Privacy Statement CNA Canada recognizes the importance of privacy and the sensitivity of personal information. As a responsible financial services organization, we are committed to protecting the confidentiality of personal information provided to us and ensuring that all personal information we hold is collected, used and disclosed in compliance with all applicable federal and provincial privacy requirements. This Privacy Policy outlines how we manage personal information of clients and others and safeguard their privacy. Privacy Rights From January 1, 2004, all organizations engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (the "Act"), for personal information collected, used and disclosed within a province unless the federal cabinet has exempted the organization because it is subject to substantially similar provincial legislation. (The Act will continue to apply to the collection, use and disclosure of personal information outside of a province.) These obligations extend to insurance companies in Canada, including CNA Canada (Continental Casualty Company). CNA Canada is responsible for the personal information we collect, use, maintain and disclose. To ensure this accountability, we have developed this policy, and trained our staff about our policies and practices. What is personal information? Personal information is generally any information that identifies an individual, or by which their identity could be deduced. However, it does not include their name, business address, business title, professional designation(s) or business telephone number. Why do we collect personal information from clients and brokers? We collect personal information from clients and brokers to: provide insurance products and related services reinsure insurance risks determine and verify identity detect and prevent fraud monitor and investigate transactions analyze business operations and results comply with applicable laws How do we collect personal information? We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect personal information directly from our insurance brokers or from the client, both at the commencement of the underwriting process and throughout the term of our relationship. another insurance company, broker or adjuster; insurance associations; from a government agency or registry; or reinsurance companies and other financial institutions. Consent We ask clients to provide explicit consent if we collect, use, or disclose their personal information, or rely upon the express consents obtained by the insurance brokers that represent us. Although we may ask for a consent in writing in some circumstances, in others we may accept a verbal consent. Sometimes, a consent may also be implied through conduct with us. Use of Personal Information We use personal information to provide insurance coverage and related services to clients, to administer our client databases and to include our clients in any direct marketing activities or other informational distributions of material. If we are notified that a client no longer wishes to receive information regarding our products and services, we will not send any further material. CNA Canada does not disclose personal information to any third party to enable them to market their products and services. For example, we do not provide our client mailing lists to other insurance companies or intermediaries. Disclosure of Personal Information Under certain circumstances, CNA Canada will disclose personal information: when we are required our authorized by law to do so, for example if a court issues a subpoena; when the individual in question has consented to the disclosure; when the insurance products and services we are providing require us to give personal information to third parties (for example, to a broker in an insurance transaction or a reinsurer in a reinsurance transaction) the consent will be implied, unless we are advised otherwise; where it is necessary to establish or collect premiums or other amounts owing to us; if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy; or if the information is already publicly known. Updating Information Since we use personal information to provide insurance products and services to brokers and customers, it is important that the information be accurate and up-to-date. If any personal information regarding a client changes, we ask the client or their broker to inform us promptly of the change so that we can make any necessary changes to our records. Is Personal Information Secure? CNA Canada takes all reasonable precautions to ensure that personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect personal information are: premises security; restricted file access to personal information; deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access; and internal password and security policies. Access to Personal Information An individual may ask for access to any personal information we hold about them. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to appropriate fees. Correcting Errors If CNA Canada holds information about an individual and the individual can establish that it is not accurate, complete and up-to-date, CNA Canada will take reasonable steps to correct it. Can an Individual be Denied Access to their Personal Information? An individual's rights to access their personal information are not absolute. We may deny access when: denial of access is required or authorized by law; information relates to existing or anticipated legal proceedings; when granting access would have an unreasonable impact on other people's privacy; when to do so would prejudice negotiations with the individual; to protect CNA Canada's rights and property; or where the request is frivolous or vexatious. If we deny a request for access to, or refuse a request to correct information, we shall explain why. CNA Canada does not use Social Insurance Numbers as a way of identifying or organizing the information we hold about clients or others. Can an Individual Request Anonymity? Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without an individual providing a name (for example, by accessing general information on our website). Credit Bureaus To help us make credit decisions about clients, prevent fraud, check the identity of new clients and prevent money-laundering, we may on occasion, request information about clients from the files of consumer reporting agencies. How Long do we Keep Personal Information? We keep personal information as long as is reasonably necessary for us to complete our dealings with an individual, or as may be required by law, whichever is longer. Communicating with Us All of our clients and brokers should know that email is not a 100% secure medium, and should be aware of this when contacting us to send personal or confidential information. Changes to this Privacy Policy CNA Canada regularly reviews all of its policies and procedures and we may change our Privacy Policy from time to time. Request for Access Any questions, or requests for access to personal information, should be directed in writing to our Privacy Officer. Employment Inquiries Although the Act does not apply to our employee information, we have elected to follow privacy "best practices" in this area. If an individual applies to CNA Canada for employment, we need to consider their personal information as part of our review process. We normally retain information from employment candidates after a decision has been made, unless they ask us not to retain the information. If we offer a person a job, and they accept, the information will be retained in accordance with our privacy procedures for employee records. Web Site Our website may contain links to other sites, which are not governed by our Privacy Policy. On our website, like most other commercial websites, we may also monitor traffic patterns, site usage and related site information in order to optimize our web service. We may also provide aggregated information to third parties, but these statistics do not include any identifiable personal information. Inquiries For further information please contact: Lynne von Wistinghausen Chief Privacy Officer CNA Canada 250 Yonge Street, Suite 1500 Toronto, Ontario M5B 2L7 Phone: 1-800-268-9399 Fax: 416-542-7310 | 
