We’re committed to protecting personal information and respecting your privacy. Our privacy policy (“policy”) explains how we handle the personal information we collect as part of our day-to-day business and lets you know about your rights when it comes to your personal information. We’ll always be clear about how and when we collect, use and share your personal information and we’ll never sell your personal information.

We may update this policy from time to time. If we do, we’ll post a notice on our website. Updates are effective on the date shown on this policy.

In this policy we refer to ourselves – The Canada Life Assurance Company and our Canadian subsidiaries – as “we”, “our” and “us”.

Our privacy officer monitors compliance with this policy.

What’s personal information?

Personal information is information that either on its own or combined with other information allows an individual to be identified. Examples include your name and address, as well as more sensitive information such as your health and financial records. When applicable, this includes information about other people such as your spouse, common-law partner, and children.

Learn more about how we collect, use, share, and protect your personal information as well as your privacy rights:

• How we collect personal information
  
• How we use personal information
  
• How we share personal information
  
• How we protect personal information
  
• Your privacy rights and how to manage them
  

How we collect personal information

We collect your personal information in three ways – directly from you, from other people and organizations, and from your use of our websites and mobile applications.

We collect personal information directly from you throughout our relationship with you. For example, we may collect personal information through paper or online applications for products and services, on the telephone, through online chat, or through email.

Depending on the products and services you have with us, we may also collect your personal information from other people and organizations. These can include your plan sponsor, advisor, healthcare provider, medical clinic, other insurance companies, government departments and agencies, and other organizations that help us provide you with the products and services you’ve requested.

When you visit our website or use our mobile applications (collectively Online Services), we’ll also collect your personal information using cookies. Cookies make your next visit easier by storing your preferences. You can control how we collect and use your personal information by visiting our cookie consent manager.

When we collect personal information, we’ll only collect what we need and we’ll tell you why we need it.

When applicable, the personal information we collect may also include information about your spouse, common-law partner, dependants and beneficiaries. We’ll ask you to confirm their consent for us to collect and use this information, and to communicate with you about them.

Type of personal information we collect

Depending on the product or service, we may collect the following types of personal information. We’ve included some categories and examples of personal information we collect. These examples aren’t intended to be exhaustive.

• Identification and contact information such as name, address, telephone number, email address, date of birth, social insurance number (SIN) when required, information on government-issued identification
  
• Authentication information such as passwords, answers to authentication questions, biometric information (physical and behavioural attributes that are unique to you), product and services identifiers such as a policy number
  
• Financial information such as annual income, assets, liabilities, banking information, investor profile
  
• Health or lifestyle information such as your travel history or plans, driving record, criminal record, health habits
  
• Medical information such as your healthcare provider’s name, medical history for you or your family
  
• Employment information such as your job and where you work, your work history, compensation records
  
• Online Services use such as your internet protocol (IP) address (a unique identifier for each device that connects to the internet), when you visit our site, which pages you visit and for how long
  

How we use personal information

We use your personal information to help you reach your mental, physical, and financial goals.

Depending on the products and services you have with us, your personal information may be used to:

Know who you are:

• Verify your identity and see if you’re eligible for products, services, coverage or careers you apply for
  
• Provide you with advice or quotes
  
• Maintain your profile and keep accurate records
  

If you provided your social insurance number (SIN), we’ll use it for tax reporting. Your SIN is also used to link your products together and to keep your information separate from other customers with similar names.

Maintain our relationship with you:

• Administer your products or services, including paying claims and processing transactions
  
• Inform you about features or benefits of products or services you already have with us
  
• Provide you with pricing and quotes for products that suit your needs
  
• Collect feedback on our customer service, including asking you to fill out optional surveys
  
• Collect feedback on how you use our Online Services, including asking you to set your cookie preferences
  
• Manage your records, and administer your compensation and/or benefits
  
• Improve our business operations, products and services – for more information, please refer to Using your personal information for data analysis
  

Respect the law and manage risk:

• Prevent and protect you and us from criminal activity, fraud, misrepresentation, or cyber crime
  
• Respond to requests to provide your information to law enforcement, courts, and/or other authorities inside and outside of Canada
  
• Comply with tax requirements
  

Offer personalized products and services and tailor your experience when you interact with us:

• Review your personal information to provide you with products and services that suit your needs
  
• Improve your experience by providing relevant information and offers
  
• Deliver advertisements for our products and services on websites and applications based on how you use our Online Services – for more information on how this works, refer to our Cookie Policy
  

Using your personal information for data analysis 

We use data and analytics technologies, such as artificial intelligence (AI) to improve our business operations, products and services. For example, these technologies help us identify and automate repetitive tasks, provide competitive pricing, offer new and improved customer service options like chatbots, optimize how we manage our workflow, personalize our communications and offers, and protect our business from fraud and financial crime.

