Privacy Policy

Heartland Farm Mutual Inc. “Heartland” is committed to protecting your privacy. Our Privacy Policy outlines our responsibilities and your rights when it comes to the collection, protection, use and disclosure of your personal information. Our employees are required to comply with our Privacy Policy in the execution of their daily activities and as a condition of their employment.

This policy is compliant with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and addresses two broad issues:

  1. The way in which Heartland collects discloses and protects personal information; and
  2. The right of policyholders to have access to personal information about themselves and, if necessary, to have the information corrected.

We take our commitment to protecting your personal information seriously.

The types of personal information that we may collect depend on the insurance products you apply for and purchase, the services you have access to and use, the payment method you use, and the way you communicate with us.  The type of information that we collect may include but is not limited to the following:

Personal Information does not include general sources of public information such as:

The Personal Information Protection and Electronic Documents Act (PIPEDA) sets standards and regulations governing the collection, use and disclosure of personal information by private sector organizations.

This legislation establishes rules and principles for the use and disclosure of personal information based on the ten privacy principles developed by the Canadian Standards Association. These principles recognize that we live in an era when commercial information is exchanged and circulated by electronic means. It balances the individual’s right to privacy in their personal information with the reasonable need of organizations to collect, use or disclose personal information.

An organization may collect, use or disclose personal information only for limited purposes that a reasonable person would consider to be appropriate in the circumstances. The Personal Information Protection and Electronic Documents Act requires us to provide the same safeguards for your privacy that we have always provided on a voluntary basis. Our Personal Information Protection Policy sets out these principles in simple terms. It explains how we ensure that your privacy and the confidentiality of your personal information are protected.

The Ten Privacy Principles

The objective of our Privacy Protection Policy is to ensure the protection of Heartland’s Policyholders’ Personal Information. This includes personal information residing within Heartland and personal information provided to other third parties in the conduct of commercial activities. To attain this goal, Heartland complies with the following ten principles of privacy accountability:

Principle 1: Accountability

Heartland is responsible for Personal Information under its possession, custody or control and a designated Privacy Officer is accountable for Heartland’s compliance to the Privacy Policy and Procedures.

We are responsible for all personal information while it is under our control, whether supplied to us directly by you or by a third party or that we have provided to a third party for processing.

We have established policies and procedures to ensure that we comply with the Personal Information Protection and Electronic Documents Act. We have designated a Privacy Officer who is responsible for our company’s compliance with the ten privacy principles developed by the Canadian Standards Association.

If you have any questions or inquiries about how your personal information is stored, or when it may need to be disclosed to others, our Privacy Officer is there to assist and explain our policies to you. Please see below to contact our Privacy Officer regarding your specific privacy questions or concerns.

Principle 2: Identifying Purpose

Heartland shall inform individuals of the purposes for which Personal Information is collected at or before the time the information is collected.

Heartland collects personal information from but is not limited to, government agencies, brokers, agents, insurers, other insurance reporting or data sharing agencies, credit bureaus and directly from you to:

If we require your personal information for any purpose other than as identified above, Heartland will seek your consent prior to using it.

Where permitted by law, your consent may be obtained to collect and use your credit information for the purposes of offering you a discount on our products.

Principle 3: Consent

Heartland requires the knowledge and consent of the individuals for the collection, use, or disclosure of their Personal Information, except in certain circumstances where consent is not required.

We issue an insurance policy with the understanding that, in addition to providing your consent, you have obtained consent from all persons named in your insurance policy for the collection, use and disclosure of their personal information, for the purposes outlined above.

Obtaining Consent:

You can provide consent to the collection, use and disclosure of your personal information expressly or consent may be implied by your actions.

Where Heartland seeks express consent, it can be given in many ways. For example:

Implied consent can be inferred from the relationship between the parties or from the nature of the dealings between the parties. For example, when you give personal information to an insurance broker or agent for the purpose of obtaining insurance, it is reasonable to infer that there is implied consent to the disclosure of that information to the insurer to meet your insurance needs.

When your personal information is highly sensitive, for example, medical reports or financial records such as income tax returns, we obtain your express written consent before using it.

In addition, when you make changes to your policy or when your policy automatically renews, you are agreeing that any consent you have previously provided to us relative to your policy remains in effect unless the consent is otherwise withdrawn.

When consent is not required:

In certain circumstances, personal information may need to be collected, used or disclosed without the knowledge and consent of the individual.

Legal

In either of these situations, obtaining consent might defeat the purpose of collecting the information.

Duty to Defend

Public Duty

Under certain circumstances, Heartland may disclose personal information under a public authority to appropriate authorities in matters of significant public interest.

