Privacy
Our privacy promise describes in clear language how ING ensures the protection of the personal information you entrust to us.
Please read this document carefully, not because anything in it is difficult to understand, but because we want you to know that ING protects your personal information. As you read you will come across certain specialized words, Industry Terms. We have underlined these words and provided definitions to make sure everything is perfectly clear. Simply click on an underlined term to see its definition.
We view our Privacy Promise as if it were an ING product, not just a legal obligation. And as you know, we believe in superior products.
When you became an ING client, you shared important personal information with us. You did this so we could serve you better and knowing we would honour and respect your privacy. Your trust was not misplaced. At ING we are committed to offering you superior products and services, so it should come as no surprise that we are also committed to meeting the privacy standards applicable to you.
Let's be perfectly clear.
What is personal information?
Personal information is information about an identifiable individual and includes employee personal information, but does not include the name, business contact information, or work product information of an employee of an organization.
What information are we responsible for protecting?
ING Canada is responsible for protecting your personal information in its possession or custody, including personal information that has been received from a third party or personal information that may not be in the custody of ING Canada but which has been transferred to a third party.
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Collecting, using and disclosing your personal information. Why do we do it?
We collect, use and disclose personal information for one reason: to serve you better. Knowing you better helps us understand your insurance and financial needs, communicate effectively with you, and provide you with the services and products you want.
Let's be specific.
We collect, use and disclose your personal information to:
- verify your identity
- determine your eligibility for ING Canada insurance and financial products and services, whether purchased through ING or your broker, and for products and services that may be of interest to you from organizations with whom we have
- strategic alliances, and to offer these products and services to you
- assess and underwrite insurance and reinsurance risks
- determine prices, fees and premiums
- investigate and settle claims
- detect and prevent fraud
- compile statistics, conduct market research, and report to regulatory or industry entities in accordance with prudent insurance practices, including claims history
- investigate specific transactions or patterns of transactions to detect unauthorized or illegal activities
- determine the suitability of your investments
- comply with the law
- or comply with tax requirements
Personal information may be collected, used or disclosed for any of these Identified Purposes set out above. If your personal information is not needed for one of the Identified Purposes, we will not use or disclose it without obtaining additional consent from you.
How do we gather your personal information?
The collection, use and disclosure of your personal information depend on how you do business with us. We may gather information from the following sources:
- from you, on applications for our insurance and investment products, or on other forms filled out through telephone, e-mail or face-to-face interviews (for example your name, address, telephone number, e-mail address, occupation, financial and banking information, and health information)
- from licensed agents, insurance brokers, intermediaries and financial services representatives with whom you have a relationship, as well as adjusters and inspectors
- from your interactions with us (for example through your payment history, underwriting and claims)
- from government and other entities, that have information on your driving record and claims history
- or from consumer reporting agencies (for example your credit history)
What you are committing to when you share personal information with us.
If you provide personal information to us or through any of the previously mentioned sources, you do so with the understanding that your personal information may be used or disclosed for the Identified Purposes amongst us, the previously mentioned sources, or third parties and that ING Canada may verify such information, or obtain additional personal information about you by checking with government agencies, credit bureaus, motor vehicle agencies and other fact collecting and verifying entities to assist us for the Identified Purposes.
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Your consent.
Your knowledge and consent are required before we may collect, use or disclose your personal information, except in special circumstances. These special circumstances include such times when your consent is deemed by law or not required by law. These circumstances may include during a fraud investigation, an investigation by the police, where the collection, use, or disclosure are reasonable for an investigation or proceeding resulting from a breach of an agreement, or in situations otherwise permitted by the law. If any of the personal information that we collect is sensitive, such as financial, we will obtain additional written or oral consent from you before collecting, using or disclosing the information.
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How do you provide us with your consent?
We accept any of the following as your consent for ING's existing use and future collection, use and disclosure of your personal information for the Identified Purposes:
- your receipt of this Personal Information Policy, unless you advise ING Canada, either orally or in writing, that you do not agree with the terms stated in this Policy, and that you wish to opt out of all or portions of it
- your unrestricted provision of information to ING Canada, either directly or through licensed agents, insurance brokers,
- adjusters or financial services representatives
- your express written or oral consent as obtained through an application process
- or your consent as provided by your authorized representative, such as a legal guardian or power of attorney
In some circumstances, your consent may not be required. For instance:
- If you obtain insurance for your family, or anyone else, you represent that you have obtained consent from them to the collection, use and disclosure of their personal information for the Identified Purposes, even though they might not be present during the application process.
- If you have an existing insurance policy with us and you request amendments to the policy, it is assumed that the consent which you gave to us when buying the original policy remains in effect.
- If you voluntarily provide personal information either orally or in writing for a purpose that would be considered to be obvious to a reasonable person.
- If the collection, use or disclosure of information is for the purpose of enrollment under an insurance plan if you are a beneficiary under the plan or have an interest as an insured under the plan.
- In the event that ING proceeds with a business transaction such as the purchase, sale, lease, transfer, merger or amalgamation or any other type of acquisition, disposal or financing of an organization or portion of an organization or of any of the business or assets of an organization, your personal information may be shared with such prospective party to complete the business transaction.
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You have the power to say no.
How you can withdraw your consent.
