Bruce A. Hollett & Associates Privacy Policy

In the life insurance business, we collect highly sensitive personal information concerning our clients' health, lifestyles and finances. As the success of our business depends upon obtaining and maintaining the trust of our customers, they must be assured that the personal information they provide to us will be maintained in the strictest confidence. 

This document therefore sets out the policy of Bruce A. Hollett & Associates, 101 – 346 Lawrence Avenue, Kelowna, BC  V1Y 6L4 in respect of the protection of the personal privacy of its clients and employees.

Personal information is defined as information concerning an identifiable individual. This includes, but is not limited to, all information concerning group and individual policyholders, lives insured, beneficiaries, employees and brokers, particularly information concerning their health, finances and lifestyle. The information may be in any form, including correspondence, memoranda, electronic communications, video or audio recordings, photographs or any other documentary material, regardless of its physical form or characteristics. 

Personal information does not include the name, title or business address, telephone number or e-mail address of employees. 

1. Accountability 

Bruce A. Hollett & Associates is responsible for personal information in its possession or control.

All employees are obligated to protect the personal privacy of group and individual policyholders, lives insured, and beneficiaries with regard to any and all personal information obtained by Bruce A. Hollett & Associates. They are expected to follow the letter and spirit of this policy, as well as any specific procedures set out for the area in which they work. 

The compliance function is accountable for Bruce A. Hollett & Associates’ adherence to this policy and the applicable statutes, regulations and guidelines that deal with the protection of personal privacy. 

If appropriate, each division will implement procedures to give effect to this policy. Staff will be adequately trained and provided with information about the privacy laws that affect the company, and the company's policies and procedures. 

2. Identifying Purposes 

The purposes for which personal information is collected will be identified at or before the time the information is collected. This will generally be done through application or claim forms. 

Bruce A. Hollett & Associates will not collect, use, or disclose information beyond that required to fulfill the specified purposes. 

Persons collecting personal information must be able to explain to individuals the purposes for which the information is being collected. 

3. Consent 

The knowledge and consent of the individual, business or corporation are given by the submission of this personal, business and corporate information via the electronic median of e-mail over a protected and secure system.  This information will be protected by safequards appropriate to the sensitivity of the information. 

4. Limiting Use, Disclosure, and Retention 

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes, and shall be destroyed in accordance with Bruce A. Hollett & Associates’ Record Retention Policy. 

It should be noted that Bruce A. Hollett & Associates will not sell any client lists under any circumstances. 

5. Safeguards 

Personal information will be protected by security safeguards appropriate to the sensitivity of the information. As Bruce A. Hollett & Associates deals with highly sensitive information concerning the health and finances of our clients, this is of paramount importance. 

The security safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. 

The methods of protection will include: 

a.       physical measures (e.g. building security system, off-site backups, archiving);

b.       organizational measures (e.g. limiting access on a ``need-to-know'' basis); and 

c.       technological measures (e.g. the use of passwords). 

6. Openness

Bruce A. Hollett & Associates will make readily available to individuals specific information about its policies and practices relating to the management of personal information. 

The information made available shall include 

1.  the name or title, and the address, of those accountable for Bruce A. Hollett & Associates' policies and practices and to whom complaints or inquiries can be forwarded;
      

2. the means of gaining access to personal information held by Bruce A. Hollett & Associates; 
      

3. a description of the type of personal information held by Bruce A. Hollett & Associates, including a general account of its use; and
      

4. a copy of this policy and any brochures or other information that explain or elaborate upon it.

7. Individual Access

Upon request, an individual will be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Bruce A. Hollett & Associates will respond to an individual's request within a reasonable time and at minimal or no cost to the individual. 

The requested information will be provided or made available in a form that is generally understandable. For example, when abbreviations or codes are used, an explanation will be provided upon request. 

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Bruce A. Hollett & Associates will amend the information as required. 

8. Challenging Compliance

An individual may address a challenge concerning compliance with this policy.

Bruce A. Hollett & Associates will investigate and respond to all complaints in accordance with the applicable departmental complaint handling protocol. If a complaint is found to be justified, Bruce A. Hollett & Associates will take appropriate measures, including, if necessary, amending its policies and procedures.