​​​​Privacy Policy

This policy applies to BARBARA MACKAY, and also applies to any licensed representatives as licensed  agents or contractors providing services on her behalf (hereinafter collectively referred to as ‘Barb’). A  copy of this policy is provided to any client upon their request.  

Barb holds Life and A&S licenses in the Provinces of British Columbia, Alberta, Saskatchewan and  Ontario. Barb is committed to safeguarding the personal information entrusted to her by her clients.  Your personal information will be managed in accordance with the applicable provincial and federal  legislation, other applicable laws and their corresponding regulations. The following table outlines the  applicable legislation per jurisdiction (includes but is not limited to): 

Jurisdiction Privacy Legislation 

British ColumbiaFreedom of Information and Protection of Privacy Act (FIPPA) Protection of Privacy Act (PIPA) 

Alberta Personal Information Protection Act 

Saskatchewan Freedom of Information and Protection of Privacy Act Ontario Freedom of Information and Protection of Privacy Act (FIPPA) FederalPersonal Information Protection and Electronic Documents Act (PIPEDA) Digital Privacy Act 

How is personal information defined?  

Personal information means information about an identifiable individual. This includes their name,  home address, phone number, age, gender, marital status, Social Insurance Number, driver’s license  number, passport number, other government issued identification, recorded answers to health  questions, health history, financial information and your educational history.  

What personal information is collected?  

Only personal information needed for the purpose of providing services to client(s) will be collected.  This may involve but is not limited to:  

  • Opening and managing an account or new policy  
  • Delivering requested products or services  
  • Enrolling a client in a referral program  
  • Processing a subscription or sending out membership information  
  • Contacting or scheduling clients about appointments  
  • Following up with clients to determine suitability of a product already purchased or being proposed  • Notifying clients of upcoming events or deadlines  
  • Administering any loyalty or referral programs  
  • Granting credit or client rewards  
  • Meeting changing regulatory requirements from time to time 

Client information is normally collected directly from the client. Your information may be collected from  other persons, or businesses with your consent or as authorized by law. As clients, you will be informed  of personal information collection before it is collected, and the purposes for which your information is  

being collected. The only time this notification will not be provided is when a client volunteers  information for an obvious purpose. For example, if you provide your address when you have won a  trade show draw prize.  

Consent:  

As a client, you will be asked for initial consent to collect, use or disclose your personal information,  except in specific circumstances where collection, use of or disclosure of information without consent is  authorized or required by law. Your consent may be assumed in cases where you volunteer information  for an obvious purpose.  

In cases where your personal information was collected prior to July 1, 2017, your prior written  permissions as required by the Canadian Anti-Spam Legislation will continue to apply. As such, Barb will  continue to communicate using verbal, written or electronic means relating to any prior disclosure, thus  prior consent and disclosure for the purpose in which the information was originally collected still  remains valid. Where contact is made by Barb to ask for reiteration of this consent and consent is  refused, it is necessary to be aware that the provision of certain ongoing services may not be available  where you are unwilling to provide consent and update your personal information.  

Federal or provincial laws may have restricted use of certain personal information that you choose to  withhold from Barb. Wherever express consent is required, it is considered normal and appropriate to  ask clients for their provision of consent in writing either via consent form, by checking a box on a  Advisor Disclosure form or the provision of consent electronically by receiving verbal, phone, text,  emails from you. Additionally, please be aware that consent is considered provided by you clicking a  button on a website or other electronic format of some nature sent directly from Barb, a carrier or an  approved product supplier.  

In cases that do not involve sensitive personal information, an opt-out consent from you may be relied  upon. For example, you may wish to disclose your contact information to other organizations that you  believe may be of interest to you. This may occur automatically unless you specifically request that your  personal information is not disclosed. You can achieve this by checking the appropriate boxes on the  product application forms to opt-out or by calling your sales agent, carrier or product supply company  directly.  

A client may withdraw consent to the use and disclosure of personal information at any time, unless  the personal information is necessary for the fulfillment of Barb’s legal obligations.  

