Privacy & Complaints Officer – Colette Rezansoff - 204.925.8262
As professional wholesale brokers and managing general agents we at TCIM have always been committed to holding our client’s personal information (including the clients of our brokers) in strict professional confidence, and we only disclose such information if authorized by you through your broker, or if required by law to do so or required to do so in conducting negotiations with underwriters or insurers. Our Privacy Code builds on this commitment.
TCIM requires that its brokers comply with all relevant legislation, with which we also comply.
Principle #1 – accountable
TCIM is accountable for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions. TCIM has established policies and procedures to comply with this declaration, and has designated a privacy officer to be accountable for compliance.
Principle #2 – through its brokers, will identify purposes
TCIM through its brokers will identify the purposes for which it collects personal information, before or when the information is collected.
Principle #3 – through its brokers, will get the clients consent
TCIM through its brokers, will make a reasonable effort to make sure customers understand how their personal information will be used by the brokerage and insurers. TCIM, through its brokers will obtain consent from its customers before or when it collects or uses the personal information.
A customer’s consent can be express, implied, or given through an authorized representative. A customer can withdraw consent at any time, with certain exceptions.
Principle #4 – limits the collection of personal information
TCIM limits the amount and type of personal information it collects. Each broker will collect personal information for the purposes identified to the customer. TCIM collects personal information using policies and procedures which are fair and lawful.
Principle #5 – limits the use, disclosure and retention of personal information
TCIM will use or disclose personal information only for the reasons it was collected, unless a customer gives consent to use or disclose it for another reason, or it is permitted or required by law.
Under certain exceptional circumstances, TCIM may have a legal duty or right to disclose personal information without the customer’s knowledge or consent to protect the interests of insurers or the public interest.
TCIM will keep personal information only as long as necessary for the identified purposes for which it was collected.
Principle #6 – will keep personal information accurate
TCIM will keep personal information as accurate, complete and current as necessary for the identified purposes for which it was collected.
Principle #7 – Safeguards Client Information
TCIM protects personal information with safeguards appropriate to the sensitivity of the information.
Principle #8 – makes it’s Information Policies Available to it’s Clients
TCIM is open about the policies and procedures it uses to manage personal information. Customers have access to information about these policies and procedures. The information will be made available in a manner that is generally easy to understand.
Principle #9 – makes Personal Information Accessible
When customers make a request in writing, TCIM will within a reasonable time tell them what personal information it has, what it is being used for, and to whom it has been disclosed.
When customers request it in writing, TCIM will give them access to their personal information. TCIM will respond to the written request in a timely fashion. In certain situations, however, TCIM may not be able to give customers access to all their personal information. TCIM will explain the reasons for this lack of access and any recourse the customer may have, except where prohibited by law.
Principle #10 – is Committed to Addressing Client Complaints and Concerns
Customers may challenge TCIM’s compliance with this declaration. TCIM has policies and procedures to receive, investigate, and respond to customers’ complaints and questions. Customers may learn about these polices and procedures by contacting the brokerage privacy officer at 204.925.8268. Appeal Form