IBAO PRIVACY POLICY
At the Insurance Brokers Association of Ontario (“IBAO”), we respect the privacy rights of individuals and handle the personal information that we receive in accordance with this Privacy Policy. While the majority of information that we collect is business information about our members, we do occasionally collect personal information, for example, when we respond to requests we receive from the general public for information about our organization and industry.
This Privacy Policy is designed to inform you of the policies and practices we have put in place to manage personal information that we receive. We encourage you to read this Privacy Policy so that you can better understand how we collect, use, share and protect your personal information.
What is Personal Information and What do We Collect?
Personal information is any information about an identifiable individual. As noted above, most of the personal information collected by the IBAO consists of membership information. Our membership records are comprised of our members’ names, brokerage business addresses, telephone numbers, email addresses, members’ RIBO numbers, members’ registered courses, designations, event attendance, birthdate, and gender information. Those members who register for our educational programs are asked for personal contact information in order for us to provide examination results to them in a confidential manner.
Information that we may collect from the general public includes name, address, telephone number and email address.
Consent
IBAO will, in most instances, obtain express consent to collect, use or disclose personal information. The method by which the consent will be obtained will be applicable to the type of personal information being collected, used or disclosed. IBAO will obtain express consent (verbal, written or electronic) to collect, use or disclose sensitive personal information such as personal financial information.
IBAO will rely on implied consent to collect, use or disclose your personal information in situations where you may reasonably expect us to require your personal information in order to provide services to you.
We obtain your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will advise you of that purpose before such use or disclosure.
Where we have obtained your personal information from third parties who have collected it in the course of performing a service for us or otherwise, we will take reasonable steps to ensure that such third parties have your consent to disclose your personal information to us and for us to use the information for purposes as we require and for which you have consented.
We may collect information about you without your knowledge or consent where permitted or required to by applicable law.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer in writing using the contact information below. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.
Use of your Personal Information
We may use your personal information for the following purposes:
- To communicate with you about our programs and services;
- To provide you with information about industry changes;
- To provide you with information about our Board and committee activities;
- If you are an IBAO member, to register you for programs and to manage your membership with us, including to send invoices and statements to you for membership dues;
- To aggregate data and identify general trends;
- To respond to your enquiries; and
- Other purposes that are permitted under applicable law.
- With our regional affiliate associations who use this information to verify which brokerage members fall under their respective territories;
Feedback and Suggestions
The IBAO encourages you to provide feedback, questions, comments and suggestions to us on our Website and programs. Any such information submitted by you to the IBAO shall be deemed to be non-confidential. The IBAO shall have no obligation of any kind with respect to such information and shall be free to reproduce, use, disclose and distribute the information to others without limitation. Additionally, the IBAO shall be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose whatsoever, including but not limited to developing, manufacturing and marketing products incorporating such information. However, the IBAO will not use your name or otherwise publicize the fact that you submitted materials or other information to the IBAO unless: (a) we ask your permission to use your name; or (b) we first notify you that the materials or other information you submit to a particular part of this site will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Disclosure
We may share your personal information with our regional affiliate associations who use this information to verify which brokerage members fall under their territory; with IBAC who uses this information to verify graduates from IBAC designation programs, as well as with our database technology providers, and other third parties who require such information to assist us with managing our relationship with you and providing services to you (collectively, “Service Providers”). Some of these Service Providers may be located in jurisdictions outside of Canada where the laws of the jurisdiction may provide for a different level of protection for personal information than is provided under Canadian laws and while the information is situated in such other jurisdictions it may be accessed by the courts, law enforcement and national security authorities. If you would like further information about our use of any Service Providers located outside of Canada, please contact our Privacy Officer at the address listed below.
Except as we have described above and except as permitted under applicable law, the personal information that we collect is not otherwise shared with any third party, nor do we sell or rent any mailing or email lists to third party vendor companies.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
Information Gathered Through Our Website
IBAO gathers certain information about visitors to its Website. This information includes the type of internet browser and operating system you are using, IP (Internet Protocol) addresses and other related information such as page requests and average time spent on our website. Please note the information will only be gathered while the visitor is on the site. No information is gathered about other third-party sites the visitor has accessed. The information collected is analyzed to help us understand trends and patterns, and to improve the content, design and user experience.
