Protection of personal information

Stroud Agencies (“the “Company”). The Company is committed to protecting the Company’s clients’, employees’ and representatives’ (the “Individual/s”) privacy, and to ensuring the confidentiality of the personal information provided to it while the Company is in business.

The Company’s Privacy Policy sets out the Company’s standards for collecting, using, disclosing and storing the Individual’s personal information. The Company’s Privacy Policy also explains how the Company safeguards the Individual’s personal information and the Individual’s right to access that information.

Personal Information

Personal Information is any information about an individual that identifies him or her, such as financial, lifestyle or health information, but not their name, title or business address, telephone or email.

Personal information must be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized or any other form.

Purpose of Information Collection

Collecting information about the Individual is necessary for the Company to provide the Individual with highest quality of services. The nature and sensitivity of the information the Company collects about the Individual varies according to the services the Company provides the Individual, and to legal requirements imposed on it (such as the Individual’s social insurance number, where investment income is generated by a chosen product).

The purposes for which the Company collects personal information about the Individual 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 the Individual’s identity, protecting against fraud, or dealing with matters concerning the relationship between the Company and the Individual.

Any questions and concerns the Individual may have regarding the purposes for collecting information may be directed to us at the address provided below.

Consent
When the Company collects personal information from the Individual, the Company obtains the Individual’s consent to use the information for the purposes collected. The Company will obtain the Individual’s consent for any additional use or collection, or if the purpose of using the information is changed.

The Company generally seeks the Individual’s express written consent to collect, use or disclose personal information. Where appropriate, for less sensitive information, the Company may accept the Individual’s verbal consent. Occasionally, the Company may imply consent where the Company can infer consent from the Individual’s action or inaction.

Consent must be given by the Individual or the Individual’s authorized representative such as a legal guardian or a person having power of attorney.

The Individual may withdraw the Individual’s consent at any time, subject to legal or contractual restrictions (for example, the Individual’s right to withdraw consent is necessarily limited where the Company needs information to extend a loan against the value of a policy issued by it). The Company will inform the Individual of the consequences of such withdrawal, including the possibility that the Company may not be able to provide a product or process a request. If the Individual chooses not to consent, the Company will record the decision in the Company’s file.

In limited circumstances, the Company has the right (or obligation) to collect, use or disclose personal information without the Individual’s 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 the Individual is a minor, seriously ill or otherwise incapacitated.

Limits to Collection, Use and Disclosure

The Company limits the collection of the Individual’s personal information to what the Company needs in relation to the purposes identified to the Individual.

The Company collects the information directly from the Individual unless the Individual allows the Company to collect information from a third party or in accordance with the law.

The Company limits the use of the Individual’s personal information to the purposes the Company has identified to the Individual. This means that the Company cannot use the Individual’s personal information for other purposes without the Individual’s consent, except as required by law.

The Company cannot disclose the Individual’s personal information to anyone except with the Individual’s consent or as required by law.

The Individual’s personal information is only accessible to certain authorized persons, and only to the extent necessary to perform their duties.

The Individual has the right to know, on request to whom the information was disclosed. Only in rare instances is the Company prevented by law from making such disclosure. The Company maintains accurate records, recording to whom it discloses personal information and in what circumstances the information was disclosed.

The Company will occasionally share the Individual’s personal information with service providers or agents to ensure the proper administration of products or to provide an Individual with the services the Individual requires. These service providers or agents must agree to comply with privacy legislation before receiving any personal information.

Retention
The Company only retains the Individual’s personal information for as long as needed for the purpose it was collected. The Company must destroy this information in accordance with the law and the Company’s file retention guidelines. When the Company destroys the Individual’s personal information, the Company makes sure that confidentiality is secured and that no unauthorized person can access the information during the destruction process.

Client List

The Company does not share or sell client lists to third parties.

Accuracy
The Company makes every possible effort to ensure that the Individual’s personal information is as accurate and complete as necessary for the purposes it is collected, used, or disclosed.

Accountability
The Company is responsible for the Individual’s personal information in the Company’s possession or control, including information that may be transferred by the Company to third parties for processing. The Company requires such third parties to keep personal information under strict standards of privacy and protection.

The Company adheres to legislated and self-imposed rules, aimed to safeguard the Individual’s privacy. The rules are established by this Privacy Policy, the Code of Business Conduct (applicable to directors, officers and employees), Market Conduct Standards (applicable to agents and brokers) as well as insurance industry guidelines and applicable law.

The Company’s staff is trained on these processes and procedures and is provided with information about privacy laws.

Safeguards
The Company has implemented and continues to implement rigorous safeguards so that the Individual’s personal information remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

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 operator access).

Request for Access to Information and Amendments

The Individual has the right to be informed whether the Company holds personal information about the Individual and to see that information. The Individual also has the right to inquire as to how the Company collected the Individual’s information, how the Company used it and to whom it may have been disclosed.

This information will be provided to the Individual within a reasonable time from the date the Company receives the Individual’s written request. The Company may charge a reasonable fee for processing the Individual’s request.

In certain limited and specific circumstances, the Company may refuse to provide to the Individual the requested information. Exceptions to the Individual’s 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 while an investigation of a potential breach of contract or fraud, and information that is subject to solicitor-client or litigation privilege.

In cases where the Company holds medical information about the Individual, the Company may refuse to provide the Individual with direct access to this information and may instead request that a health care professional be designated to provide the information to the Individual.

The Individual may challenge the accuracy and completeness of the Individual’s personal information. The Company 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:

Stroud Agencies
#304, 9945 – 50th Street

Edmonton, AB

T6A 0L4

Attention: Privacy Officer

Complaints and Concerns

The Company’s employees and representatives are trained to respond to the Individual’s questions or concerns about personal information. Should the Individual be unsatisfied with the Company’s employee's or representative’s response, the Individual may contact the Privacy Officer at the address mentioned above.

A complaint concerning the protection of personal information should be addressed to the Privacy Officer at the address provided above.