Personal Information Protection Policy

INTRODUCTION

The Wawanesa Mutual Insurance Company (“Wawanesa”) is committed to protecting the personal information of its Customers. The Company has developed this Personal Information Protection Policy (the “Policy”) to provide information regarding the Company's approach to the management and control of personal information collected in the course of its business.

This Policy, in compliance with all applicable privacy legislation, including without limitation the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), British Columbia's Personal Information Protection Act, Alberta's Personal Information Protection Act, and Quebec's An Act respecting the protection of personal information in the private sector (collectively, the “Privacy Laws”), addresses two broad issues:

1. the way in which Wawanesa collects, uses, discloses and protects personal information; and

2. the right of Customers to have access to personal information about themselves and, if necessary, to have the information corrected.

Wawanesa strives to balance its Customers' right of privacy concerning their personal information with its own need to collect, use or disclose personal information in the course of its business.

The ten interrelated principles set out in PIPEDA (the “Privacy Principles”) form the basis of this Policy. Each principle is accompanied by a commentary that elaborates on the principle. To the extent that this Policy

(a) conflicts with the Privacy Laws or other applicable legislation, the provisions of such legislation shall prevail; or

(b) omits any rights or obligations of either Wawanesa or its Customers under the Privacy Laws or other applicable legislation, such provisions are deemed to be incorporated into this Policy.

DEFINITIONS

The following definitions apply in this Policy:

“Collection” means the act of gathering, acquiring or obtaining personal information from any source, including third parties, by any means. Personal information necessary to carry on its business may be collected by Wawanesa, its agents and brokers, or their authorized agents.

“Consent” means voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of Wawanesa. Implied consent arises where consent may reasonably be inferred from the action or inaction of the Customer. For further information, please refer to the commentary accompanying Principle Three.

“Customer” means an individual about whom Wawanesa collects personal information in order to carry on its business and includes individuals who are insureds, former insureds, applicants, claimants, individuals involved in a claim, and individuals insured as part of a group or corporate policy.

“Personal information” has the meaning ascribed to it by the Privacy Laws and related regulations, and includes an individual's name, address, telephone number, date of birth, family status, marital status, occupation, medical and health records, assets, liabilities, income, credit rating, credit history, credit and payment records, banking information, previous insurance experience (including claims history), and driving record, as well as information concerning whether or not credit was previously extended or refused to the individual.




AM Best