In certain sections of the site, IBAO may invite you to contact us, request information or complete a registration form. In these cases, we request contact and other related information. If you choose to provide this information, we will use it only to contact you as requested, or to register you to access certain sections of our website or for specified events.
Cookies: Our website uses a technology called “cookies”. A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. You may set your web browser to notify you when you receive a cookie. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the features of our website.
Tracer Tags & Web Beacons: Some areas of our websites may also use “web beacon” technologies. Web beacons work in conjunction with cookies and let us know what portions of our site are of interest to our visitors and to help us provide you with tailored information from our website. If you turn off cookies, web beacon technologies will still detect anonymous visits, but the notices they generate cannot be associated with other information that is collected and are disregarded.
Third-party links: Our website may contain links to other sites that IBAO does not own or operate. Also, links to our website may be featured on third-party websites on which we advertise. Except as described in this Privacy Policy, we will not provide any of your personal information to these third parties without your consent. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites and therefore we have no responsibility in respect of them.
Security of Your Personal Information
The IBAO maintains physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
You are responsible for maintaining the confidentiality of any password(s) you are given to access our Website, and are fully responsible for all activities that occur under your password(s). You agree to notify the IBAO immediately of any unauthorized use of your password(s).
Electronic Marketing Messages
We may send you information about product and services that we believe may be of benefit to you. Where applicable, we rely on our existing business or non-business relationship with you to send these marketing messages electronically. If we do not have an existing business or non-business relationship with you, we will obtain your opt-in consent to send these marketing messages to you, unless we are otherwise permitted to send the message under applicable law. You may opt out of receiving these marketing messages at any time.
Retention of Your Personal Information
IBAO only retains your information for as long as necessary to fulfill the purpose for which it was originally collected or as required by law, in accordance with its records retention policies.
Access to your Personal Information
IBAO strives to keep your personal information accurate, up to date and relevant for its intended use. You can assist us by updating your personal information with us (e.g. change of address) as changes occur.
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Member Services department, and if our Member Services department is unable to help you, please contact our Privacy Officer in writing using the contact information below.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you an administration fee to access your personal information; however, we will advise you of any fee in advance. We will respond to your request within 30 days.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with the requested access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Updating your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information changes, please inform our Member Services department at membership@ibao.on.ca.
In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
If our Member Services department is unable to help you, please contact our Privacy Officer using the contact information below.
Accountability
We have appointed a Privacy Officer to oversee compliance with our privacy obligations and commitments. For more information about this Privacy Policy and how we handle personal information, please contact our Privacy Officer, Brett Boadway, at 416-488-7422 or toll free at 800-268-8845.
Respecting and Responding to Your Privacy Concerns/Complaints
Your privacy concerns matter to us. If you have any questions or concerns about your privacy rights or how we manage your personal information, please contact our Member Services department using the contact information provided above.
We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If our Member Services department is unable to help you, please contact our Privacy Officer using the contact information provided below. If, after following these procedures, you remain dissatisfied with our response, you are entitled to make a written submission to the Privacy Commissioner of Canada using the following methods:
| Office of the Privacy Commissioner of Canada (OPCC) | |||
| Phone | 1 800 282 1376 (toll-free) | Fax: 1 819 994 5444 | TTY: 1 819 994 6591 |
| Website | www.priv.gc.ca | ||
| Mailing Address | Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, QC K1A 1H3 |
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Changes to Privacy Policy
From time to time, IBAO may make changes to our Privacy Policy to reflect changes in our legal or regulatory obligations, or in the manner in which we deal with your personal information. Any changes that affect your rights will be communicated to you via this statement and posted on our website. We encourage you to refer back to it on a regular basis.
Disclaimer
This Privacy Policy does not create or confer upon any individual any rights, or impose upon IBAO any obligations outside of, or in addition to, any obligations imposed by Canada’s federal privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
Date: Last revised November 19, 2019