In this document, you and your mean any individual whose personal information we collect, use and disclose as described in this policy and we, us and our mean Sun Life Financial Inc., Sun Life Assurance Company of Canada and their affiliates in Canada. View the list of Sun Life Financial group of companies.
Our commitment to protecting your privacy, our policy
Collecting personal information about you is essential to our ability to offer you high-quality investment, retirement and insurance products and to provide you with on-going service relating to your lifetime financial needs. We take great care to keep your personal information which we collect accurate, confidential and secure.
Our Policy sets high standards for collecting, using, disclosing and storing personal information. Sun Life Financial's Canadian Privacy Policy is complemented by our Privacy Code, our online Privacy Statement and by practices and procedures to manage your personal information.
Sun Life Financial's Privacy Policy for Canada
How we collect, use and disclose personal information
How we collect
We may collect information about you in writing, electronically or verbally. If we collect your information by telephone, the call may be recorded for monitoring, quality improvement and training purposes, or to create a record of your information and your instructions.
We ask you for only the information we need
We only collect the information about you that we need, such as financial, health, lifestyle and contact information, from you and other persons for the purpose identified to you.
Our files containing information about you are kept for the purpose of providing and servicing financial, insurance and investment products and services that we believe are right for you, over your lifetime.
We will not sell your personal information.
Why we need the information
Generally, we need to collect personal information to:
- understand your needs, the suitability of our products and services, and assess future needs through customer surveys, market research and analysis,
- determine your eligibility,
- continue to offer you and administer the full range of products and services that you have with us, in accordance with legal requirements,
- identify you and implement risk management programs and procedures to protect against fraud, errors or misrepresentations, and
- meet regulatory or contractual requirements.
We will obtain your permission
We collect, use or disclose your personal information with your permission for the purpose identified, or as allowed or required under the law.
Your permission may be expressed in writing or be implied and you may give it to us verbally, electronically, or through your authorized representative.
You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice. However, without your permission we may not be able to provide you with the products or services you requested.
Before we make information available to third parties, other than an advisor, reinsurer or service provider who needs it to conduct tasks on our behalf, we will tell you at the time we obtain your consent or before we make the information available who those persons or organizations are, the kind of information we need to share with them and why.
You have a choice
We may occasionally inform you of other financial products and services that we believe meet your changing needs. If you do not wish to receive these offers, let us know by calling 1 877 SUN LIFE (1 877 786 5433). If you ask us to remove your contact information from our marketing records, we will do this in a timely fashion.
We will limit how long we keep information
We will keep your personal information as long as legally or operationally necessary.
We will protect your personal information
We are responsible for your information
We are responsible for all personal information in our possession, including information transferred to a third-party service provider or agent, so that we can provide you with a product or service. Sometimes, unless we are otherwise prohibited, our employees, distribution partners such as advisors, and third-party service providers, along with our reinsurers and any of their service providers, may be located in other provinces or countries outside Canada, and your personal information may be subject to the laws of those provinces and countries. All such persons, whether or not they are located in Canada, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy policy and practices.
How we protect information
Access to your personal information is restricted to those of Sun Life Financial's employees, distribution partners and authorized third-party service providers who need it to do their jobs.
We have developed and continue to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a "need-to-know" basis, and technological measures such as the use of passwords and encryption. While we endeavour to protect all information, the most sensitive information, such as medical information, receives the highest level of protection.
Your right to access your personal information
Your rights
You have the right to ask in writing whether we hold any personal information about you, to see that information, and how we collect, use or disclose your personal information. We may not be able to provide you with all the information you request, depending on the circumstances, and there may be a charge for any copy of personal information requested. Where we have obtained medical information about you from a third party, we will release this information only through your physician.
How to request an update or correction
If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it, or you may contact us to update your personal information in our records.
If you show that your personal information is inaccurate or incomplete, we will make the necessary changes as appropriate.
If you feel we have not dealt with your request to your satisfaction, you can follow our customer complaint process, available online at www.sunlife.ca.
How to register complaints
You may register a privacy-related complaint by contacting Sun Life Financial's Canadian Privacy Officer. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right, including changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.
For more information and how to contact us
If you have any questions about Sun Life Financial Privacy Policy and Privacy Code for Canada, and to obtain information about our privacy practices, please contact us by sending a written request by e-mail to privacyofficer@sunlife.com, or by mail to Privacy Officer, Sun Life Financial, 1 York Street, Toronto, Ontario, M5J 0B6, Canada or you can also contact us at 416-408-8850.
Visit our website at: www.sunlife.ca
Sun Life Financial's Privacy Code For Canada
Principle 1 - Accountability
Each member company, employee or agent of the Sun Life Financial group of companies in Canada is responsible for personal information under his or her control and each member company shall designate an individual or individuals to be accountable for compliance with this Code.
Principle 2 - Identifying Purposes
The purposes for which personal information is collected shall be identified before or at the time the information is collected.
Principle 3 - Consent
The prior knowledge and permission of the individual are required for the collection, use or disclosure of personal information, except for legal or security reasons.
Principle 4 - Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.
Principle 5 - Limiting Use, Disclosure and Retention
Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law.
Principle 6 - Accuracy
Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.
Principle 7 - Safeguarding Information
Personal information will be protected by safeguards appropriate to the sensitivity of the information.
Principle 8 - Openness
Members of the Sun Life Financial group of companies will make readily available to their customers specific information about our policies and procedures relating to the management of their personal information.
Principle 9 - Individual Access
Upon request, an individual will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 - Handling Customer Complaints and Suggestions
Individuals can address any complaint regarding compliance with the above principles with our Privacy Officer.
