The Industrial Alliance Group is composed of Industrial
Alliance Insurance and Financial Services Inc. and its subsidiaries
("we/us"). Together, we are committed to protecting
our clients', employees' and representatives' ("you/your")
privacy, and to ensuring the confidentiality of the personal
information provided to us in the course of our business.
disclosing and storing your personal information. Our
information and your right to access that information.
Collecting information about you is necessary in order for
us to provide you with high quality services. The nature
and sensitivity of the information we collect about you varies
according to the services we provide you and to legal
requirements imposed on us (such as your social insurance
number, where investment income is generated by a chosen
The purposes for which we collect personal information
about you are identified at or before the time of collection.
For example, information may be collected while submitting
an application, opening an account, or submitting a claim.
Purposes for collecting information generally include providing
products or services requested, confirming your identity,
protecting against fraud, or dealing with matters concerning
the relationship between us.
Any questions and concerns you may have regarding the
purposes for collecting information may be directed to us at
the address provided below.
When we collect personal information from you, we obtain
your consent to use the information for the purposes collected.
We will obtain your consent for any additional use
or collection, or if the purpose of using the information is
We generally seek your express written consent in order to
collect, use or disclose personal information. Where appropriate,
for less sensitive information, we may accept your
verbal consent. Occasionally, we may imply consent where
we can infer consent from your action or inaction.
Consent must be given by you or your authorized representative
such as a legal guardian or a person having power of
You may withdraw your consent at any time, subject to legal
or contractual restrictions (for example, your right to withdraw
consent is necessarily limited where we need information
to extend a loan against the value of a policy issued by
us). We will inform you of the consequences of such withdrawal,
including the possibility that we may not be able to
provide a product or process a request. If you choose not to
consent, we will record the decision in our file.
In limited circumstances, we have the right (or obligation)
to collect, use or disclose personal information without your
knowledge and consent. This occurs when legal, medical, or
security reasons may make it impossible or impractical to
seek consent. When information is being collected for the
investigation of a potential breach of contract, the prevention
or detection of fraud, or for law enforcement purposes,
seeking consent might defeat the purpose of the information
collection. Similarly, seeking consent may be impossible
or inappropriate when you are a minor, seriously ill or
LIMITS TO COLLECTION, USE AND DISCLOSURE
We limit the collection of your personal information to what
we need in relation to the purposes identified to you.
We collect the information directly from you unless you allow
us to collect information from a third party or in accordance
with the law.
We limit the use of your personal information to the purposes
we have identified to you. This means that we cannot
use your personal information for other purposes without
your consent, except as required by law.
We cannot disclose your personal information to anyone
except with your consent or as required by law.
Your personal information is only accessible to certain
authorized persons, and only to the extent necessary to
perform their duties.
You have the right to know, on request, to whom the
information was disclosed. Only in rare instances are we
prevented by law from making such disclosure. We
maintain accurate records, recording to whom we disclose
personal information and in what circumstances it was
We will occasionally share your personal information with
service providers or agents to ensure the proper administration
of products, or to provide you with the services you
require. These service providers or agents must agree to
comply with privacy legislation before receiving any personal
In certain circumstances, we may use service providers
outside Canada, including the United States. We are responsible
for the service provider?s compliance with our
personal information is comparable to that provided by us.
Any questions concerning the collection, transfer or use of
personal information outside Canada can be forwarded to
the Privacy Officer at the address provided below.
We only retain your personal information for as long as
needed for the purpose it was collected. We must destroy
this information in accordance with the law and our file retention
guidelines. When we destroy your personal information,
we make sure that confidentiality is secured and that
no unauthorized person can access the information during
the destruction process.
We do not sell client lists to third parties.
We make every possible effort to ensure that your personal
information is as accurate and complete as necessary for
the purposes it is collected, used, or disclosed.
We are responsible for your personal information in our
possession or control, including information that may be
transferred by us to third parties for processing. We require
such third parties to keep personal information under strict
standards of privacy and protection. We adhere to legislated
and self-imposed rules, aimed to safeguard your privacy.
Business Conduct (applicable to directors, officers and employees),
Market Conduct Standards (applicable to agents
and brokers) as well as insurance industry guidelines and
Our staff is trained on these processes and procedures and
is provided with information about privacy laws.
We have implemented and continue to implement rigorous
safeguards so that your personal information remains
strictly confidential and is protected against loss or theft,
as well as unauthorized access, disclosure, copying, use, or
Protection methods include organizational measures such
as requiring security clearances and limiting access to a
"need-to-know" basis, physical measures (e.g. building access
cards for employees, visitor registration and identification
cards, off-site backups and archiving), and technological
measures such as the use of password and encryption (e.g.
the use of routinely changing passwords, firewalls and segmented
REQUEST FOR ACCESS TO INFORMATION ANDAMENDMENTS
You have the right to be informed whether we hold
personal information about you and to see that information.
You also have the right to enquire as to how we collected
your information, how we used it and to whom it may have
This information will be provided to you within a reasonable
time from the date we receive your written request. We
may charge a reasonable fee for processing your request.
In certain limited and specific circumstances, we may refuse
to provide to you the requested information. Exceptions to
your access right can include information that is prohibitively
costly to provide, information that contains references to
other individuals, information that cannot be disclosed for
legal, security or commercial proprietary reasons, information
that has been obtained in the course of an investigation
of a potential breach of contract or fraud, and information
that is subject to solicitor-client or litigation privilege.
In cases where we hold medical information about you, we
may refuse to provide you with direct access to this information
and may instead request that a health care professional
be designated to provide the information to you.
You may challenge the accuracy and completeness of your
personal information. We will respond to an amendment
request within a reasonable time.
Any request for access to information or request for amendment
must be sent to the following address:
Attention: Chief Privacy Officer
T.E. Investment Counsel, a member of iA Investment Counsel Inc.
26 Wellington Street East, Suite 710
Toronto, Ontario M5E 1S2
Email : firstname.lastname@example.org
COMPLAINTS AND CONCERNS
Our employees and representatives are trained to respond
to your questions or concerns about personal information.
Should you be dissatisfied with the response of our employee
or representative, you may contact the Privacy Officer:
A complaint concerning the protection of personal information
should be addressed to the Privacy Officer at the address provided above.
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