We adhere to the following principles when handling Personal Information:
Accountability: We are responsible for Personal Information under our control and establish this Framework for managing privacy across all our business operations. We have designated individuals who are responsible for monitoring compliance with these principles, our policies, practices and procedures and the expectations of our regulators.
Transparency – Individuals have the right to be information about the collection, use and disclosure of their personal information. We make information about our privacy policies and practices readily available to individuals, subject to any exceptions permitted by law.
Identifying purposes – We will be transparent about our privacy practices and will clearly identify the purposes for which we collect, use, retain and disclose Personal Information.
Lawful basis – We will only collect, use and disclose your Personal Information as reasonably necessary for the identified purposes, and only do so where there is a lawful basis. Sometimes, this will be with the knowledge and consent of a member, customer or employee. At other times, it will be on the basis of a contractual obligation, legal obligation, our legitimate interests or vital interests. But in each case only to the extent necessary to fulfill that obligation or interest. Where we require your consent, we may obtain it in writing, verbally, electronically or through an authorized representative. Consent may also be implied.
Limiting Collection – We will limit the collection of Personal Information to that which is necessary for the purposes we identify, and we will collect it fairly and lawfully.
Limiting use, disclosure and retention – We will not use or disclose Personal Information for purposes other than those for which we collected it, except with your consent, or as permitted or required by law. We restrict the access to and disclosure of Personal Information to those who have a need for the information. This may include our employees, licensed representatives or service providers who need the information to perform their duties or to provide us with services. It may also include other companies within the Forester group of companies. who, from time to time, may offer or promote other financial products, benefits or services, or those of select third parties, that we believe may be of interest to our members and customers. We may also have joint marketing or distribution agreements with other financial institutions that may offer or promote products that we believe may be of interest to our members and customers. In some instances, our subsidiaries, employees, service providers, representatives, reinsurers, and any of their service providers may be located in other jurisdictions. Personal Information may then be subject to the laws of those other jurisdictions.
We do not retain Personal information longer than is reasonably necessary or relevant for the identified purposes or as required by law. Once the retention of Personal Information is no longer reasonably necessary or relevant for the identified purposes, nor required by law, it will be destroyed, erased or made anonymous.
Accuracy – We make reasonable efforts to keep Personal Information accurate, complete, and up-to-date as is necessary for the purposes for which it will be used.
Security safeguards– We will classify and protect Personal Information by security safeguards appropriate to the sensitivity of the information. We make reasonable effort to prevent any loss or misuse, or any unauthorized disclosure, destruction or modification, of Personal Information.
Individual Rights – Upon request, and as required by applicable laws, we inform authorized individuals of the existence, use and disclosure of their Personal Information and give them access to it as required by law. Individuals may challenge the accuracy and completeness of their information and have it amended, as appropriate. Subject to applicable laws, individuals may also request us to delete the personal information we hold about them. We will consider all such requests and provide our response within a reasonable period, and as required by such laws. Certain personal information may be exempt from such requests in certain circumstances.
Challenging compliance – Individuals may challenge compliance with the above principles by contacting our Chief Privacy Officer who is located at our corporate head office in Toronto, Canada. We also have individuals responsible for privacy in each jurisdiction in which we operate. If you have any questions, concerns or complaints about the handling of your Personal Information at Foresters, please contact a local privacy officer.
Chief Privacy Officer
789 Don Mills Road
Toronto, ON M3C 1T9