Privacy Policy

I. Introduction

The Dominion of Canada General Insurance Company ("The Dominion") is committed to providing excellent customer service. To meet your insurance needs, The Dominion must collect, use and disclose personal information. The Dominion respects your privacy and the integrity of your personal information.

This Privacy Policy outlines The Dominion's responsibilities and commitments to protect your personal information. In particular, the Policy addresses:

• the purposes for which we collect, use and disclose personal information;
• the nature of the personal information we collect, use and disclose;
• when and why The Dominion collects personal information;
• the meaning of implied and express consent to collect, use and disclose personal information and when consent is not necessary;
• how The Dominion uses and discloses personal information; and
• your ability to access your personal information held by The Dominion.

II. Legislation

Federal legislation known as the Personal Information Protection and Electronic Documents Act and similar provincial legislation ("privacy legislation") govern The Dominion's collection, use and disclosure of personal information. The Dominion has practices and procedures that satisfy the standards set out in privacy legislation.

In accordance with privacy legislation, The Dominion follows ten Fair Information Principles.

1. Accountability. The Dominion's Privacy Officer is accountable for The Company's compliance with these ten Fair Information Principles.
2. Identifying Purposes. Where required, The Dominion will explain why the collection of personal information is necessary.
3. Consent. The Dominion relies on your consent prior to collecting, using or disclosing your personal information. Exceptions arise where use or disclosure is required or permitted by law - for example, in the course of a criminal investigation.
4. Limiting Collection. The Dominion collects the personal information necessary to administer insurance policies and fulfil the insurance contract.
5. Limiting Use, Disclosure and Retention. The Dominion will not use or disclose personal information for a reason other than the purpose for which it was collected. The Dominion will retain personal information only as long as necessary to fulfil the purposes for which it was collected and as required by law.
6. Accuracy. The Dominion makes best efforts to monitor and update the accuracy of personal information as needed to provide insurance coverage and respond to claims.
7. Safeguards. The Dominion takes steps to safeguard personal information by using safe storage procedures and technological measures which limit access to the information to authorized employees. Where personal information is disclosed to third party service providers, The Dominion requires the service providers to also protect the personal information.
8. Openness. The Dominion's Privacy Policy is readily accessible on The Dominion website. On request, a printed copy will be provided.
9. Individual Access. The Dominion recognizes your right to access your personal information held by The Dominion. If access must be denied, according to privacy legislation, The Dominion will provide an explanation for the denial.
10. Addressing Privacy Concerns. The Dominion's Privacy Officer welcomes enquiries about our Privacy Policy and privacy practices.

III. What is "Personal Information"?

Personal information is defined in legislation as information about an identifiable individual, excluding the name, title, business address or telephone number of an employee of an organization. Some examples of personal information The Dominion may collect include your address, date of birth, e-mail address, medical history or driving record.

IV. When and Why The Dominion Collects Personal Information

A. Brokers Collect Personal Information
All consumers who purchase insurance (or consider purchasing insurance) from The Dominion do so with the guidance and assistance of a professional, licensed and independent insurance broker. The broker collects your personal information to assess your insurance needs. The broker may recommend that you consider a number of products from different companies. In order to recommend products, the broker provides insurance companies with your personal information. The broker will explain that this exchange of personal information is necessary for insurers to assess your risk profile and provide an accurate quotation regarding the cost of the policy being considered.

The information collected by the broker will depend on the insurance coverage you want. Some examples are provided below to explain the type of information necessary to provide automobile and property insurance.

B. The Collection of Personal Information for Automobile Insurance
If you want to purchase automobile insurance, provincial governments require that you provide information requested on the Automobile Application form. This application form is used by all insurance companies and is approved by provincial insurance regulators. The Automobile Application form varies from province to province, but all provincial governments gather similar information, such as your name, address, how the vehicle will be used, and the applicant's and listed drivers' accident history and history of convictions arising from operating an automobile. In some provinces you will be required to answer questions about your health, with respect to your ability to safely operate a vehicle.

C. The Collection of Personal Information for Property Insurance
To provide property insurance, insurance companies require personal information such as your date of birth and occupation, your past experience renting and owning property, as well as information regarding the property. Where there is a mortgagor or any other person with a legal interest in the property, you must disclose this information. Also, The Dominion may require a home inspection for underwriting purposes, to be completed by a professional and independent firm, to ensure the property is adequately protected.

V. How The Dominion Uses and Discloses Personal Information

The Dominion uses and discloses the personal information collected for various purposes:

• to assess an application for property and casualty insurance coverage;
• to communicate with a customer regarding an insurance policy;
• to confirm information provided by a customer or claimant, including verifying identity;
• to evaluate and settle a claim;
• to detect and prevent fraud;
• to offer and provide products and services to meet customer needs;
• to analyze risk and business results; and
• as may be required or authorized by law.

Additional examples of The Dominion's use and disclosure of personal information are provided below.
The Dominion may verify the accuracy of information provided on any application for insurance. For example, The Dominion may check driving records or claims history. Where the information is incorrect, The Dominion may decline the application for insurance. Also, as part of the underwriting and claims handling process, The Dominion transfers personal information to other insurance companies to verify the accuracy of information provided in the application for insurance or to help identify insurance fraud.

