At Puhl Employee Benefits, protecting your privacy is important to us. Whether you are an existing client or are considering a relationship with us, we recognize that you have an interest in how we may collect, use and share information about you.
Puhl Employee Benefits has a long tradition of safeguarding the privacy of our client’s information. We understand and appreciate the trust and confidence you place in us and we take seriously our obligation to maintain the confidentiality and security of your personal information.
In order to meet your needs as a member of the Hoteliers Benefit Plan, it is necessary for us to obtain accurate information about you. We collect, use, distribute and retain only information about you that is relevant & necessary for a service or transaction. We will not disclose your information to any person without your permission.
We will only disclose your information as set out below.
- If disclosure is necessary to effect a transaction or service. For example, disclosure will be made to third parties for certain registration & applications providing they too have appropriate privacy policies in place.
- Disclosure will be made if we are compelled to do so by law and we will only disclose the specific information requested.
Collection of Non-public Personal Information
Collecting personal information from you is essential to our ability to offer you high-quality investment, retirement, insurance benefits and other financial products. When you apply for products or services from us, we need to obtain specific information from you to determine whether or not we can provide what you are requesting. As part of that process, we may collect information about you, (known as non-public personal information), from the following sources:
- Information we receive from you on application or other forms, such as your name, address, social insurance number and date of birth; or
- Information about your transactions with us, our affiliates or others such as other life insurance policies or annuities that you may own.
Limited Use and Sharing of Non-public Personal Information
We use the non-public personal information we collect to help us provide the products and services you have requested and to maintain and service your account(s). Once we obtain non-public personal information from you, we do not disclose it to any third party except as required by law.
We may share your non-public personal information within Puhl Employee Benefits to help us develop innovative financial products and services and to allow our member companies to inform you about them. Puhl Employee Benefits provides a wide variety of financial products and services including individual life insurance, individual fixed and variable annuities and group life, disability and medical stop-loss insurance.
We also may disclose your non-public personal information to companies that help in conducting our business or perform services on our behalf, or to other financial institutions with which we have joint marketing agreements. Puhl Employee Benefits is highly selective in choosing these companies, and we require them to comply with strict standards regarding the security and confidentiality of our client’s non-public personal information. These companies may use and disclose the information provided to them only for the purpose for which it is provided, as permitted by law.
There also may be times when Puhl Employee Benefits is required to disclose our client’s non-public personal information, such as when complying with Federal or local laws, when responding to a subpoena, or when complying with an inquiry by a government agency or regulator.
Our Treatment of Information about Former Clients and Employees
Our protection of your non-public personal information extends beyond the period of your relationship with us. If you client relationship with us ends, we will not disclose your information to non-affiliated third parties other than when permitted or required by law.
Security of Your Non-public Personal Information
We maintain physical, electronic and procedural safeguards that comply with federal and provincial regulations to safeguard your non-public personal information from unauthorized use or improper access.
Employee Access to Your Non-public Personal Information
We restrict access to you non-public personal information to those employees who have a business need to know specific information in order to provide products or services to you or to maintain your accounts. Our employees are governed by a strict code of conduct and are obligated to maintain the confidentiality of client information
Canadians are protected by two federal privacy laws, the Privacy Act (pertains mainly to federal government departments & agencies): and the Personal Information Protection and Electronic Documents At. (PIPEDA)
As of January 1, 2001, individuals were protected by PIPEDA, which sets out ground rules for how private sector organizations may collect, use or disclose personal information in the course of commercial activities. The law gives individuals the right to see and ask for corrections to information an organization may have collected about them. Since the beginning of 2001, the act applies to personal information about client or employees that is collected, used or disclosed by the federally regulated sector in the course of commercial activities. It also applied to information sold across provincial and territorial boundaries. AS of January 1, 2002, the personal health information collected, used or disclosed by these organization sis also covered.
As of January 1, 2004, PIPEDA will cover the collection, use or discloser of personal information in the course of any commercial activity within a province, including provincially regulated organizations.
The Canadian Standards Associations Model Code
Puhl Employee Benefits’ privacy provisions are based on the Canadian Standards Association’s ‘Model Code for the Protection of Personal Information’. The standard addressed the ways in which organizations collect, use and disclose personal information. It also addresses the rights of individuals to have access to their personal information and to have it corrected if necessary.
1. Our organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organizations compliance with the following principles.
2. Identifying Purposes. The purposes for which personal information is collected shall be identified by our organization at or before the time the information is collected.
3. Consent. The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except when inappropriate.
4. Limiting Collection The collection of personal information shall be limited to that which is necessary for the purposes identified by our organization. Information shall be collected by fair and lawful means.
5. Limiting Use. Disclosure and Retention. Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with consent of the individual or as required by la. Personal information shall be retained only as long as necessary for fulfillment of those purposes.
6. Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
7. Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
8. Our organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
9. Individual Access. Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance. An individual shall be able to address a challenge concerning compliance with the above principles to the designated individuals(s) responsible for our organization’s compliance.