You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. If the withdrawal of consent would frustrate the performance of a legal obligation, your consent may not be withdrawn unless agreed to by us. Please note that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive. Furthermore, your withdrawal of consent does not prohibit ING from continuing to collect, use or disclose your personal information in the circumstances already outlined with respect to such times that your consent is deemed by law, such as in the course of an investigation or proceeding, or if your consent is not required by law.
To withdraw your consent, you should contact our Privacy Officer at the address or telephone number listed. Unless we hear otherwise from you, you are giving to us your consent for the collection, use and disclosure of personal information as provided in this Policy for the Identified Purposes.
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How long do we keep your personal information?
Your personal information is retained only so long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter in case we need to meet any legal or business purposes. If ING uses your personal information to make a decision that directly affects you, your personal information will be kept for at least one year following the collection and use of such information.
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How do we protect your personal information?
Whether in electronic or paper-based format, ING Canada maintains strict security systems to safeguard your personal information in its custody or under its control from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. When we no longer need your personal information, we take as much care to destroy it as we do when storing it.
In the event that we transfer your personal information to a third party for processing (for example, when printing cheques, managing claims and client statements, or for data processing), we contractually require any person or organization providing products or services on our behalf to protect our customers' confidentiality in a manner consistent with our own internal measures, or as required by law.
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Your right to access your personal information.
You have a right to access your personal information that we have under our control subject to any legal restrictions or rights of refusal of ING Canada. You also have a right to know which third parties have received your information from ING Canada.
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How do you access your personal information?
Please make your request in writing to ING Canada's Privacy Officer, stating as specifically as possible which personal information you are requesting.
We will try to respond to such requests as soon as possible, and will advise you if for some reason we cannot respond right away. ING Canada may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost, at which time a deposit may be requested for the preparation of your access request.
ING Canada has the right or legal obligation to refuse your request for access to personal information if:
- the information is protected by solicitor-client privilege
- granting access could reveal confidential commercial information
- doing so would reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request
- doing so can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request
- the personal information was collected for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed
- the disclosure would likely reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity
- the information is generated in the course of a formal dispute resolution process
- or the information would likely reveal personal information about another individual.
ING may refuse in a response to confirm or deny the existence of personal information collected as part of an investigation when access to all or part of the personal information requested by the applicant is declined.
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Keeping your information accurate.
A priority.
ING Canada strives to ensure that the personal information we have on file about you is as accurate and up-to-date as necessary for the Identified Purposes for which it is to be used. If ING is satisfied on reasonable grounds that request to correct an error or omission of personal information should be implemented, we make every effort to correct our records.
ING Canada shall amend personal information that is materially inaccurate or incomplete and, where appropriate, shall endeavour to advise other parties having access to the information in question.
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If you have a complaint, we want to know about it.
If you have a complaint related to this Personal Information Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our Policy and practices, if necessary.
If we are not able to resolve your concern, or if you have any other concerns about ING Canada's Personal Information Policy and procedures, you may contact the Office of the Privacy Commissioner of Canada or, if applicable, the provincial Privacy Commissioner. ING Canada's Privacy Officer will provide you with this contact information upon request.
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Industry terms, and what they mean.
adjuster- representative of an insurance company who is licensed to investigate claims which are submitted and to negotiate the amount of the settlement, if any.
power of attorney - authority given to one person or corporation to act on behalf of another person or corporation legal and financial matters.
reinsurance risks - Reinsurance is when an insurance company places all or part of the insurance with another insurance company, who will then be responsible for a percentage of the risk or loss. This does not affect you in any way.
third party - person other than you who is involved in a transaction.
underwrite - To estimate the value and determine at what amount and on what terms the insurance company will provide insurance. Underwrite is another way of saying insure.
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About this document.
This Personal Information Policy spells out the responsibility of the ING Canada group of companies (ING Canada, ING, we, our, us), and your rights as our applicant, customer, former customer or claimant (you or your), regarding the collection, use and disclosure of your personal information. The ING Canada group of companies includes ING Canada Inc., ING Canada Holdings Inc., ING Insurance Company of Canada, ING Novex Insurance Company of Canada, Belair Insurance Company Inc., The Nordic Insurance Company of Canada, ING Wealth Management Inc., ING Insurance Services Inc., ING Investment Management, Inc., Equisure Financial Network Inc. and its broker subsidiaries, and Wellington Warranty Company Inc.
This Personal Information Policy is subject to any amendments, which will be posted on ING Canada's website and will also be available from ING Canada's Privacy Officer by calling 1 866 941 5094.
How to contact us. Easy.
Updated versions of this Personal Information Policy are posted on ING Canada's website at www.ingcanada.com, or you can direct any queries about this Policy to ING Canada's Privacy Officer at the telephone, e-mail address, or mailing address listed below.
For more information, to file a complaint, to make enquiries, or to opt out of all or parts of this Policy, please contact ING Canada's Privacy Officer:
ING Canada Privacy Officer
700 University Avenue, 15th Floor
Toronto, Ontario
M5H 3M7
Telephone No.: 1 866 941 5094
Fax No.: 416 941 5322
E-mail address: privacy@ingcanada.com
Our strategic alliances
Our Strategic Alliances include ING Bank of Canada, Zurich North America Canada, Chubb Insurance Company of Canada, 21st Century Travel Insurance Limited, Groupe Estrie-Richelieu Insurance Company, The Boiler Inspection and Insurance Company of Canada, CAA Quebec, The Wholesale Group, EMC Underwriting, Genmark, and South Western Group.
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