Privacy policy
SAGE Insurance and group retirement Personal information protection policy
1. Purpose of the policy
At SAGE Insurance and group retirement, we are committed to protecting the privacy of our clients, employees and agents, as well as ensuring the confidentiality of the personal information entrusted to us in the course of our activities.
Our Privacy Policy not only meets the requirements of the Act respecting the protection of personal information in the private sector, but also describes our standards for the collection, use, disclosure and retention of your personal information. This policy also explains how we protect your personal information and your right of access to it.
This document is updated on an ongoing basis to ensure that you are aware of changes to our privacy practices, as well as to unify these practices and comply with applicable laws. We encourage you to review this policy periodically for updates.
2. Scope
Inspired by industry best practices, SAGE Insurance and group retirement, the firm is committed to complying with the laws and regulations governing the protection of privacy and to protecting all confidential information it holds. All employees of SAGE Insurance and group retirement who collect, use or communicate personal information are required to comply with this policy.
SAGE Insurance and group retirement’s responsibility with regard to the protection of personal information also extends to its agents, service providers and partners who offer the same high level of protection to your personal information.
3. Personal information
Personal information is information that relates to a natural person and allows them to be identified, such as information about their financial situation, lifestyle or health 1 . It is confidential, that is to say it cannot be communicated without the consent of the person concerned.
Personal information must be protected regardless of the nature of its medium and whatever its form: written, graphic, audio, visual, computerized or other.
4. Purposes of collection of information
SAGE Insurance and group retirement, must collect information about you in order to provide you with high-quality services. The nature and sensitivity of the information we collect about you varies depending on the services we provide to you and the legal requirements we must comply with (such as your social insurance number if a chosen product generates investment income) 2 .
The purposes for which we collect information are usually to provide you with the products or services you have requested from us, confirm your identity, prevent fraud, or resolve issues regarding our relationship.
The purposes for which we collect your personal information are identified before or at the time of collection. For example, information is collected when you submit a proposal, open an account or file a claim for compensation.
If you have any questions or comments regarding the purposes for which we collect certain information, please contact us at the address below:
SAGE Insurance and group retirement
2500 rue Beaurevoir Entrance A Office 350 Quebec (Quebec) G2C 0M4
Bureau 418-622-8550 | Toll free 1 877-622-8550
info@sagedecision.com
sagedecision.com
Data Protection Officer
The Company has appointed a Privacy Officer who ensures compliance with the law, oversees privacy and security policies and practices, and is available to answer questions from employees and customers.
Norman Dickenson
Vice President, Claims, Property Management and Technology.
Email: norman.dickenson@essor.ca
T: 514 878-9373 ext. 30069
Office: 1100, Robert-Bourassa Blvd., 6th Floor, Montreal, Qc, H3B 3A5
5. Consent
When we collect personal information about you, we obtain your consent to use it for the purposes for which it was collected. SAGE Insurance and group retirement must obtain your consent to use your information for other purposes or to collect additional information about you.
Typically, we ask for your express written consent to collect, use or disclose your personal information.
For less sensitive information, we may, in some circumstances, accept your verbal consent. On occasion, we may, based on your actions or inactions, assume that you have given us your implied consent 3 .
Consent must be given by you or a duly authorized person such as a guardian or attorney.
You may withdraw your consent at any time, subject to legal or contractual restrictions. For example, your right to withdraw consent is necessarily limited if we need information to provide you with a loan against the value of a policy issued by us. We will inform you of the consequences of such a withdrawal of consent, including the possibility that we may not be able to provide a product or process your application. If you choose to withdraw your consent, we will record this in our records. Furthermore, we ensure that the records we hold are up to date and accurate at the time they are used 4 .
In some situations, we must or are required to collect, use or disclose personal information without your consent. This occurs when, for legal, medical or security reasons, it is impossible or impractical to obtain consent 5 . When information is collected to investigate a possible breach of contract, for the prevention or detection of fraud, or for law enforcement, obtaining consent may defeat the purpose of the information collection. In some cases, obtaining consent may be impossible or inappropriate if you are a minor, seriously ill or incapacitated.
6. Limitation of collection, use and communication
We limit the collection of your personal information to what is necessary for the purposes explained to you 6 . We collect personal information directly from you, unless you have consented to our collecting it from third parties or we are permitted to do so by law.
We use your personal information only for the purposes for which it was collected. This means that we cannot use your personal information for any other purpose without your consent, except as required by law.
When necessary, exclusively with your consent or if permitted by law, we may communicate your personal information to certain authorized parties for the proper management of your contract or to comply with regulatory and/or legal requirements, including:
- Your insurance representative
- Any reinsurer concerned
- Service providers and agents who need it to perform their contract or mandate and to ensure the proper administration of our products 7
- Legal or judicial authorities, when required by law, for example in cases of fraud or criminal activities.
Notwithstanding the foregoing, your personal information is only accessible to those persons authorized to access it and for whom it is necessary in the performance of their duties.
You have the right to know, upon request, to whom your information has been disclosed. Only exceptionally and in accordance with the law will we refuse to disclose this information. We keep accurate records of the persons to whom we have disclosed your information and the circumstances in which your information was disclosed.
We may, in certain circumstances, use service providers located outside of Canada, including the United States. We are responsible for ensuring that the service provider complies with our privacy policy and for ensuring that their level of protection is comparable to ours.
7. Conservation
We retain your personal information for as long as necessary for the purposes for which it was collected. We must destroy this information in accordance with the Act 8 . At all times, employees take security measures to ensure the protection of personal
information collected, used, communicated, retained, or destroyed and which are reasonable taking into account, in particular, its sensitivity, the purpose of its use, its quantity, its distribution and its medium.
