Commonwealth Insurance is committed to protecting your personal information, whether you are a customer of Commonwealth or not, and no matter how Commonwealth Insurance came be in possession of your information.

As of January 1, 2004 strict new privacy legislation will govern the conduct of Commonwealth Insurance where your personal information is concerned. Ten principles govern the collection, use, disclosure and accountability of Commonwealth Insurance where your personal information is concerned. To protect your personal information, Commonwealth Insurance has implemented strict rules governing the use of your personal information, many of which go beyond that which is expected under the legislation.

The Ten privacy principles and our commitment to them are as follows:

• Accountability: Commonwealth has designated an individual, Don Parry, as the person who is accountable for ensuring we use personal information appropriately.
• Identifying Purposes: Commonwealth will identify the purposes for collecting personal information at or before the time the information is collected.
• Consent: Commonwealth will only collect, use or disclose your personal information with your knowledge and consent as accorded by law.
• Limiting Collection: Commonwealth will only collect personal information that is necessary for the purposes we have identified at the time the information is collected.
• Limiting Use, Disclosure and Retention: Commonwealth 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 Don Parry, who is accountable for our compliance with these principles.

Collecting, Using and Disclosing Information about You We collect, use and disclose your personal information in order to provide you with the insurance protection that you have requested, or, in the case of a claimant, to provide you with the compensation to which you are entitled. In order to do this, we use your personal information 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
• compiling statistics
• acting as required or authorized by law

These are our “Identified Purposes”.

Commonwealth takes a global view of the Identified Purposes in that we are not collecting personal information just for any one of the purposes. We are collecting the personal information for all of the Identified Purposes. This being so, you can expect that although we may initially use the data for underwriting your policy, we may later use it for claims purposes, and visa versa.

We only collect personal information that we require to provide you with the insurance protection that you have requested and to administer any claims that you may have. The type of personal information that we hold depends upon the nature of your relationship with us, but may include:

• name,
• address,
• telephone number,
• e-mail address,
• date of birth,
• family status,
• marital status,
• occupation,
• medical and health records,
• assets,
• liabilities,
• income,
• credit rating,
• whether or not credit was extended or refused,
• credit and payment records,
• previous insurance experience including claims history,
• policy type and number,
• driver’s licence number,
• vehicle identification number (VIN),
• mortgagee,
• banking information,
• credit card information,
• driving record

We only use such information for the Identified Purposes.

By providing your broker or a Commonwealth employee with personal information, we consider that you do so with the knowledge and understanding that it is collected, used and disclosed for the Identified Purposes.

Given the nature of the insurance industry, consent may be implied in some circumstances. For example, we sometimes provide insurance or amendments to existing policies over the telephone, on short notice or with little written documentation. In these circumstances, it is impossible to obtain express written consent from you. Another example is that consent can also be given by you on behalf of another individual. For example, where an individual applies for auto insurance for them self and their family, the applicant is giving consent for the collection, use and disclosure of personal information both for them self and their family members even though the family members are not present during the application process. By dealing with us on insurance related matters, we infer that we have your consent for the collection, use and disclosure of personal information necessary for the Identified Purposes.

You may withdraw your consent, subject to legal or contractual obligations and on reasonable notice, but this may limit our ability to provide you with the requested product or service. In the event that you wish to withdraw your consent, you should contact Don Parry first to understand the implications of such withdrawal, and then if you choose to proceed, to give the requisite notice.

Protecting Your Privacy

Your personal information is kept in strict confidence. We maintain physical, electronic and procedural safeguards to protect your information from unauthorized access. We review our policies and practices, monitor our computer networks, test the strength of our security and monitor our compliance with relevant laws in order to help us ensure the safety of your personal information. We restrict access to your personal information to those employees whom we have determined need to know that information to provide products or services to you. In addition, all our employees are bound by a Confidentiality Policy. Personal information is retained only as long as it is needed, or to meet any legal, regulatory or tax requirements.

There are situations specific to the general insurance industry where we will disclose personal information as dictated by prudent insurance practices. For example, as part of the underwriting handling process, we may transfer personal information to other insurance companies including reinsurance companies which share in the risk. Additionally, personal information may be disclosed to information services providers for underwriting, claims, classification and rating purposes. We may also disclose personal information to businesses that provide goods and services to insurance companies and their customers, such as claims adjusters, appraisers and repair shops. As well, we may disclose personal information to regulatory agencies as dictated by law. Only the information necessary for these services will be provided by us to these services providers, and it is done on the basis that they will maintain the confidentiality of the information. These organizations are also bound by the same legal requirements as Commonwealth where your personal information is concerned.

Accessing Your Personal Information

 You have the 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 Don Parry at the address listed below. 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. 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 and will make reasonable efforts to advise other parties to whom we have supplied your personal information of corrections that are needed. There is no charge for verifying or correcting information.

Further Information and Contact

If you have a question or complaint regarding our privacy policies or procedures, you may contact the individual accountable for our personal information protection compliance:

Don Parry
PO Box 49115
595 Burrard Street Suite 1500
Vancouver, B.C. Canada V7X 1G4

Phone (604) 683-5511
Fax (604) 683-8968

If you make an inquiry or lodge a complaint, and are not satisfied with the outcome of that, you may challenge that outcome by writing a letter to our President at PO Box 49115, 595 Burrard Street, Suite 1500, Vancouver, B.C. Canada V7X 1G4 requesting reconsideration of your matter. Commonwealth Insurance’s commitment is to promptly open a dialogue with you. If your concern remains unresolved to your satisfaction, you may address your concerns to:

The Privacy Commissioner of Canada 112 Kent Street Ottawa, Ontario K1A 1H3

Phone (613) 995-8210 Toll-free 1-800-282-1376 Fax (613) 947-6850 info@privcom.gc.ca