Respecting
your Privacy
In
this document, you and your mean the individual
who is a customer or potential customer of a member of the Sun Life Financial
group of companies in Canada and we, us and our
mean the members of the Sun Life Financial group of companies in Canada, who
include Sun Life Financial Inc., Sun Life Assurance Company of Canada, Sun Life Financial Trust Inc., Sun Life Financial Advisory Inc., Sun Life Financial Realty Advisors Inc., Clarica Financial Services Inc., Clarica Investco Inc., and other affiliates of Sun Life
Assurance Company of Canada, in Canada.
Our
commitment to protecting your privacy, our policy
Collecting
personal information about you is essential to our ability to offer you high-quality
investment, retirement and insurance products and to provide you with on-going
service relating to your lifetime financial needs. We take great care to keep
your personal information which we collect accurate, confidential and secure.
Our
Policy sets high standards for collecting, using, disclosing and storing
personal information. Sun Life Financial's Canadian Privacy Policy is complemented
by our Privacy Code and by procedures to manage your personal
information.
If you have
any questions about Sun Life Financial's Canadian Privacy Policy and Privacy
Code, please contact our Canadian Privacy Officer at (416) 408-8850 or by email
at "privacyofficer@sunlife.com".
How
we collect, use and disclose personal information
We will protect your personal information
Your right to access your personal information
For more information
We ask you for only the
information we need
We collect only the information
we need for the purposes we have identified to you.
Our files are kept for the
purpose of providing and servicing financial and insurance products and services
that we believe are right for you, over your lifetime.
We will not sell your personal
information.
Why we need the information
Generally, we need to collect
personal information to:
- understand your needs,
- determine your eligibility,
- continue to offer you
the full range of products and services that we believe meet your changing
needs and to service such products and services,
- meet regulatory or contractual
requirements relating to the services and products provided to you.
We will make sure you understand
why we need the information by using clear, understandable language when we
identify the purpose.
We will obtain your permission
We collect, use or disclose
your personal information with your permission.
Your permission may be expressed
in writing or be implied and you may give it to us verbally, electronically,
or through your authorized representative.
You may withdraw your permission
to collect, use and disclose your personal information at any time, subject
to legal and contractual restrictions and reasonable notice.
Where medical information
about you is collected or released, we will obtain your consent to do so. We
will not share it with other members of the Sun Life Financial group of companies.
Before we make information
available to third parties, other than an agent or service provider who needs
it, we will tell you at the time we obtain your consent or before we make the
information available, who those persons or organizations are, the kind of information
we want to share with them and why.
We will limit how long
we keep information
We will keep your personal
information as long as it is necessary, including updating the product or service
or as required by law.
When we destroy personal
information, we will use safeguards to prevent unauthorized parties from gaining
access to the information during the process.
We are responsible for
your information
We are responsible for
all personal information in our possession, including information transferred
to a third party service provider or agent, so that we can provide you with
a product or service.
All employees, agents and
authorized service providers of Sun Life Financial are required to protect the
confidentiality of your personal information.
How we protect information
Access to your personal
information is restricted to those of Sun Life Financial's employees, agents
and authorized service providers who need it to do their jobs.
We have developed and are continuing to enhance security procedures to safeguard
and protect personal information against loss, theft, unauthorized disclosure,
copying, and unauthorized use or modification. We will maintain appropriate
safeguards and security procedures that reflect the types of documents, including
electronic or paper records, organizational measures including security clearances
and limiting access on a "need-to-know" basis, and technological measures
such as the use of passwords and encryption. While we endeavour to protect all
information, the most sensitive information, such as medical information, receives
the highest level of protection.
Your rights
You have the right to ask
whether we hold any personal information about you and to see that information,
as provided by law. Where we have obtained medical information about you from
a third party, we will release this information only through your physician.
You also have the right
to know:
- how we collected your
personal information,
- how we are using it,
and
- to whom it may have been
disclosed.
How to request an update
or correction
If you believe any of the
information we have collected about you is incorrect or incomplete, you have
the right to ask us to change it.
If you show that your personal
information is inaccurate or incomplete, we will make the necessary changes.
If you feel we have not
dealt with your request to your satisfaction, you can follow our complaint resolution
procedures.
How to register complaints
You may register a privacy-related
complaint by contacting Sun Life Financial's Canadian Privacy Officer. We will
explain Sun Life Financial's Canadian complaint procedure to you and investigate
all complaints. If a complaint is justified, we will take all appropriate steps
to set the situation right, including changing our policies and practices if
necessary. We will also let you know what other complaint procedures may be
available to you.
For more information, please
contact Sun Life Financial's Privacy Officer in Canada at (416) 408-8850 or
by email at privacyofficer@sunlife.com.
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Principle 1 -
Accountability
Each member, employee
or agent of the Sun Life Financial group of companies in Canada is responsible
for personal information under his or her control and each member company
shall designate an individual or individuals to be accountable for compliance
with this Code.
Principle
2 - Identifying Purposes
The purposes
for which personal information is collected shall be identified before
or at the time the information is collected.
Principle
3 - Consent
The prior
knowledge and permission of the individual are required for the collection,
use or disclosure of personal information, except for legal or security
reasons.
Principle
4 - Limiting Collection
The collection
of personal information shall be limited to that which is necessary for
the purposes identified. Personal information shall be collected by fair
and lawful means.
Principle
5 - Limiting Use, Disclosure and Retention
Personal
information will not be used, disclosed or retained for purposes other
than those for which the information was collected, except with the permission
of the individual, or as permitted or required by law.
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Principle 6 - Accuracy
Personal information
shall be as accurate, complete and current as is necessary for the identified
purposes for which it is to be used.
Principle 7 - Safeguarding
Information
Personal information
will be protected by safeguards appropriate to the sensitivity of the
information.
Principle 8 - Openness
Members of the Sun
Life Financial group of companies will make readily available to their
customers specific information about our policies and procedures relating
to the management of their personal information.
Principle 9 - 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 it. An individual will be able
to challenge the accuracy and completeness of the information and have
it amended as appropriate.
Principle 10 -
Handling Customer Complaints and Suggestions
Individuals can address
any complaint regarding compliance with the above principles with our
Privacy Officer.
privacyofficer@sunlife.com
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