Frank Cowan Company (FCC) has been in the insurance business since 1927, and has long practiced confidentiality in the handling of all personal information it has collected from our clients. FCC only uses the information we are given to provide the services for which we have been retained. These services include: providing municipal, hospital and other public entity insurance programs administered by independent insurance brokers.
Personal Information: Means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal Information includes personal health information with respect to an individual, whether living or deceased, and means (a) information concerning the physical or mental health of the individual; (b) information concerning any health services provided to the individual; (c) information concerning the donation by the individual of any body part or any bodily substance of the individual or information derived from the testing or examination of a body part or bodily substance of the individual; (d) information that is collected in the course of providing health services to the individual; or (e) information that is collected incidentally to the provision of health services to the individual.
Personal Information for the purpose of this policy, shall not include information disclosed as aggregate data. Aggregate data for the purpose of this policy, refers to data that does not reveal, and cannot be manipulated to reveal, member-specific information.
Our Privacy Practices:
The Personal Information FCC collects, or is provided, is used and disclosed for the purposes of conducting the services for which we provide. As part of the employment process, our staff, Directors and Officers will sign a confidentiality agreement which outlines FCC's expectation of its employees to act responsibly in the handling of client information.
In order to further affirm our commitment to maintaining the confidentiality and privacy of our client's personal information, we have done the following:
FCC has assigned a Privacy Officer(s) to provide client service on matters of privacy relating to FCC's use, disclosure, security and retention of personal or personal health information. FCC's Privacy Officer(s) will also be responsible for maintaining this policy and updating staff on changes to both privacy legislation and business practices.
FCC has held an awareness seminar for key members of staff on privacy legislation and will continue to update all staff on privacy related issues and legislation.
2. Identify the purpose
FCC collects personal information in the course of providing services to our clients. The following is an example of circumstances in which FCC may be provided, or required to collect, personal information:
property/casualty insurance applications, premium collection and claim payment
individual claim assessments, legal processes and claim payment
3. Obtain consent
Consent to use personal information is required to be obtained at the time of its collection. If FCC collects the personal information directly from an individual, FCC will obtain express consent for the collection, use and disclosure of such information. However, FCC may receive personal information collected by other parties. Where possible in these circumstances, FCC will take reasonable measures to require that consent for their use of the personal information has been obtained.
If FCC uses personal information it has collected, or has been provided, for any reasons other than those disclosed to an individual at the time consent was given, then FCC will seek to obtain consent for the new use of the information.
4. Limit collection
FCC limits its collection of personal information to that which is reasonably required to accurately complete the services for which we have been retained. We are committed to respecting the privacy of an individual's personal information and will not collect personal information which is not reasonably required.
5. Limit use, disclosure and retention
FCC limits its use and disclosure of personal information to the purpose(s) described at the time the information is collected. FCC retains personal information it collects only as long as is necessary to completely fulfill our services. FCC maintains a records retention policy. The retention policy has been developed to meet FCC's record retention requirements consistent with good business practices and known industry standards.
In the event that FCC decides to purchase, sell, reorganize or transfer the assets of a business, including any Personal Information held by that business, FCC's client information may be subject to review for such purpose by another party. Should FCC or such other party wish to use any Personal Information for purposes not described herein, then consent for such use of the information will first be obtained.
Note: As is the case with all companies, FCC may be lawfully bound to disclose personal information for purposes other than those described at the time consent was obtained. These purposes have been described in applicable privacy legislation as those designed to protect personal and/or public interest.
6. Be accurate
FCC recognizes that personal information can change. We encourage our clients to keep their personal information current so that we may provide the best services possible. Within a reasonable time of being notified, FCC will update records to reflect changes in personal information.
7. Use appropriate safeguards
FCC has inventoried the various ways in which we store personal information, and has taken reasonable measures to ensure the security of this information within our premises, at our offsite storage locations and in our system databases.
Furthermore, FCC will require its staff to sign a confidentiality agreement within which is detailed the firm's expectation that staff will respect and safeguard client information. Through this agreement, employees are aware that a breech of confidentiality could result in termination of their employment.
8. Be Open
Should you wish to question why specific information is required, our Privacy Officer is available to answer any such inquiries.
In all matters of privacy, including access requests and privacy concerns, we encourage our clients to contact our Privacy Officer:
Vice President, Risk Management Services
Frank Cowan Company
75 Main Street North
Phone: 1-800-265-4000 or (519) 458-4331 ext 55226
9. Give individual access
It is extremely important for clients to know that they have access to their personal information. Requests for personal information held by FCC, or corrections to such information, can be made by contacting the sponsoring employer, or, in the case of direct client relationships, personal information can be requested or corrected by contacting our Privacy Officer(s) by email, phone or fax. In response to such requests, FCC will correct or provide that personal information which can be corrected or retrieved at a reasonable cost to FCC or the sponsoring employer, and will do so in a timely manner. In order to guard against fraudulent requests for access, FCC will require sufficient information to allow us to confirm the identity of the person making the request before granting access or making corrections.
Note: As is the case with all companies, FCC may be lawfully bound to deny access of an individual to their personal information. Reasons for such a denial have been described in applicable privacy legislation as those designed to protect personal and/or public interest.
10. Provide recourse