Types of personal information
Inova may collect personal information in order to fulfill the Purposes set out in principle one of this Policy including: an individual’s address, telephone number, date of birth, family status, marital status, occupation, medical and health records, assets, liabilities, income, credit rating, credit and payment records, an individual’s previous insurance experience, including claims history, individual’s driving record, policy number and vehicle identity number.
In our service delivery to you over the telephone, we typically record and monitor each conversation for the following reasons:
- To confirm your identity,
- To maintain the quality of our service delivery,
- To assist in staff training,
- To update and establish a record of the information you provide.
We will make all reasonable efforts to ensure that any personal information we collect and keep is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we will rely to a large extent on you to provide us with accurate information and to inform us of changes, such as changes in your contact information. You have the right to access and verify your personal information maintained in our files, and to request that any factually inaccurate personal information be corrected, if appropriate.
Under current legislation and as our customer, we will ask for your express consent to send you electronic messages. If you do not wish to receive anymore marketing material from us, you may do so by using the unsubscribing feature found in any of our electronic messages. This opt-out will not extend to communications you have specifically consented to receive on an individual basis, or follow-ups that are essential in the dealings of your insurance needs.
THE TEN PRINCIPLES
Inova complies with the following principles:
Principle One: Accountability
Inova is responsible for all personal information under its control, whether supplied by you and by a third party, or that we have provided to a third party. We have established internal policies and procedures to comply with our policy, and have designated a Privacy Officer who is responsible for ensuring we comply with privacy legislation.
Send us an email to communicate with our team regarding your specific privacy questions or concerns.
Principle two: purposes
Inova informs individuals of the purposes for which personal information is collected at the time or prior to the collection of the information.
Inova shall collect information from, but not limited to, government agencies, insurers, other insurance reporting or data sharing agencies, credit bureaus and directly from you to:
- Assess your application for insurance, including underwriting your policy;
- Communicate with you for customer service, and to better manage our relationship with you;
- Respond to your inquiries;
- Maintain the accuracy of our records;
- Evaluate, investigate and settle claims;
- Detect and prevent fraud;
- Provide you with Inova’s other insurance products, services and related information and/or promotional materials to meet your needs;
- Analyze business results;
- Train employees and monitor for quality assurance; and
- Meet legal and regulatory requirements.
If Inova requires your personal information for any purpose other than as identified above, we will seek your consent before using it. Where permitted by law, your consent may be obtained to collect and use your credit information in order to provide you with a discount.
Principle three: consent
Inova requires the knowledge and consent of you for the collection, use, or disclosure of your personal information, except where consent is not required.
We issue an insurance policy with the understanding that with your consent, you have the obtained consent of all persons named in your insurance policy for the collection, use and disclosure of their personal information for the purposes outlined above.
You may provide Inova with your express consent (oral or writing) for the collection, use and disclosure of your personal information, or your consent may be implied by your actions. Express consent is given by a customer’s agreement to acquire or accept a product or service. Express consent may also be given by a customer’s action (for example, by clicking an accept button on a computer screen or by providing his/her driver’s license number). If oral consent is given, Inova and/or intermediaries will document and/or record the conversation in order that it may be located should this be necessary.
Consent will also be given by you when you receive your insurance policy and you do not inform us that you wish to opt out of all or portions of it.
Implied consent will be inferred from the relationship between Inova and its partners or from the nature of the dealings of the parties. For example, it is reasonable to conclude there is implied consent to the disclosure of personal information to the insurer to meet your insurance needs when you provide personal information to Inova for the purpose of obtaining insurance.
In addition, when you make changes to your policy or when your policy automatically renews, you are agreeing that any consent previously provided relative to your policy remains in effect.
Consent may be given by you or by an authorized representative. Inova will verify authorization by, among other things, requesting identification or the representation and the reason for representation.
Knowledge and consent are not required under the law for the collection, use and disclosure of personal information in instances such as: for compliance with a subpoena, search warrant, or court order, where personal information is publicly available, for the detection and prevention of fraud or when required by law.
Withdrawal of consent by written notification. Subject to contractual restrictions and reasonable notice, you may refuse or withdraw consent to the collection, use or disclosure of personal information by writing to Inova’s Privacy Officer. You may also opt out of certain communications we may send you regarding other products and services. However, withdrawing your consent may affect our ability to meet your insurance needs.
