PRIVACY AND CONFIDENTIALITY STATEMENT
The General Insurance OmbudService (GIO) is committed to respecting the personal privacy of each individual who uses our service. GIO is an independent not-for-profit corporation, created in 2002, with the purpose of helping Canadian consumers resolve disputes or concerns with their home, automobile or business insurers.
YOU are important to us
What Personal Information We collect.
When you submit a complaint, we collect information relating to it from you, the insurer, and others that may be involved. This may include your name and contact information, your age and date of birth, gender, family status, medical and health information, occupation, income, assets, liabilities and payment records, information on previous insurance records and claims, driving record, and the nature of and facts associated with your complaint.
When you visit our site, we may use technologies such as cookies to collect IP address, operating system, browser type, language preference, whether you are a new or returning visitor, device type, pages visited, the time spent on those pages, access dates and times, clicks, and general location derived from IP address, how the site is accessed, and demographics.
How we Use the Personal Information we collect.
We use the information we collect to investigate and facilitate the resolution of your complaint, to communicate with and respond to you, to manage, administer, and maintain our operations, to investigate and settle disputes or security breaches, and for legal reasons.
We use information we collect using technologies to analyze web traffic, to understand what portions of our site people visit, to improve our website in order to better tailor it to user needs. We also use this information for statistical analysis purposes.
How we share the Personal Information we collect.
We may share personal information with service providers that help us process it, and with other Industry OmbudServices to investigate a complaint, including the OmbudService for Life & Health Insurance. Otherwise, all personal information is anonymized when reported externally. No consumer or member company could be identified through any of our external reports.
You have the choice whether you wish to proceed with any complaint you submit. You may also deactivate some of our analytics tools as we describe in “How we Collect and Use Information Using Technology”, below.
What Personal Information We Collect
With your consent, we collect, use and disclose personal information from you, the insurance corporation that is the subject of your complaint, other organizations or individuals involved in your complaint, (such as insurance brokerages, adjusters, and service providers), and others to investigate and facilitate the resolution of your complaint.
The types of personal information collected, used and disclosed will depend on the nature of your complaint, but may include your:
- telephone number;
- other contact information such as email address;
- age and date of birth;
- family and marital status;
- medical and health information;
- assets, liabilities, payment records;
- previous insurance records and claims experience;
- driving record; and
- the nature of and facts associated with your complaint, including your and your insurer’s position and submissions in relation your complaint, and whether your complaint is the subject matter of which is being investigated by any other entity or regulator.
How we Use and disclose the Personal Information We Collect
We may use and disclose your personal information in the following manners:
- To assess and seek to resolve your complaint in accordance with our Terms of Reference for Dispute Resolution. Depending on the process of your complaint under our Terms of Reference, this may include informal conciliation with your insurer, mediation, and if conciliation and mediation do not resolve the matter, adjudication.
- To communicate with you and your insurance company regarding your complaint and its assessment and resolution. For example, as your complaint progresses, you may be contacted by the mediator or adjudicator.
- To manage, administer, and maintain our operations.
- To respond to your questions or complaints.
- To investigate and settle any dispute or claim which relates to our site or services.
- To investigate security breaches or cooperate with government authorities pursuant to a legal matter.
- To comply with applicable laws and regulations.
To review your complaint, GIO may need to ensure it has received appropriate consents and/or authorization forms concerning the release and treatment of confidential information from all necessary parties and any other agreements or releases that GIO considers appropriate in the circumstances.
If your complaint proceeds to adjudication, and your insurance company does not accept the non-binding recommendation(s) of the adjudicator, but you do, GIO may make a non-identified general description of complaint, suggested resolution, and the fact that the insurer refused to follow it public.
We may use and disclose personal information to cooperate with other Industry OmbudServices in the investigation of a complaint, including the OmbudService for Life & Health Insurance, and any other ombuds entity participating in the Financial Services OmbudsNetwork, where we deem that subject matter of a complaint is one in which another Industry OmbudService has expertise and if you and your insurer consent.
We may share your personal information with third parties that help us use your personal information for the purposes described in this Privacy and Confidentiality Policy. For example, we may share personal information with service providers that assist us with the activities described in this Policy, such as delivery companies, or companies that help us run our website.
We reserve the right to transfer any personal information if we enter a corporate transaction or reorganization, such as if we merge with or are acquired by a third party, or if any such transaction is proposed.
We may also disclose personal information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; or (iii) to protect our rights, safety or property, or those of a third party.
Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
We may also anonymize, aggregate or otherwise strip any personal information or other information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purposes we deem appropriate. For example, GIO may use the information it possesses for the purposes of statistical reporting. When information is collected or used for statistical reporting, it will not identify the individual or any information specific to an individual.
How we Collect and Use Information Using Technology
Our website uses Google Analytics, which is a web analytics service that provides statistics and analytical tools. We use Google Analytics on our website to analyze how users use the website, and to and report on activities and trends. Google Analytics may collect information such as general location as inferred from IP address, the amount of time a visitor spends on our website, which pages are more frequently accessed, how the website is accessed (either directly, a search engine, or from a link), what sort of software is used (e.g. operating system, browser type, etc.), as well as demographics. For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners/. For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.
You can also choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our website may permit or facilitate interactions with other interactive third-party websites or services (“Social Media”), such as enabling you to “like” or “share” content. If you choose to share content or otherwise post information from or via our website to Social Media, that information may be public and the third party may have access to information about you and your use of our websites. We are not able to control, and are not responsible for how such third parties may use your information.
How we Protect Personal Information
Proper documentation and compliance with GIO complaint protocol must be followed before the mediator can have access to your personal information.
In order to help prevent unauthorized access or disclosure of personal information, we have put in place physical, electronic and managerial procedures to help safeguard and secure the personal information we collect.
Personal information may be accessed by persons within GIO, the other organizations we describe in this Privacy and Confidentiality Statement, and our third-party service providers, who require such access to carry out the purposes described in this Privacy and Confidentiality Statement, or otherwise permitted or required by applicable law. Personal information we collect is managed from our offices in the Toronto Region.
Even though we have taken steps to help protect the personal information in our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.
We may Transfer Personal Information to Other Countries
Personal information that we collect may be stored and processed in Canada or any other country in which we or our service providers maintain facilities, including in the United States. Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.
By using our site or by providing us with personal information, you consent to any such transfer of information outside of Canada. If you have any questions regarding our use of service providers outside of Canada, you may contact us using the contact information we provide below.
Links to other websites
Our site may contain links to other websites operated by third parties. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide or that is collected when you visit such third-party sites and such sites are not governed by this Privacy and Confidentiality Statement. You should exercise caution and look at the privacy statement applicable to each website you visit.
Your submission of a complaint or other personal information to GIO is your choice. At each stage of the complaint procedure, for example, moving from conciliation to mediation, or mediation to adjudication, you have the choice whether or not to proceed.
Accessing and Correcting your Personal Information
You have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal information GIO has about you, or if you would like to have it corrected, please contact us using the contact information provided below. In some cases, we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons.
To help protect against fraudulent requests for access to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your personal information.
GIO does not typically collect personal information directly from children. However, if your complaint relates to your minor child, the we may collect and process personal information regarding your child in the manner we describe in this Privacy and Confidentiality Statement.
If you have any questions regarding this Privacy and Confidentiality Statement, any personal information you have submitted to us, or if you would like to:
- access personal information that you have already provided to us so that you can correct or update it; or
- to submit a complaint
You may contact us at:
General Insurance OmbudService
4711 Yonge Street, 10th Floor
Toronto, Ontario M2N 6K8