Your Privacy is our Priority

This Privacy Code incorporates the following ten principles:

1. Accountability

All of our employees are responsible for maintaining and protecting the personal information to which they have access. For these purposes, “personal information” is information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources with your consent. It includes details such as your name and address, age, gender and marital status, identification numbers, including your credit card or certificate number and your occupation.

We have strict policies and procedures for protecting personal information and designated individuals within the Companies who are responsible for monitoring our compliance.

Securian Canada has a Chief Privacy Officer who oversees privacy governance, including this Privacy Code and related policies, dispute resolution, education, communications and reporting to our senior management and the Audit and Conduct Review Committee. The Chief Privacy Officer can be contacted as follows:

John Burns
Chief Privacy Officer
Canadian Premier Life Insurance Company
Canadian Premier General Insurance Company
1400-25 Sheppard Ave West
Toronto, ON M2N 6S6
Email address: privacy.officer@securiancanada.ca

2. Identifying Purpose

When you become a Securian Canada customer, or apply for additional products and services, we ask you for your personal information for the following purposes:

• to verify your identity and protect against fraud;
• to determine the suitability of our products and services for you;
• to determine your eligibility for our products and services and offer them to you;
• to set up and manage the products and services that you have requested; and
• to comply with laws and regulation.

3. Consent

When you apply for a new product or service, we ask you for your consent to collect, use or disclose your personal information. Consent may be oral or written, express (e.g., providing your personal information on an application form or during an inbound telephone call) or implied (e.g., not withdrawing your consent to a certain use of your personal information when given the opportunity to do so).

You may, at any time, withdraw your consent so long as:

• you provide reasonable notice;
• we are not legally required to collect, use or disclose your information; and
• withdrawing your consent does not impede our ability to fulfill your contract.

4. Limiting Collection

We only collect the information that we need for the identified purposes. We may ask you to provide the following personal information:

• Health Information is required for some of our insurance products to ensure that you are eligible for
• Contact Information such as your name, address, telephone number or email

You may choose not to provide us with certain information in some situations; however, if you make this choice, we may not be able to provide you with the product, service or information that you request.

We may monitor or record our incoming or outgoing telephone calls with you for our mutual protection (e.g., to ensure your instructions are carried out, to document that we have made required disclosures to you and to ensure that customer service call quality standards are maintained).

We will make certain that you are informed of the purposes listed above when you apply for any of our products or services. If a new purpose for using your personal information develops, we will ask for your consent.

5. Limiting Use, Disclosure and Retention

We will only use or disclose your personal information for the reason(s) it was collected. We do not sell or give lists of our customers to other companies for their own use and, if we obtain customer lists from other organizations, we require the organizations to confirm their compliance with all relevant privacy legislation. We do not share your personal information with any related or affiliated companies for marketing purposes.

• Adobe Inc. (Adobe Analytics and Adobe AEM)
• Dynatrace, Inc. Or Dynatrace LLC
• Google Canada Corp. or Google LLC
• Microsoft Canada Inc. or Microsoft Corp. (Bing and Microsoft Clarity)

These companies collect data elements such as:

• IP Addresses
• User agent string
• Cookie ID
• Web Activity data (pages, viewed, clicks, etc.)
• User Profile data (internal ID’s, browser, marketing channel,etc.)

Such data are provided to Securian Canada for data processing and administration. Some or all this data may be provided to third party consultants, third party administrators, policy administrators, investigators, external call centre staff, external claims adjudicators, or reinsurance companies, to provide services on Securian Canada’s behalf.

If any external companies are provided any information, they will be given only the information needed to perform those services. We have contracts in place holding these companies to the same high standards of confidentiality by which we are governed. In some cases, these other companies may be located outside of Canada and may be required to disclose information to government authorities, regulators or law enforcement under a lawful order made in that country.

Personal information may be released to legal or regulatory authorities in cases of suspected money laundering, criminal activity, for the detection or prevention of fraud or when required to satisfy the legal or regulatory requirements of governments, regulator authorities or other self-regulatory organizations. Other reasons for the release of personal information include when we are legally required to do so (e.g., by court order). If we release personal information for any of these reasons, we keep a record of what, when, why and to whom such information is released.

We have policies in place that govern the retention of your personal information so it will be kept only for as long as it fulfills its intended purpose or as legally required. If personal information is no longer required, we securely destroy it. The length of time that we keep your personal information will depend upon the product or service that we provide to you and the nature of the information.

6. Accuracy

We are committed to the accuracy of your personal information and ensuring that it is complete and up to date. If you discover inaccuracies in our data, or your personal information changes, please notify us immediately, so that we can make the necessary changes. When required, we will make our best efforts to advise others of any important amendments to your personal information that we may have released to them. If we do not agree to make the amendments that you request, you may challenge our decision by contacting our Chief Privacy Officer.

7. Appropriate Safeguards

Your personal information is secure with us, regardless of the format in which it is held. We have comprehensive security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of your personal information.

We maintain physical, electronic and procedural safeguards to protect your personal information. Examples of safeguards include restricted access to our information processing and storage areas, limited access to relevant information by authorized employees only (such as the Claims Department, Complaint Department, or Contact Centre), use of passwords, firewalls and encryption of electronically transmitted information, and the use of secure locks on filing cabinets and doors. As well, all employees are required to immediately retrieve from our printers all documents that include personal information.

We have agreements and controls in place with third party service providers, such as Claims consultants, policy administrators (e.g. DRIASI, Armour Group/PSG) among others, requiring that any information provided by us must be safeguarded and used only for the sole purpose of providing the service we have requested from them.

8. Openness

Our Privacy Code and any other policies and practices relating to the management of personal information are available to customers. From time to time, we may make changes to this Privacy Code and will inform you of changes, as required by law. The most up-to-date Privacy Code is always available at www.securiancanada.ca.

9. Access

If you want to review or verify your personal information, or find out to whom we have disclosed it, please request this by contacting our Chief Privacy Officer. We may need specific information from you to enable us to search for, and provide you with, the personal information we hold about you. There may be instances where we are unable to provide some of the personal information, we hold about you and if we are unable, we will let you know the reason(s) why, as permitted by law.

10. Complaints

You may submit a complaint to our Chief Privacy Officer concerning our compliance with this Privacy Code. We will fully investigate all complaints and will inform you of the outcome of the investigation. If you wish to pursue your privacy complaint further, you may contact:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: 819-994-5444
TTY: 819-994-6591
Fax: 819-994-5424

Our Commitment to You

We appreciate the opportunity to help you meet your insurance needs. Earning and keeping your trust is at the very core of our business. We are committed to respecting and protecting the privacy and confidentiality of the personal information you have entrusted to us. As a client of Securian Canada, you have the opportunity to make choices about how personal information about you may be shared. As you consider this, we encourage you to make choices that will best enable us to provide you with quality products and services that help you meet your financial needs and objectives.

Important changes to our privacy policies and practices will be reflected in this Privacy Code in a timely manner. We may add, modify or remove portions of this Privacy Code as required.