Medical and Other

Withdrawing your consent:

Subject to certain legal and contractual restrictions and reasonable notice, you may refuse or withdraw consent to the collection, use or disclosure of personal information at any time by notifying our Privacy Officer in writing. In addition, you may also opt out of certain communications we may send you regarding other products and services. However, you should be aware that withdrawing your consent may affect our ability to respond to your insurance needs.

Principle 4: Limiting Collection

Heartland will always limit the collection of Personal Information to that which is necessary for the identified purposes and by fair and lawful means.

We only collect information that we require to do business with you. We will collect it openly, fairly and lawfully.

Principle 5: Limiting Use, Disclosure and Retention

Heartland will not use or disclose Personal Information for purposes other than for which it was collected, except with your consent or as permitted or required by law. Your personal information will be retained only as long as it is necessary to fulfil those purposes.

There are situations specific to the Property and Casualty insurance business where we will use, disclose and retain personal information as dictated by prudent insurance practices.  Examples of these situations include:

Disclosure to Third Parties

Heartland does not provide or sell its customer lists to any outside company for use in marketing or solicitation. Only employees and third parties with a business “need to know”, or those whose duties require it, are granted access to personal information about our policyholders.

We keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law.

Principle 6: Accuracy

Heartland makes every effort to ensure that Personal Information about its policyholders is as accurate, complete, and up-to-date as is necessary for the purposes for which it was collected.

This may require contact with you or your insurance broker or agent to confirm or update personal information required for underwriting purposes. In addition, the Insurance Act and the terms and conditions of your policy of insurance may require you to notify us of material changes to your personal information.

If you have any questions about the accuracy and completeness of the personal information that we have collected or retained, please do not hesitate to contact our Privacy Officer. If you need to update some aspect of your personal information, please contact your insurance broker directly.

Principle 7: Safeguards

Heartland will protect Personal Information by establishing and operating security safeguards appropriate to the sensitivity of the information that is held, and to prevent any unauthorized activity related to the information.

Specifically, we have stringent security measures in place to protect personal information against such risks as loss or theft, computer hackers, unauthorized access, disclosure, copying, use, modification or destruction.

Heartland Farm Mutual Inc. protects your personal information regardless of the format in which it is held. We also protect the personal information we disclose to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All our employees with access to personal information are required as a condition of their employment to respect the confidentiality of personal information.

Principle 8: Openness

Heartland will make available to policyholders upon written request, specific information about our policies and practices relating to the management of their Personal Information.

We ensure openness by providing you with the following information:

Heartland makes information available to help our policyholders exercise informed choices regarding the use of their personal information.

Principle 9: Policyholder Access

Heartland will, upon written request from policyholders, inform them of the existence, use, and disclosure of any Personal Information about them and they will be provided access to that information except as may be limited by law. Our policyholders are able to challenge or correct the accuracy and completeness of their Personal Information and have it amended when appropriate.

When a request is made in writing, we will inform you in a timely fashion, of the existence, use, and disclosure of your personal information and you will be given access to that information. In order to safeguard your personal information, we may require you to provide sufficient identification information to permit us to authorize access to your file.

In certain exceptional situations, we may not be able to provide you with access to all of the personal information we hold. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that is subject to solicitor-client or litigation privilege, or, in certain circumstances, information of a medical nature. If this is the case, Heartland will provide the reasons for denying access upon request.

Policyholders can obtain information or seek access to their individual files by contacting our designated Privacy Officer at the address described below. We may charge you for providing access to your information but only after first advising you of the approximate cost.  When a policyholder successfully demonstrates the inaccuracy or incompleteness of personal information, Heartland will correct the information as required.

Principle 10: Challenging Compliance

Heartland provides the ability for policyholders to challenge compliance with the above principles by contacting our Privacy Officer.

Heartland maintains strict procedures for addressing and responding to all inquiries or complaints from its customers about its handling of personal information. We inform our customers about our privacy practices as well as the availability of complaint procedures, if necessary.

Our Privacy Officer will investigate all complaints concerning compliance with the privacy policy. If a complaint is found to be justified, we will take appropriate measures to resolve the complaint including the amendment of our policies and procedures.

In exceptional circumstances, the Privacy Officer accountable for compliance with our privacy policy may seek external legal advice where appropriate before providing a final response to individual complaints.

Policy updated August 25, 2020

For Further Information

For more information, please refer to our website www.heartlandmutualinsurance.com or by calling our toll-free number: 1-800-265-8813.

How to contact our Privacy Officer:

Vanja Popic-Imamovic

Compliance and Privacy Officer
Heartland Farm Mutual Inc.
100 Erb Street East
Waterloo, ON  N2J 1L9

Email: vimamovic@hfmi.ca

Phone: 1-800-265-8813