Unfortunately insurance fraud is a reality that leads to higher insurance premiums for everyone. Where circumstances suggest a false or misrepresented claim or policy application, we will conduct a careful investigation that adheres to legal and other guidelines. Such verification and investigation are in the best interest of all consumers as it operates as a check on the accuracy of information, helps identify and prevent fraud and ensures that policyholders pay the appropriate premium based on the risk they represent.

When a claim arises, The Dominion uses personal information to investigate the claim, assess damages and make the appropriate payments. If there is a lawsuit, The Dominion may need to share personal information with its legal counsel.
The Dominion may use your personal information to conduct a satisfaction survey following a claim, to ensure we meet our high standards of customer service.

The Dominion may use personal information to conduct statistical studies on information pertaining to groups of policyholders to improve our understanding of claim trends, price adequacy and financial results and forecasts. The Dominion may also use aggregate data to conduct statistical studies. For example, we may analyze claims data to determine the proportion of accidents involving vehicles in one area compared to another.

The Dominion is required by various provincial statutes to provide information regarding automobile applications, claims and premiums to provincial insurance regulators or to an appointed statistical agency. Such data is used by regulators to conduct statistical studies and research. This provides regulators with a better understanding of consumers' experiences with insurance.

The Dominion may transfer your information to service providers who may process or store your information in the United States. The Dominion remains accountable for your information and measures are taken to ensure service providers meet stringent security and confidentiality requirements, however, such information is subject to the laws of the United States and may be accessible to law enforcement and national security authorities of the United States.

The Dominion never sells personal information, or other information relating to you, to any organization, including charities or direct marketing groups.

VI. Consent

A. Implied Consent
Consent to collect, use or disclose personal information can be implied or express. Implied consent is inferred from the circumstances, including the relationship between the parties and the nature of the interaction. For example, when you contact an insurance broker to obtain automobile or property coverage, it is reasonable for the broker to presume your implied consent to share personal information with the insurer so that together they can assess and meet your insurance needs. Similarly, it is reasonable for the insurer to presume your implied consent to disclose your personal information to your broker, in order to assess your application or administer your insurance policy.

B. What is Express Consent?
When The Dominion handles sensitive personal information, The Dominion obtains express written or verbal consent. Sensitive information includes medical information or financial records for claims involving personal injury or income loss. In these circumstances, the sensitive personal information is not collected until a claim is made and it becomes necessary to obtain such information to determine entitlement to benefits. Express consent is obtained at the time of the claim.

C. Exceptions to Consent
Privacy legislation sets out situations in which consent to collect, use or disclose personal information is not necessary. Some examples of when it is not necessary for The Dominion to obtain consent include when the information is:

• disclosed to our lawyers;
• used to collect debts owed to us by policyholders; or
• used during an investigation of potential fraud, other policy breaches, or other illegal acts.

D. Withholding or Withdrawing Consent
You may withhold or withdraw your consent; however, this may affect The Dominion's ability to provide insurance or administer an insurance policy. Where the withdrawal or withholding of consent prevents The Dominion from providing adequate customer service, The Dominion may be unable to process your claim for payment or may cancel an existing policy. In some cases, we may be unable to honour the withdrawal or withholding of consent.

VII. Requests to Your Access Personal Information

You may request access to your personal information that has been collected, used or disclosed by The Dominion. To do so, please contact the Privacy Officer by letter or e-mail at the addresses set out below. Access requests must be in writing. We will reply to your request within 30 days.

Please note that email is not a secure mode of communication. For security reasons, do not include sensitive or confidential information in any email message.

Please note that The Dominion may charge reasonable costs in providing access to and copies of personal information and will inform you if such costs arise.

The Dominion may refuse an access request in situations where:

• such access would hinder an investigation relating to the enforcement of any law, including alleged fraud;
• the information is protected by solicitor-client and/or litigation privilege;
• to do so would reveal confidential commercial information - where possible, The Dominion will provide access after removing the confidential information;
• it is prohibitively costly to provide the information;
• the information contains references to other individuals - where possible, The Dominion will provide access after removing the references to other individuals; or
• the information was created in the course of a formal dispute resolution process, such as mediation or arbitration.

VIII. For Further Information

This Privacy Policy sets out The Dominion's commitment to safeguarding your personal information. The examples clarify The Dominion's practices with respect to the collection, use and disclosure of personal information, however, they do not represent a complete list of circumstances in which The Dominion collects, uses and discloses information to administer insurance policies.

The Dominion may update its Privacy Policy to adhere to changes in legislation or to improve service to our policyholders. Please refer to our website for the current Privacy Policy or contact The Dominion's Privacy Officer.

If you would like more information regarding The Dominion's Privacy Policy and practices, please do not hesitate to contact the Privacy Officer.

	Telephone:	1-800-268-8447 (toll free) 416-362-7231 (Toronto area)
	Fax:	416-366-6229
	E-mail:	privacy@thedominion.ca
	Address:	Privacy Officer c/o The Dominion of Canada General Insurance Company 165 University Avenue Toronto, Ontario M5H 3B9