Crewson Insurance Brokers Ltd.

Privacy Guidelines

Crewson Insurance Privacy Policy and Procedures
At Crewson Insurance Brokers Limited (Crewson Insurance) we understand that privacy is an important issue for all of our clients. The Crewson Insurance privacy code outlines the 10 interrelated principles which detail our commitment in meeting the legislative requirements regarding the confidentiality and security of our client’s personal information. Crewson Insurance believes that ensuring the accuracy, confidentiality and security of all client information is more than a legal requirement, it is an ethical obligation.

Client Consent
Crewson Insurance has an obligation to obtain client consent to collect, use or disclose any personal information that will be kept on record for transacting business on behalf of our clients or providing services to support the ongoing maintenance of their investment portfolios.

Consent is required for the collection of personal information and the subsequent use or disclosure of this information. Each new client will be provided with a copy of the Crewson Insurance Privacy Statement upon the client’s request. Crewson Insurance will make every reasonable effort to ensure that the client understands how their personal information will be used or disclosed, and given the opportunity to share their questions and concerns. Consent cannot be obtained through deception or duress.

Consent is not required for the collection, use and disclosure of personal information for legal or security reasons such as the collection of personal information for the detection and prevention of fraud or compliance with legal, regulatory or government orders, where obtaining consent might defeat the purpose of collecting this information.

Client’s consent may be

expressed,
implied, or
given through an authorized representative such as a lawyer.

Consent may be given

orally,
in writing, or
electronically

Depending on the sensitivity of the information the client can express whether or not consent is granted: over the telephone when information is being collected electronically when submitting an agreement, application or other information in writing when signing an agreement or application form, when using a product or service, or when indicating by means of a check-off box

Consent may be withdrawn or refused, subject to contractual or legal arrangements, that Crewson Insurance is given reasonable notice. Any client that requests to limit their consent must be advised that:

Crewson Insurance may be obligated to collect and maintain certain personal information on file as directed by our principals or regulatory bodies,
they are limiting the ability of Crewson Insurance to transact business on their behalf, as we must provide personal information to our third party distributors to secure their transaction, and
all requests to limit consent must be forwarded in writing to the Crewson Insurance Privacy Officer

Crewson Insurance will not unreasonably withhold products or services from clients who refuse or withdraw consent. If detailed personal information is required by statutory regulations Crewson Insurance may need to decline a request from clients who will not consent to the use of such information.

Collection of Personal Information
Personal information will be collected directly by our brokers when a client requests, obtains or uses any of the financial products or services available through Crewson Insurance. The sales associate will communicate the purposes for which information is being collected either orally or in written format. Crewson Insurance brokers may collect information for the following reasons:

to understand the needs of the client
to determine the suitability of the product or service
to determine the eligibility of the client for products and services
to develop, offer and manage products and services to meet the needs of the client
to provide ongoing service
to detect and prevent fraud and help safeguard the financial interest of the dealer and its clients
to meet statutory legislative and regulatory requirements
to verify the client’s identity

Crewson Insurance will only collect personal information for the purposes identified to the clients; use lawful methods of collection; and will not collect information indiscriminately or under duress to the client.

Using Personal Information
Client information will only be used or disclosed for the purpose for which it was collected. Crewson Insurance will not use a client’s personal information for any additional purpose unless further consent has been acquired to do so.

Crewson Insurance will not sell client lists or personal information to Third Parties.

Information will be shared between the staff of Crewson Insurance and third party distributors for the purpose of transacting business on behalf of the client.

Storing Personal Information
Crewson Insurance is committed to the safekeeping of the client’s personal information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use or modification. All files must be kept in a secure location at each branch premises to maintain privacy and ensure physical safety.

Crewson Insurance will retain all documentation that has client sensitive information only as long as necessary or expected to be necessary for the identified purposes, or as required by legislation.

Accuracy of Information
All personal client information on file with Crewson Insurance will be accurate, complete and up to date as necessary for the purposes for which is it collected and used. Information shall be sufficiently accurate, complete and up to date to minimize the possibility that inappropriate information may be used to make a decision about the client.

Access to Client Information
Access to personal client information will be limited to employees of Crewson Insurance.

Clients have a right to access their personal information that is kept on file with Crewson Insurance. Upon request, Crewson Insurance will, within a reasonable time period, tell the client what personal information is on file, what it is being used for, and to whom it has been disclosed.

Clients may also request in writing, directed to the Crewson Insurance Privacy Officer a request for access to their personal information. The client may be asked to be specific about what information they want to access and will need to provide personal information to properly identify themselves, to enable Crewson Insurance to provide details regarding the existence, use and disclosure of personal information. Crewson Insurance will make this information available within 30 days of the request, or provide written notice of extension where additional time is required to fulfill the request.

If the request for providing information to the client must be refused by Crewson Insurance, a written notification will be sent to the client documenting the reasons for the refusal and resources for them to redirect the request. Reasons for refusal to provide information may include:

information that would disclose information of another individual
information generated in a formal dispute resolution process
information that can not be disclosed for legal, security or commercial proprietary reasons, and
information that is subject to solicitor-client or litigation privilege

Training
The Privacy Officer is responsible for ensuring that all staff, employees and contracted individuals receive the appropriate training on privacy issues and their responsibilities detailed in he Crewson Insurance Privacy Code.

At the time a new employee or contracted individual joins Crewson Insurance they will be provided with a copy of our Privacy Statement and also a copy of the Crewson Insurance Privacy Code. These will be for review purposes and will be supported with training by their designated branch manager or other individuals that have been designated to assist with the training process.

The individuals must be confident that they can provide Crewson Insurance clients with informed knowledgeable information regarding the Privacy Act, the Crewson Insurance Privacy Code and the policies and procedures that have been implemented. They must also agree to adopt the Crewson Insurance Privacy Code and act accordingly in addressing our commitment to meeting the regulatory requirements under the Privacy Act.

Handling Complaints
The Crewson Insurance Privacy Officer is the point of contact for all matters regarding the collection, use, disclosure and data security of personal client information. These can be in writing, by email or by a personal telephone call.

The Crewson Insurance Privacy Officer will acknowledge receipt of the client’s complaint or concern in writing within 48 hours of the notification. This will detail a resolution if possible at that time. If more time is required to resolve the matter, then the Privacy Officer will note that in the correspondence and provide a future date as to when the matter will be resolved. If this requires contact of an outside third party, then the Privacy Officer will need to obtain the further consent of the client to share information pertaining to the issue. Any issues that have not been resolved by the Privacy Officer within 45 day of receipt will be reported to the Crewson Insurance Board of Directors for further review and direction on steps to be taken to resolve the issue.

All documentation regarding any complaints involving the collection, use or disclosure of personal information that has been directed to the Privacy Officer will be kept on file with Crewson Insurance for the legal required time and then will be destroyed using appropriate security measures to ensure that the material cannot be reproduced or reused in any further format.