INTRODUCTION
Maintaining the privacy and confidentiality of client information is one of the cornerstones of Easy Links Financial Inc. Since the company is built on trust, our clients expect that when they provide their personal information, including but not limited to name, date of birth, phone number, email address, address, medical conditions, credit card information, it will be properly protected and will only be used for the purpose for which the information was provided unless the client expressly authorizes otherwise.
PURPOSE
The purpose of this Privacy Policy is to ensure that the privacy and confidentiality of the Easy Links Financial Inc. clients is maintained at all times. Additionally, this Privacy Policy has been developed to comply with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which sets out rules for the collection, use and disclosure of personal information.
SCOPE OF THIS POLICY
This policy applies to all current, future or past clients of Easy Links Financial Inc. and must be followed by all employees, including but not limited to, customers service representatives, insurance brokers, developers, human resources, management, technical support.
THE TEN PRINCIPLES OF PIPEDA
The ten principles of PIPEDA are referred to as the “fair information principles” and form the basis of this Privacy Policy.
1. Accountability: Easy Links Financial Inc. is accountable for the personal information it collects, uses, retains and discloses;
2. Identifying Purposes: Easy Links Financial Inc. staff will explain the purpose for which the information is being used, at or before the time of collection, and this information will only be used for those stated purposes;
3. Consent: a client’s consent will be obtained at the time of collection, use, or disclosure of the individual’s personal information;
4. Limiting Collection: the collection of personal information will be limited to only the amount and type that is reasonably necessary for the identified purposes;
5. Limiting Use, Disclosure and Retention: personal information will be used for only the identified purposes, and will not be disclosed to third parties unless the individual consents to the alternative use or disclosure, and shall only be retained as long as necessary for the fulfillment of those purposes;
6. Accuracy: 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. Safeguards: Easy Links Financial Inc. uses physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure;
8. Openness: Easy Links Financial Inc. informs its clients and trains its employees about this Privacy Policy and the privacy procedures;
9. Individual Access: upon request, a client shall be informed of the existence, use, and disclosure of his or her personal information, they shall be given access to that information and shall be able to challenge the accuracy and completeness of the information and have it amended, as appropriate;
10. Provide Recourse: Easy Links Financial Inc. informs its clients and employees of how to bring a request for access, or complaint, to the Privacy Officer, and responds promptly to requests or complaints by the clients.
PERSONAL INFORMATION DEFINITION
Under PIPEDA, personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as age, name, policy numbers, income, ethnic origin, opinions, evaluations, comments, social status, credit records, medical records etc.
PURPOSES OF COLLECTION
Easy Links Financial Inc. collects, uses and discloses a client’s personal information in order to:
• Offer insurance products and services
• Determine insurance premiums
• Assess insurability
• Determine what product best suits the client’s needs
• Verify identity
• Update client policies with accurate insured name(s), date(s) of birth, phone number(s), address(s), email address(es), travel date(s) etc.
• Provide assistance and customer service
• Verify the accuracy of private information
• Liaison the claim process once a client initiates a claims appeal
• Keep records of personal information as accurate and up-to-date as is necessary to fulfill the purposes for which it is used
• Personal information may be used for other purposes that will be disclosed to the client prior to collection, use and disclosure of the information
CONSENT
An individual’s express consent will be obtained prior to or at the time of collection of the personal information. The purposes for the collection, use or disclosure of the personal information will be provided to the individual at the time his or her consent is required. Once consent is obtained to use his or her information for those purposes, Easy Links Financial Inc. has the individual’s implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified. Consent may be expressed in writing or it may be given verbally, electronically, or through authorized representative(s), such as a client’s financial services advisor and / or their contact in Canada.
An individual may choose to withdraw their consent or refuse to provide some or all of their personal information at any time by contacting the Customer Service Department. In certain circumstances, consent may be required for legal or contractual reasons. In these circumstances, withdrawing or withholding consent may affect Easy Links Financial Inc.’s ability to continue to provide the client with the products and services that have been requested.
LIMITING COLLECTION
Personal information collected will be limited to the purposes set out in this Privacy Policy. Whenever practical, Easy Links Financial Inc. will collect the required information directly from the client, or from the client’s authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail, email, or the Internet and through the client’s business dealings with the company. Easy Links Financial Inc. uses fair and lawful means to collect client’s personal information and only collects information that is pertinent and consistent with the purposes of the collection.
