“Personal Information” refers to any information collected or received by TSW about an identifiable individual or any information, which used alone or in combination with other information may lead to the identification of an individual.
Personal Information includes, but is not limited to the following:
Personal Information does not include the title, business address, email address or telephone number of an employee of an organization as this information would normally be found on a business card, publicly available directories or websites.
Collecting Personal Information is essential to our ability to provide the services and insurance products that best meet the needs of our clients. We limit the collection of Personal Information and its disclosure to insurers or service providers to what is necessary to offer clients the products requested or for other reasons for which they have provided consent.
TSW collects, uses and discloses Personal Information for various purposes, including:
Should other purposes arise, they would be identified to the client while or before the information is collected or prior to use, unless required by law.
TSW will always obtain express consent from its customers to collect, use or disclose their Personal Information. Consent may be given in oral form in person or over the phone, or in written form (signed consent form, signed application form, letter, e-mail, etc.).
TSW will consider your consent to the collection, use and disclosure to third parties such as insurers to be express, upon receiving Personal Information destined to allow us to provide you with a product or service. Entities providing TSW with their employees’ Personal Information have a responsibility to obtain prior consent from such employees.
Subject to certain legal or contractual restrictions, you may withdraw your consent at any time by submitting a written request to our Corporate Privacy Officer at the address below. In some cases, refusing to provide certain Personal Information or withdrawing consent may prevent us from obtaining insurance coverage or other requested products, services or information from you. We will need to validate the identity of anyone making such request.
Unless you withdraw your consent, it is deemed to last for as long as is required by the purpose for which the information was collected, even if you cease to be a client of TSW.
TSW limits the collection, use and disclosure of Personal Information to what is necessary to offer the insurance services requested or for other purposes for which clients may provide consent or as otherwise permitted by law (such as receiving other types of products or services). The Personal Information of our clients is only accessible to certain authorized persons, and only to the extent necessary to perform their duties.
TSW will only retain Personal Information for as long as necessary to fulfill the purpose for which it was collected and/or to meet legal, regulatory or contractual requirements.
We, or service providers acting on our behalf, may process and/or store some or all of your Personal Information in jurisdictions outside of Canada, including the United States. Personal Information processed and/or stored outside of Canada will be subject to the laws of the country in which it is stored. Where we do so, we will contractually require such third party to employ the appropriate security safeguards to protect your Personal Information, subject to the law in the third party jurisdiction.
TSW does not share, sell, trade, lend or otherwise disclose Personal Information to any third party.
TSW will make every possible efforts to ensure that the client’s Personal Information in its records is as accurate and complete as is required to fulfill the purpose for which the information was collected. If you find any errors in your Personal Information, you must notify us in writing and we will make the amendments immediately and make sure they are conveyed to insurers to which we disclosed the information during the year before the correction date.
TSW is maintaining rigorous security standards and procedures to protect all Personal Information under its control against unauthorized access and use, which include physical measures such as limiting access to our premises, utilizing secure shredding services, maintaining strict controls to limit and monitor employee access to our system and educating employees on the importance of privacy through internal procedures and training programs. TSW also uses technological measures such as encryption, passwords, firewalls and other data protection mechanisms to safeguard the Personal Information under its control.
You have the right to access or review your Personal Information retained in our client files by sending a written request in that regard. Upon submission of a written request to our Corporate Privacy Officer, TSW will inform you whether it holds Personal Information about you and provide you with access to your Personal Information within a reasonable timeframe. Normally, we will respond to access requests within thirty (30) days. We may charge a nominal access fee depending on the nature of your request and will advise you of any fee prior to proceeding with your request.
Please note that in certain circumstances TSW may not be able to provide you with access to your Personal Information if it contains references to Personal Information about a third party or any information that is protected by legal privilege, proprietary to TSW or that cannot be disclosed for other legal reasons.
Corporate Privacy Officer
TSW Management Services Inc.
1564 Docteur-Penfield Avenue
Montreal, Quebec H3G 1B9