Personal Information Protection

Summary Information

COLLECTING, USING AND DISCLOSING INFORMATION ABOUT YOU

Information Collected

We collect, use and disclose your personal information in order to provide the products and services you have requested. Personal information is collected for the purposes of establishing and maintaining communications with you; underwriting risks on a prudent basis; investigating and paying claims; detecting and preventing fraud; offering and providing products and services to meet your needs; receiving payments on account of insurance premiums, investment contributions, policy loan repayments and mortgage payments; depositing funds into your account; approving and administering mortgages; compiling statistics and acting as required or authorized by law (the "Identified Purposes").

We take a global view of the Identified Purposes. In other words, we are not collecting personal information just for any one of the purposes (e.g. underwriting your policy). We are collecting the personal information for all of the Identified Purposes, so in effect you can expect that although we may initially use the data for underwriting your policy, we may later use it for claims purposes.

We only collect personal information that we require to provide you with the service and benefits you are entitled to as an individual Customer or group benefit plan Participant. The type of personal information that we hold depends upon your dealings with us, but may include your name, address, telephone number, date of birth, family status, marital status, occupation, medical and health records, assets, liabilities, income, credit rating, credit and payment records, banking information, previous insurance experience (including claims history), driving record and whether or not credit was extended to you or refused. We only use such information for the Identified Purposes.

Providing Consent

When you first become a Customer of Wawanesa Life, either as an individual Customer or group benefit plan Participant, your personal information is obtained and used only with your consent. The consent you provide at that time allows us to administer all aspects of your insurance coverage. In order to provide you with benefits as an individual Customer or group benefit plan Participant, it may be necessary for you to provide us with additional personal information at a future time. We may not require you to provide consent at that future time unless the information being provided is to be used for a new purpose not listed amongst the Identified Purposes.

Your consent can be either express or implied. Where practical, we will obtain your express consent. For example, when you sign an application form you are giving us express consent to use your personal information to provide you and/or your dependents with products and services. Given the nature of the life insurance industry, consent may be implied in some circumstances. For example, if you are a member of a group benefit plan and present your benefit identification card to a pharmacist in lieu of paying for a prescription, it can be implied as consent for the pharmacist to provide your personal information to Wawanesa Life to obtain payment for the service rendered, and for Wawanesa Life to process the related claim for payment.

For our existing Customers, we will continue to use and disclose your personal information previously collected in accordance with our current privacy policy, unless you inform us otherwise. We will infer that consent has been obtained for the continued use or disclosure of your personal information by the continuation of premium payments, submission of claims and requests for other forms of service.

Withdrawal of Consent

You may withdraw your consent, subject to legal or contractual obligations and on reasonable notice. Withdrawal of consent may limit our ability to provide you with the requested product or service or we may have to terminate your policy. If you wish to withdraw your consent, you should first contact the Privacy Officer, Wawanesa Life, 400-200 Main Street, Winnipeg, Manitoba, R3C 1A8 to understand the implications of such withdrawal, and then, if you choose to proceed, give the requisite notice.

Protecting Your Privacy

Your personal information is kept in strict confidence. We protect your personal information from error, loss and unauthorized access.

Employee Access to Personal Information

Our employees who have access to your personal information are made aware of how to keep it confidential. Generally, employees only have access to the information required to perform their jobs. All employees of Wawanesa Life are bound by a Confidentiality Policy.

Information Protection Measures

We have developed and continue to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records. Organizational measures taken include security clearances and limiting access on a "need-to-know" basis. Technological measures include the use of passwords and encryption.

Outside Parties

There are situations specific to the life insurance industry where we will provide personal information as dictated by prudent insurance practices. For example, as part of the underwriting process, we may transfer personal information to other insurance companies, including reinsurance companies which share in the risk. We may transfer personal information to paramedical or similar medical services organizations retained to gather additional medical information from you.

We may also disclose personal information to businesses that provide goods and services to insurance companies and their customers, such as benefit administrators and claims payment service providers. As well, we may provide personal information to insurance intermediaries, such as your broker.

We may disclose personal information to information processing and storage providers, as well as programming, printing, mailing and distribution services.

Only the information necessary for these services will be provided by us to these service providers, and it will be done on the basis that they will maintain the confidentiality of the information. The people, organizations and service providers may be in other provinces or in jurisdictions outside Canada. Your information may be shared as required by the laws of those jurisdictions.

Where medical information about you is collected or released, we will always obtain your express consent to do so.

We do not make any personal information available to affiliated organizations, such as subsidiaries, without your consent.

Retention/Destruction of Personal Information

We keep your personal information for only as long as we need it to administer products and services and for a reasonable time thereafter,or to meet any legal, regulatory, or tax requirements. We destroy your personal information when it is no longer needed, or we remove your name from the information.

Accessing Your Personal Information

You have a right to submit a written request to access your personal information that is in our possession and make corrections to it. Such a request is to be made to the Senior Vice President, Chief Legal Officer & Corporate Secretary. We will respond to your request within 30 days or advise you if additional time is required to respond to your request.

There may be situations in which we are legally prohibited from allowing you access to your personal information. For example, we would be so prohibited if allowing you access to your personal information would likely reveal personal information about another person or other confidential information. If this is the case, we will advise you why, subject to any legal restrictions.

We may also charge you for providing access to personal information, however we will only do so after first advising you of the approximate cost.

We will amend personal information that is demonstrated to be inaccurate or incomplete.

Principles Underlying the Wawanesa Life Personal Information Protection Policy

Accountability. We have designated an individual, the Senior Vice President, Chief Legal Officer & Corporate Secretary, as the person who is accountable for ensuring we use personal information appropriately.
Identifying Purposes. We will identify the purposes for collecting personal information at or before the time the information is collected.
Consent. We will only collect, use or disclose your personal information with your knowledge and consent as accorded by law.
Limiting Collection. We will only collect personal information that is necessary for the purposes we have identified.
Limiting Use, Disclosure and Retention. We will not use or disclose personal information for purposes other than those for which it was collected, except with consent or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
Accuracy of Information. Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Safeguards. Personal information will be protected by security safeguards appropriate to the sensitivity of the information.
Openness. We will make readily available to individuals specific information about our policies and practices relating to the management of personal information.
Individual Access. Upon request, an individual will be informed of the existence, use and disclosure of his or her personal information and will be given access to that information. An individual can challenge the accuracy and completeness of the information and have it amended as appropriate.
Challenging Compliance. An individual can address a challenge concerning compliance with the above principles to the Senior Vice President, Chief Legal Officer & Corporate Secretary, who is accountable for our compliance with these principles.

These principles are developed more fully in our Personal Information Protection Policy.

Further Information and Contact

You can obtain further information about our Personal Information Protection Policy and practices concerning service providers outside Canada from www.wawanesa.com or our Customer Service Department, Wawanesa Life, 400-200 Main Street, Winnipeg, Manitoba, R3C 1A8.

If you have a question (including a question concerning our collection of personal information, or the collection, use, disclosure or storage of personal information by service providers outside Canada on our behalf) or complaint regarding our privacy policies or procedures, please contact the individual accountable for our personal information protection compliance:

Privacy Officer
The Wawanesa Life Insurance Company
400 - 200 Main Street
Winnipeg, Manitoba R3C 1A8

If your concern remains unresolved to your satisfaction, you may address your concerns to:the appropriate public official designated in relevant provincial legislation, or if none, Privacy Commissioner of Canada.