Principle One: Accountability ~ Full Text

1. PRINCIPLE ONE: ACCOUNTABILITY

Wawanesa is responsible for personal information under its control and shall designate an individual or individuals who are accountable for Wawanesa's compliance with the Privacy Principles.

1.1 The individual designated to oversee Wawanesa's compliance with this Policy is

Vice President, General Counsel and Secretary
The Wawanesa Mutual Insurance Company
900-191 Broadway
Winnipeg, Manitoba R3C 3P1

(the “Designated Individual”).

1.2 Accountability for Wawanesa's compliance with this Policy rests with the Designated Individual, even though other individuals within Wawanesa may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within Wawanesa may be delegated to act on behalf of the Designated Individual.

1.3 Wawanesa is responsible for personal information in its possession or custody, including information that has been transferred to a third party service provider for processing or storage. In such circumstances, Wawanesa will provide only the information necessary to perform such services and will use contractual or other means to provide a comparable level of protection while information is being processed or stored by the third party service provider. In the event that the third party service provider is located in a foreign jurisdiction, it is bound by the laws of that jurisdiction, which may require it to disclose personal information to the courts, law enforcement agencies, or national security authorities of the jurisdiction. Information concerning Wawanesa's policies and practices with respect to service providers outside Canada may be obtained from Wawanesa's website or by contacting the Designated Individual.

1.4 Wawanesa has implemented and will maintain policies and procedures to give effect to the Privacy Principles, including the following:

  1. procedures to protect personal information; and
  2. procedures to receive and respond to complaints and inquiries.

Additionally, Wawanesa

  1. has developed information to explain Wawanesa's policies and procedures; and
  2. trains staff and provides them with information about Wawanesa's policies and procedures.



AM Best