information held by the association. Individuals have the right to challenge the accuracy and completeness of their personal information held by Silvercrest Insurance Group, and to have it amended as appropriate.

•          All requests by individuals (e.g. members, employees, volunteers, contractors) to access their personal information held by Silvercrest Insurance Group, or to correct or amend their personal information, should be directed to the designated Privacy Officer.  Such requests should be in writing.

•          Silvercrest Insurance Group. responds to requests for access to personal information within 30 business days.

•          Responding to an individual’s request for information is usually done at no or minimal cost to the individual.  However, a fee for reasonable costs incurred may be charged when responding to more complex requests, provided the individual is informed in advance.

•          In order to safeguard personal information, Silvercrest Insurance Group. may request sufficient information from the individual to verify that person’s identity.

Limitations to Individual Access

•          Silvercrest Insurance Group. provides individuals access to their personal information subject to limited and specific exceptions.  Silvercrest Insurance Group. will refuse access to personal information if:

•          Silvercrest Insurance Group. has disclosed information to a government institution for law enforcement or national security reasons;

•          it would reveal personal information about a third party unless there is consent or a life-threatening situation;

•          doing so could reasonably be expected to threaten the life or security of another individual;

•          the disclosure would reveal confidential commercial information; or

•          the information is protected by solicitor-client privilege

•          If access to information is refused, Silvercrest Insurance Group. shall, in writing, inform the individual of the refusal, the reason(s) for the refusal, and any recourse the individual may have to challenge Silvercrest Insurance Group.

Correction/Amendment of Personal Information

•          Silvercrest Insurance Group. corrects or amends personal information as required when an individual successfully demonstrates the inaccuracy or incompleteness of the information.  Amendment may involve the correction, deletion, erasure, or addition to any personal information found to be inaccurate or incomplete.

•          Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Silvercrest Insurance Group.shall inform any third parties having access to the personal information in question as to any amendments, or the existence of any unresolved differences between the individual and Silvercrest Insurance Group.

10. CHALLENGING COMPLIANCE

•          Silvercrest Insurance Group. investigates all complaints concerning compliance with its Privacy Policy, Guidelines and practices, and responds within 30 days of receipt of a complaint.   If a complaint is found to be justified, Silvercrest Insurance Group. takes appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. Individuals shall be informed of the outcome of the investigation regarding their complaint.

•          Complainants may address inquiries or complaints concerning compliance with these policies or guidelines by contacting Silvercrest Insurance Group. Privacy Officer as set out in these Guidelines under Principle 8 (Openness).  A complaint may also be addressed in writing to the Privacy Commissioner of Canada at 112 Kent Street, Ottawa, Ontario, K1A 1H3.

Policy Revisions

Any changes to the Silvercrest Insurance Group. Privacy Policy will be promptly communicated on this page. Policy changes will not alter how we handle previously submitted personal information.