Should you choose to withdraw your consent Barb will be respectful of that decision but may not be  able to provide you with certain products and/or services if the necessary personal information is not  able to be collected. Barb may collect, use or disclose clients’ personal information without consent only  as authorized by law. For example, Barb might be required to provide information collected from you  when its use or disclosure is reasonable for purpose of a regulatory investigation, legal proceeding under  court order, collect a debt or payment owed to her or her organization, maintain good standing of a  policy/contract, act in a medical emergency that threatens life, health or safety of yourself or a 

minor/adult dependent, or when the personal information of you or a named beneficiary is not available  from a public telephone directory, online social media or other internet based source.  

How is your personal information used and disclosed?  

Barb will use and disclose client personal information only for the purposes for which the information  was collected, except as otherwise authorized by law. For example, the law requires Barb to use  personal contact information for the purpose of thwarting Terrorist Financing and Money Laundering  schemes and to demonstrate we have a mechanism to report as such any suspicious transactions  accurately.  

Personal information such as individual passport numbers and other government issued ID, recent  corporate annual filings and beneficial owner information will be collected such that proper FINTRAC  (Financial Transactions and Reports Analysis Centre of Canada) protocols are followed. For more  information about FINTRAC and Barb’s responsibilities in that regard, please reference:  

http://www.fintrac.gc.ca/guidance-directives/compliance-conformite/rba/rba-li-eng.asp Alternatively, you can search FINTRAC on the Service Canada website.  

How is your personal information safeguarded?  

Barb makes every reasonable effort to ensure that client information is complete and accurate. You, the  clients are required to notify her if there is a change in personal information that may affect your  relationship with her organization. If you are aware of an error in the information Barb has about you,  please let her know and it will be corrected upon request and the affected carriers or product suppliers  will be updated wherever possible and/or necessary. In some cases, this request may be made to you in  writing so as to ensure accuracy. Clients’ personal information is protected in a manner appropriate to  the sensitivity of the information. Every reasonable effort is made to prevent loss, misuse, unauthorized  disclosure or modification of personal information. In addition, every reasonable effort is made to  ensure any unauthorized access to your personal information. Appropriate security measures when  destroying clients’ personal information, including shredding paper records and locking up client  information when not in use are strictly adhered to.  

Personal client information is retained only if it is reasonable to expect that it will be used to fulfill the  purposes for which it was initially collected, maintaining a good standard of future client service,  propose new and ongoing business relations and/or for legal purposes. 

Access to records containing personal information:  

Any and all of Barb’s clients have a right of access to their own personal information in a record that is in  her custody or under her control subject to some exceptions. For example, organizations are required to  refuse information that would reveal information about another individual or information that is  privileged or contained in mediation records. If a request is refused in whole or in part, reasons will be  provided for the refusal. 

You may make a request for access to your personal information by writing to:  

Barbara MacKay, Privacy Officer  

943 – 7th Avenue 

Castlegar, BC V1N 1S2 

You must provide sufficient information in your request to allow Barb to identify the information you are  seeking. You may also request information about use of your personal information or any disclosure of  that information to persons outside her office. Your request will receive a response within 45 calendar  days.  

Complaints & Questions:  

If you have a concern about any collection, use or disclosure of personal information by Barb, or about a  request for access to your own personal information please contact the Privacy Officer at the above  address.  

If you are not satisfied with the response you receive, contact one of the following offices according to  your Province of Residence:  

In British Columbia: Office of the Information and Privacy Commissioner for British Columbia 

In person: 

4th Floor, 947 Fort Street 

Victoria BC, V8V 3K3 

By Mail: 

P.O. Box 9038 Stn. Prov. Govt. 

Victoria BC, V8W 9A4 

Phone: 250-387-5629 

Or Email: info@oipc.bc.ca 

In Alberta: Office of the Information and Privacy Commissioner of Alberta 

Suite 2460, 801 – 6 Ave SW  

Calgary AB, T2P 3W2  

Phone: 403-297-2728  

Or Email: generalinfo@oipc.ab.ca

In Saskatchewan: Office of the Saskatchewan Information and Privacy Commissioner  

503, 1801 Hamilton Street  

Regina SK, S4P 4B4  

Phone: 306-787-8350  

Or Email: webmaster@oipc.sk.ca 

In Ontario: Information and Privacy Commissioner of Ontario 

2 Bloor Street East 

Suite 1400  

Toronto ON, M4W 1A8 

Phone: 416-326-3333  

Or Email: info@ipc.on.ca

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