The use of these technologies involves the analysis of large amounts of information, including personal information. When we use your personal information for this purpose, wherever possible we remove parts of your information, such as your contact information, so you can’t be identified. We’ll always handle your personal information in a respectful manner.

How we share personal information

We share your personal information with other people and organizations who help us administer your products and services. Some of these people and organizations may be located outside your province of residence or outside Canada. In that case, your information will be subject to the laws of the other jurisdiction, including any law permitting or requiring disclosure of the information to government agencies, courts, and law enforcement in that jurisdiction.

Other organizations we share your information with may include:

• Paramedical examiners
  
• Medical laboratories
  
• The Medical Information Bureau (MIB)
  
• Specialty coverage providers
  
• Claims assessors
  
• Independent medical examiners
  
• Pharmacy benefits managers
  
• Travel assistance providers
  
• Technology suppliers
  
• Legal services providers
  
• Creative and promotional agencies
  
• Print and mail services
  
• Record storage companies
  
• Pension and benefits administrators
  
• Other insurance and reinsurance companies
  
• Other financial institutions
  
• External auditors
  
• Credit reporting agencies.
  

Other people we share your information with include:

• Your advisor and people who work with your advisor
  
• Healthcare providers
  
• Plan administrator (including their service providers and advisors)
  

We may also share your personal information with our Canadian subsidiaries, government departments and agencies, law enforcement, courts and other authorities inside and outside of Canada to meet our legal requirements and to prevent or address criminal activity, fraud, misrepresentation or cyber crime.

How we protect personal information

Protecting personal information

We take protecting your personal information seriously. We have technical and organizational safeguards to protect personal information against loss and unauthorized access, use or disclosure.

Everyone who works at Canada Life, as well as the people and organizations who act on our behalf, are responsible for protecting personal information.

To do this, we have safeguards to protect personal information from unauthorized access. These include:

• Strict access management policies
  
• Proactive threat monitoring
  
• Data encryption
  
• Multi-factor authentication
  
• 24/7 monitoring of our offices
  
• Controlled access to the buildings we operate in
  

An example of our strict access management policies includes limiting access to personal information to:

• Canada Life employees or authorized contractors who need access to the specific personal information to do their job
  
• Other people you have authorized (examples include a power of attorney or other personal representative or advisor)
  
• Other people and organizations who help us administer your products and services
  

All employees and contractors are provided information security, privacy, and code of conduct training reinforcing the importance of protecting personal information.

How our service providers protect personal information

We make sure our service providers act in a way that’s consistent with this policy and applicable laws. They must contractually agree to comply with our standards for the protection and confidentiality of personal information, which includes protecting their systems against unauthorized access and applying security and privacy standards that match or exceed our own high standards.

Service providers can only collect, use, or disclose personal information for purposes we allow.

How long your information will be kept

We’ll only keep your information for as long as we need it, or for as long as is required by our policies and/or applicable laws. Where appropriate, we may anonymize personal information to protect it and to minimize the amount of personal information we retain.

Your privacy rights and how to manage them

You’re always in control of the personal information you have provided to us. You can choose how your personal information is used by updating your preferences through your online account or by submitting a privacy rights request in writing or through our privacy centre.

When it comes to your personal information at Canada Life, you have the following rights:

• The right to access your personal information.
  
• The right to correct your personal information if it’s inaccurate or incomplete.
  
• The right to delete your personal information.
  
• The right to change your consent options. This includes choosing whether you receive customer experience surveys, the use of your SIN for non-tax reporting purposes, and whether and how you want to receive information and offers from Canada Life using the personal information we collect from you throughout your relationship with us.
  
• The right to ask us about our privacy practices at Canada Life.
  
• The right to ask about any decision we made using automated processing. This includes being able to submit observations about the decision-making process to us.
  

There may be instances where we’re unable to fulfill your privacy request, subject to certain restrictions or laws. If this happens, we’ll let you know as soon as possible.

If you choose to remove your consent to the collection, use and disclosure of the personal information required to serve you and meet our legal obligations, we may not be able to continue to provide you with products and services. No matter what you choose, you’ll continue to receive information about the products and services you already have with us.​

Have any concerns, questions, or requests?

Contact us by writing to our privacy officer.

Canada Life Privacy Officer
The Canada Life Assurance Company
255 Dufferin Avenue | London, Ontario | N6A 4K1
privacy@canadalife.com

Last updated - September 2023