Principle four: Limit of collection
Inova shall collect only the personal information necessary for the purposes set out above. We only collect information necessary to conduct our business dealings with you and we shall do so openly, fairly and lawfully.
Principle five: Limit of use, disclosure and retention
Inova shall not use or disclose personal information for purposes other than those for which it was collected, with the exception where we have obtained consent from the individual or as required by law. Inova shall retain personal information only for the fulfillment of the purposes set forth above.
In instances where personal information was obtained through the use of Inova’s two-click quote application (and where consent was provided by the customer with the goal to obtain only an insurance quote estimate), Inova will retain no record of the personal information obtained.
We may disclose your personal information to third parties, which are subject to applicable privacy legislation. Only those companies or individuals who are authorized, based on their need to carry out work for the purposes identified in principle two, can have personal information disclosed to them.
Furthermore, should Inova become involved in any business transaction including purchase or sale, merger or amalgamation, your personal information may need to be shared with applicable third parties to complete such a transaction.
The retention periods for personal information are consistent with Inova’s business partners’ retention policies, which meet provincial and federal legislation requirements. Your personal information will only be retained as long as necessary for Inova to serve you (or for legal purposes).
Principle six: Accuracy
Inova shall ensure personal information is accurate and complete for the purposes it is used and to minimize improper decisions that are made about you. In case of any doubt about its accuracy, Inova may contact you to verify and/or amend the information.
Principle seven: Safeguards
Inova has established proper safeguards given the sensitivity of the information it retains in order to prevent unauthorized access to the information. In general, Inova ensures that personal information: is not left unattended, is accessed only when legitimate business needs exists, is not copied or modified or destroyed without consent, is accessed only by authorized individuals, is sent to third parties through secured means and is stored in a secure location.
When receiving personal information from third parties, Inova employees and contractors adhere to the same principles set forth by the present policy. Any personal information that is no longer required for its original purpose and has been retained for the minimum required term shall be destroyed, erased, made anonymous or archived in a secure matter.
Principle eight: Transparency
Upon written request, Inova shall make available an explanation of its policy and the management of its complaints process. Requests and enquiries of this nature may be directed to our Privacy Officer.
Principle nine: Access
Upon written request from individuals and except as may be limited by law, Inova shall provide an explanation on how it has used and disclosed personal information about them. Requests of this nature must be made to our Privacy Officer in writing by email, fax or letter. We respond to these requests in thirty (30) days. If an extension is required, Inova shall provide a notice stating the reasons for the extension within the initial thirty (30) day delay. Before responding in writing, Inova will verify if the person making the request is the person in question and correspondence will be to the address we have on file. Inova will assist individuals who need help in preparing such requests. If a request for disclosure is denied, Inova shall provide an explanation. Examples of non-disclosure may include (but not limited to): prohibitive cost and legal litigation. We may charge you for access to your information but only after first advising you of the approximate cost.
All amendments resulting through this process will be formally recorded.
How we share and destroy your information
In general, the disclosure of your information will be restricted to the parties who either need it or have a right to it. Your information will be provided or be accessible to: (a) our employees, agents and representatives who need it in the performance of their duties, (b) our affiliates (to address issues/concerns you may have with our services and products or to assist with other enquiries/investigations), (c) service providers who require your information to perform their duties towards their obligations to us, (d) anyone or organizations to whom you provided consent and (e) anyone who is otherwise authorized by law.
In instances where your personal information is provided to organizations in other jurisdictions/provinces in Canada, the laws of these jurisdictions would take effect.
When we destroy your personal information, we shall ensure proper safeguards are in place to inhibit unauthorized access during the destruction procedure.
Information we obtain from third parties
In the performance of our services to you, we obtain information from third parties. These may include (but not limited to) insurance brokers/agents/adjusters and reporting agencies. When we do this, we do this with your consent (or we confirm the personal information was lawfully collected and that it can be shared with us). This information may include (but not limited to): driving record and claims history, credit information, and accident reports.
For any questions you may have or if these intended uses are not reasonably obvious from the circumstances in which personal information is collected, you can limit or withhold the use or disclosure of the information by sending your request in writing to the attention of:
Inova Privacy Officer
3100 Boulevard Le Carrefour, Local 560,
Date policy posted: March 2017. Inova reserves the right to alter its policy from time to time. Such changes will be effective 10 days after its posting to its website.