LIMITING USE, DISCLOSURE AND RETENTION
Personal information will only be used for the purposes set out in this Privacy Policy and will only be provided to, or be accessible by the Easy Links Financial Inc. personnel, associated advisors and the contracted insurance carriers for the purposes of processing an application for insurance, processing a claim, or other client requests.
No personal information is disclosed to a third party without the client’s consent, unless the disclosure of the personal information is permitted or mandatory under prescribed applicable laws and regulations.
Personal information will be retained in client files as long as the file is active, for as long as it is required to fulfill the identified purposes and for such periods of time as may be prescribed by applicable laws and regulations. Personal information that is no longer required will be destroyed, erased or made anonymous.
ACCURACY
Easy Links Financial Inc. endeavours to ensure that any personal information provided by the client in his or her active file(s) is accurate, current and complete as is necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed. Individuals are requested to notify the Customer Service Department of any change in personal or business information.
SAFEGUARDS
Easy Links Financial Inc. will use physical, organizational, and technological measures to safeguard personal information to only those Easy Links Financial Inc. employees, or third parties (such as contracted insurance carriers) who need to know this information for the purposes set out in this Privacy Policy.
Organizational Safeguards: Access to personal information will be limited to the Privacy Officer, Sales / Administration and / or Management personnel. The individuals granted access to personal information are not permitted to copy or retain any personal information on clients and must return all such information given to them once the purpose for being provided with this information has been fulfilled. All Easy Links Financial Inc. employees are required to sign a confidentiality agreement binding them to maintain the confidentiality of all personal information to which they have access to.
Physical Safeguards: All confidential information is stored in a physically secure manner, is used only for the intended purposes and is not disclosed to any unauthorized third party. Copies of confidential information is only printed as necessary, retrieved from the printer immediately, and stored or destroyed in an appropriate manner, as necessary. Active files are stored in locked filing cabinets when not in use. Access to work areas where active files may be in use is restricted to Easy Links Financial Inc. employees only and authorized third parties. All inactive files or personal information no longer required are shredded prior to disposal to prevent inadvertent disclosure to unauthorized persons.
Technological Safeguards: Personal information contained on Easy Links Financial Inc.’s computers and electronic databases are password protected in accordance with Easy Links Financial Inc.’s Electronic Communication Policy. Access to any of the Easy Links Financial Inc.’s computers is also password protected. Easy Links Financial Inc.’s Internet router or server has firewall protection sufficient to protect personal and confidential business information against virus attacks and “sniffer” software arising from Internet activity.
OPENNESS
Easy Links Financial Inc. will endeavour to make its Privacy Policy and procedures known to the client via this Privacy Policy.
ACCESS / COMPLAINTS / RECOURSE
A client who would like to review or verify what personal information is held by Easy Links Financial Inc., or to whom the information has been disclosed (as permitted by PIPEDA), may make the request for access, via phone by contacting the Customer Service Department, or in writing to the Easy Links Financial Inc.’s Privacy Officer. Upon verification of the individual’s identity, the Customer Service Department and / or the Privacy Officer will respond accordingly.
If the client finds that the information held by Easy Links Financial Inc. is inaccurate or incomplete, upon the individual providing documentary evidence to verify the correct information, if necessary, Easy Links Financial Inc. will make the required changes to the client’s active file(s) promptly.
If an individual has a concern about Easy Links Financial Inc.’s personal information handling practices, a complaint, in writing, may be directed to the Privacy Officer. Upon verification of the individual’s identity, the Privacy Officer will act promptly to investigate the complaint and provide a written report of the findings to the individual. Where the Privacy Officer makes a determination that the individual’s complaint is well founded, the Privacy Officer will take the necessary steps to correct the offending information handling practise and / or revise Easy Links Financial Inc.’s Privacy Policy and procedures.
It is important that the complaint is filed in writing and that “ATTN: Privacy Officer” is written on the envelope or in the subject of the email.
AMENDMENT TO EASY LINKS FINANCIAL INC.’S PRIVACY POLICY
This Easy Links Financial Inc. Privacy Policy is in effect July 29, 2016 (retroactive to January 1, 2016), and was revised on December 15, 2017, with the latest revision on May 22, 2024. This Policy is subject to amendment in response to developments in the prescribed applicable laws and regulations. The Privacy Officer will review and revise the Privacy Policy from time to time as required by changes in the prescribed applicable laws and regulations. Notification of any changes in the Privacy Policy will be posted accordingly. Any changes in the Privacy Policy will apply to personal information collected from the date of the posting of the revised Privacy Policy.
Last Revised May 2024