The company implements anonymization methods where possible, particularly for sensitive data or when it is necessary to carry out studies, analyses or research without compromising the privacy of individuals.
When we destroy your personal information, we take steps to ensure its confidentiality and that no unauthorized person can gain access to it during the destruction process.
8. Use of personal information for promotional purposes
In order to offer you products and services that may meet your needs from time to time, to communicate special offers and advice to you and to serve you better, SAGE Insurance and group retirement may use the contact information you have provided (e.g. name, address, telephone number, email address, etc.) to contact you and may also share a list of its customers’ contact information with the other companies that make up SAGE Insurance and group retirement. You may opt out at any time by contacting us. This does not include communications about the product you hold and administrative communications necessary for the proper management of your file.
To meet legal requirements, we must obtain your consent so that the companies that make up SAGE Insurance and group retirement can use and share your personal information with each other for promotional purposes, in line with your expectations. Your information will be used to provide you with a personalized experience and to send you, from time to time, information, offers and advice tailored to your personal situation and interests.
SAGE Insurance and group retirement will not share your information with other companies unless we have obtained your prior consent or if the law allows it.
We will never use sensitive personal information such as your health status for promotional purposes without first obtaining your specific consent to do so.
You may at any time ask us not to use or share your personal information between the companies that make up SAGE Insurance and group retirement for promotional purposes by sending a written request to the person responsible for the protection of personal information at the address and contact information indicated at the end of this document.
If you do not consent to the collection, use and sharing of your personal information, we may not be able to provide you with the products and services you request to the extent you expect.
Please note that we do not sell our customer lists to third parties.
9. Accuracy and responsibility
We make every effort to ensure that your personal information is as accurate and complete as is necessary for the purposes for which it is collected, used or disclosed.
We are responsible for the personal information in our possession or custody, including information we provide to third parties for processing. We require these third parties to maintain this information in accordance with strict standards of confidentiality and security.
We adhere to the principles set out by law and the rules we have put in place for the protection of your privacy. These rules are set out in this privacy policy, the code of ethics (which applies to directors, officers and employees) as well as insurance industry guidelines and other applicable laws.
Our staff are informed and adequately trained on our privacy policies and practices.
10. Security measures
We have implemented and continue to develop rigorous security measures to ensure that your personal information remains strictly confidential and is protected against loss or theft and against any unauthorized consultation, disclosure, copying, use or modification.
These security measures include:
- Organizational measures (e.g. use of security certificates and restricted access to what is necessary);
- Physical measures (e.g. electronic management access to offices for employees, backup and archiving of data using an external system, etc.);
- Technological measures (e.g. use of passwords and encryption, frequent password changes, use of firewalls and segmented access operators, etc.).
We recommend that you use unique and strong passwords for your online accounts and that you do not disclose your passwords to anyone.
11. Request for access to information and rectification
You have the right to know whether we hold personal information about you and to view that information. You also have the right to request how we have collected your personal information, how we have used it and to whom it may have been disclosed.
This information will be provided to you within a reasonable time from the day we receive your written request.
In certain specific cases, we may refuse to provide you with the requested information. Exceptions to your right of access include, but are not limited to:
- It would be extremely costly to provide the requested information;
- This information refers to other people;
- This information may not be disclosed for legal, security or commercial proprietary reasons;
- This information was obtained in connection with an investigation into a possible breach of contract or to prevent or detect fraud;
- This information is protected by attorney-client privilege or litigation privilege.
When we hold medical information about you, we may refuse to share it with you directly and may ask that it be shared with a healthcare professional you have designated to share it with you.
You may verify the accuracy and completeness of your personal information and, if necessary, request its rectification. We will respond to any request for rectification within a reasonable time. Any request for access to information must be sent to the address at the end of this document.
12. Security incident
In the event of a security incident involving personal information, the SAGE Insurance and group retirement compliance department completes (for internal use) a security incident declaration report involving a breach of personal information (freely inspired by the one available on the website of the Commission d’accès à l’information du Québec).
Following this report, an assessment is carried out by the senior management of SAGE Insurance and group retirement to determine whether the nature of the incident requires a declaration to the provincial or federal organization responsible for the protection of privacy.
13. Limitation of liability
The use of technologies such as the Internet involves significant risks. As a result, it is impossible to guarantee that the personal information you provide is completely secure. However, rest assured that SAGE Insurance and group retirement implements all reasonable means at its disposal to protect your data.
Consequently, you acknowledge that SAGE Insurance and group retirement and its suppliers cannot be held responsible for any damages or harm that may arise or result, directly or indirectly, from a breach of the confidentiality of data and/or information transmitted via the Internet to SAGE Insurance and group retirement.
14. Transparency, concerns and complaints
Our employees can answer your questions and concerns regarding the protection of your personal information.
To consult your file, to make a complaint regarding non-compliance with personal information processing procedures or to obtain more information about the Personal Information Protection Policy, contact us.
1. Article 1, LPRPSP, P-39.1
2. Article 4, LPRPSP, P-39.1.
3. Article 14, LPRPSP, p-39.1.
4. Article 11, LPRPSP, P-39.1.
5. Articles 18 to 23, LPRPSP, P-39.1.
6. Article 5, LPRPSP, P-39.1.
7. These service providers or agents undertake to comply with the legislation concerning the protection of personal information before any personal information is transmitted to them.
8. Article 10 and 12, LPRPSP, P-39.1.
