Privacy

Morgex Insurance has made a commitment to respect the privacy rights of individuals by ensuring that their personal information is collected, used and disclosed in a manner that a reasonable person would consider appropriate in the circumstances.

The federal Personal Information Protection and Electronic Documents Act (PIPEDA) began to apply to certain businesses and apply to all insurance brokerages as of January 1, 2004. This information is based on principles and rules of that ACT.

Accountability

Our commitment is to:

• Protect personal information
• Allow individuals to request information, seek amendments to their personal information; and file complaints against Morgex Insurance with our Privacy Officer
• Train and educate staff
• Develop information, which explains those procedures to our Clients and to the public.

We will use reasonable means to ensure that client personal information is given a level of protection while being processed by a third party. If not practical to obtain written authorization, we may choose to make a written notation in our own files.

Identifying Purposes

We will identify the purpose for which we collect personal information at or before the time the information is collected.
We may choose to identify such purposes verbally or in writing. Written notification will be used whenever practical to do so. This information itself may be used to identify such purposes. Common purposes for collection include:

• Offering and providing insurance and related products and services to you
• Establishing and maintaining communications with you
• Verifying your identity and the accuracy of your Personal Information with government agencies, industry associations, insurers and other brokers
• Analyzing, assessing and underwriting risks on a prudent basis
• Determining and facilitating your payment of fees and premiums
• Investigating and settling of claims
• Detecting and preventing fraud or other illegal activities
• Compiling statistics
• Complying with the law or the requests of law enforcement agencies or regulators
• Notifying you or allowing our affiliated companies to notify you of certain products or service offered by our affiliated companies

We may choose to verbally explain to clients the purposes for which personal information is collected, and then pace a note in the client's file indicating that this has been done. Alternatively, an application form may be used.

Consent

Morgex Insurance may obtain consent for the collection, use, or disclosure of client's personal information or we may determine that consent has been implied by the circumstances.

Express consent is a specific authorization given by the individual to Morgex Insurance, either verbally or in writing. Implied consent is one which Morgex has not received a specific authorization but the circumstances allow us to collect, use or disclose personal information (ie. Receipt of premium implies coverage has been accepted).

Express written consent includes a client:

• Signing a consent form (such as the Personal Information Consent)
• Providing a letter, application form or other document authorizing certain activities
• Providing an authorization electronically (through a computer).

Express oral consent can be given in person or over the telephone. If we obtain an express oral consent, we will normally make note of that consent in the client's file.

We will often seek express oral consent at the onset of a new business relationship. However, we may determine that by an individual seeking insurance coverage through our organization, consent has been implied for us to collect, use and disclose personal information within a reasonable manner.

Subject to legal exceptions, consent may be withdrawn at any time. We generally require such withdrawal to be in writing. There may be serious consequences to failing to provide or withdrawing consent, such as Morgex Insurance's inability to acquire or renew an insurance policy and/or cancellation of a policy.

We do not consider a regular updating of information in a client's file to be a new purpose, therefore Morgex will not seek a new consent for this purpose.

Exceptions:
There are circumstances that we are not required to obtain an individual's consent or explain purposes for collection, use or disclosure of personal information. These include however are not limited to the following:

• We may collect, use and disclose personal information without consent where it is in the individual's interest and timely consent is unavailable, or to investigate a breach of an agreement (such as insurance fraud) or a contravention of law.
• We may use personal information without consent for law enforcement and national security purposes, for debt collection, to a lawyer representing our organization, and in an emergency situation in which an individual?s life, health or security is threatened.

Limiting Collection

The personal information we collect will be limited to that which is necessary for the purposes we have identified.

• We only collect personal information for specific and legitimate purposes.
• We will only collect information by fair & lawful means and not by misleading or deceiving individuals about the purpose for which information is being collected.
• We may need to obtain information about clients from third parties, for example a client's driving record, etc.

Limiting Use, Disclosure and Retention of Information
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. We will only retain personal information as long as necessary for the fulfillment of those purposes. Personal information that is no longer required to fulfill identified purposes will be destroyed, erased, or made anonymous.

Accuracy

The personal information we collect will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

• Morgex Insurance will on an ongoing basis, ensure the accuracy and completeness of personal information under our care and control.
• Individuals who provide their personal information to us must do so in an accurate and complete manner.
• We consider a regular updating of client personal information to be necessary to ensure accuracy of client files and to provide appropriate insurance coverage for clients.
• Our goal is to minimize the possibility that inappropriate information may be used to make a decision about any individual whose personal information we process.
• The process for ensuring accuracy and completeness will involve the initial collection of personal information from a client, accuracy and completeness of information provided by the client, regular reviews with the client and verifying accuracy by contacting third parties (e.g., motor vehicle and driver licensing authorities)

Individual Access

Upon written request an individual will be informed as to whether or not we hold personal information about him or her. If we do hold such personal information, upon written request, we will provide access to the information, as well as a general account of its use. If there is a large volume of information in varying formats (e.g., hard copy or electronic) we may choose to provide a summary of the information that is on hand. Written request may be made to our Privacy Officer:
Liana Blais
11120 - 178 Street
Edmonton, AB
T5S 1P2
Direct: (780) 732-6785
Fax: (780) 453-2814
Email: liana.blais@morgex.com

The procedure for making a request is as follows:

1. All requests must be made in writing using a form as the Request/Complaint Form.
2. We will respond to a request within 30 days after receipt of the request, unless we first advise you that we need a longer period to respond.
3. Reasons-if we refuse a request, we will inform the individual in writing of the refusal, explaining the reasons and any recourse the individual may have, including the possibility that they may file a complaint with the Privacy Commissioner of Canada.
4. Deemed Refusal-Notwithstanding sub-paragraphs 2. and 3. above, if we do not respond within the above time limit, we will be deemed to have refused the request.
5. Costs for responding-Morgex Insurance may require payment of a modest fee to cover our administrative costs associated with preparing a response.

Exceptions preventing Morgex Insurance from providing access, include where:

• Personal information about another person might be revealed
• Commercially confidential information might be revealed
• Someone?s life or security might be threatened
• The information was collected without consent for the purposes related to an investigation of a breach of an agreement or contravention of the law
• The information was generated during the course of a formal dispute resolution process

Challenging Compliance

An Individual may address a challenge concerning compliance with the above policies and procedures to our Privacy Officer. Upon request, individuals who wish to inquire or file a complaint about the manner in which we handled their personal information-or about our personal information policies and procedures-will be informed of our applicable complaint procedures. To file a complaint, an individual must fill out a Request/Complaint Form, which requires basic information and a description of the nature of the complaint. Our Privacy Officer will acknowledge the complaint immediately after its receipt and will assign someone to investigate it. We will clarify facts directly with the complainant, where appropriate and written outcome of our investigation, including any steps taken to rectify the problem, if applicable.