Access to Personal Information (Canada)

Zensurance Inc and Zensurance Brokers Inc (collectively “Zensurance”) understand the importance of protecting the privacy of clients and place a high priority on effectively dealing with any privacy related requests. This Access to Personal Information Policy addresses how Zensurance will meet its obligations under our Privacy Policy and the law with respect to permitting access to personal information. All privacy related access requests will be treated seriously, dealt with promptly and handled in a confidential manner.

This procedure will apply to a client seeking access to review his or her own personal information. This procedure also applies to others, including law enforcement authorities, seeking to access information on a client.

To make an access request, the following procedure may be followed, or as appropriate, will apply:

  1. The Applicant must contact the Privacy Officer for Zensurance in writing or via email and request access to the personal information.
  2. The request for access will be retained and recorded by the Privacy Officer.
  3. The Privacy Officer will send an acknowledgement by letter to the Applicant of receipt of the request stating the date of receipt, within 15 business days following the date of receipt of the access request and confirm that the access request is being processed. D. Zensurance will respond to the request within 30 days.

The Privacy Officer will determine if the request for access is legitimate and not frivolous or vexatious. The Privacy Officer may require further information to allow him or her to make this determination. If the Privacy Officer determines that the request for access is not legitimate, or the Applicant is not authorized to make the request, he or she will:

  1. Decline to permit access to the file;
  2. Document why;
  3. State the reason for declining access in the file;
  4. Inform the Applicant in writing, as to the reason for declining access; and
  5. Provide the available resources to challenge the decision.

In permitting access to personal information, the Privacy Officer will first examine the file to make a copy of the contents to be disclosed. Zensurance will take steps to authenticate the identity of the customer prior to providing access and will set out the authentication procedure used in the file. Zensurance may charge a reasonable fee to comply with an access request as permitted by law.

The Privacy Officer shall not disclose any information that Identifies third parties unless

  1. On the face of the document containing the information, there is a consent by the third party to the release of his/her name in connection with the information in question; or
  2. It is possible to sever any information identifying a third party, in which case the Privacy Officer will provide the customer with access to the remaining information; or
  3. falls within an exception to disclosure indicated in Zensurance’s Privacy Policy or by applicable law.

Access to personal information may take place by mail. The Privacy Officer will:

  1. Make copies of documents that will be released;
  2. Mail or, if requested, electronically transmit copies of the documents to be released;
  3. Insert a note in the file listing the documents transmitted indicating the date and method of transmission of documents and the place of inspection.
  4. Provide a reasonably specific account of third parties to whom information has been disclosed including a list of entities to which information may have been disclosed; and E. Advise the Applicant of the source of information included in the file.

Once the Applicant has received the information from the Privacy Officer, the Applicant may then submit written comments to the Privacy Officer concerning any information he or she considers inaccurate or incomplete for insertion in the file. The Privacy Officer will place these comments in the file.

You may contact Zensurance at:

Zensurance Privacy Offer
1301-200 University Avenue Toronto,
Ontario M5H 3C6
privacy.officer@zensurance.com

Zensurance will also comply with any and all requirements to notify a government institution of an access request respecting any disclosure of information to such government institution or in response to a subpoena or similar order.

Last revised: September 2021

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