Chubb Insurance Company of Canada (Chubb¹) has been a trusted provider of insurance to Canadian companies and individuals
since 1928. Chubb has earned that trust in part by its careful treatment of the personal information2 that customers entrust to our3 care in order that we can serve their insurance needs. Chubb does not sell personal information and Chubb staff have been
trained to treat personal information confidentially and with respect.
Further information about Chubb’s practices and policies with respect to its handling of personal information and compliance
with privacy laws follows.
Why Chubb Collects and Discloses Personal Information.
Chubb collects and discloses personal information only for the purposes of serving the insurance related needs of Chubb customers4. Among other things, this includes evaluating, monitoring and assessing insurance needs, providing risk management services,
underwriting, rating, binding, and issuing insurance policies and providing all policy related or administrative services,
including verifying information, loss control, compliance with regulatory requirements and claims investigation, surveillance,
detecting and preventing fraud, adjustment and coverage assessment. This also includes collecting and disclosing personal
information about third parties with respect to claims made against Chubb customers.
The Kinds of Personal Information Chubb Collects.
Chubb collects widely varying types of personal information. What we specifically collect depends on the particular purpose
for collection and the particular circumstances involved. Without limiting the generality of this and purely by way of example,
the type of personal information that Chubb may collect includes property descriptions, claims histories, driving records,
employment information, medical and health information and financial information.
How Chubb Obtains Personal Information.
Most of the personal information collected by Chubb is provided to us by insurance brokers. We believe that we deal with
the most professional and respected brokers in the insurance industry.
Chubb also obtains personal information from various third party sources as part of the underwriting process. For instance,
when we underwrite automobile insurance, we may obtain credit information and a record of driving offences. We may also obtain
claims or underwriting information from other insurance companies or insurance industry sources. When we insure the directors,
officers, employees, representatives or contractors of a company, we may obtain personal information about those individuals
from the company. Chubb’s insurance brokers are responsible for obtaining the consent of our customers with respect to the
collection of such information. Chubb and our brokers will infer such consent when appropriate. If an insurance broker tells
Chubb that we have a customer’s consent to collect information, we will rely on the broker’s advice.
Chubb and its affiliated companies collect personal information from a variety of sources in investigating, evaluating and
adjusting claims. Personal information required for claims purposes may be obtained from our customers, our customers’ insurance
brokers, or from third party sources. Chubb may collect such information directly or through insurance adjusters, private
investigators or lawyers representing Chubb or our insured. We require that only reputable and properly licensed insurance
adjusters and investigators investigate and adjust claims.
Consent may be obtained by Chubb directly or through the broker, an insurance adjuster, investigator or lawyer when personal
information is collected for claims purposes. Consent may not be obtained with respect to the collection of certain publicly
available information. If the information is collected with respect to an investigation involving the suspected breach of
an insurance policy (or other agreement) or breach of Canadian law, then consent may not be obtained.
In some cases, Chubb and our brokers will infer such consent when appropriate.
Chubb’s Disclosure of Personal Information.
Chubb discloses personal information, including to its affiliated companies, only for the reasons listed above or if required
to do so by law. By way of example, in order to provide various claims services we frequently disclose personal information
to third party service providers and others. These would include (but are not limited to) insureds, insurance brokers, insurance
adjusters, windshield repair companies, automobile repair shops, contractors, construction companies, investigators, engineers,
accountants, lawyers, and others. When Chubb discloses data containing personal information to insurance industry associations
or service providers, the disclosure is subject to confidentiality requirements.
Similarly, Chubb may be required to disclose personal information in order to obtain further personal information that it
requires for underwriting purposes. For instance, a name and insurance policy number may need to be provided to another insurance
company to obtain a claims history.
We obtain consent to disclosure when required. Generally, consent to disclosure is obtained by the customer’s insurance broker
(this consent may be obtained when the customer applies for or renews the insurance policy), by Chubb or by the service provider.
Consent may also be inferred when appropriate. If an insurance broker tells Chubb that we have a customer’s consent to disclose
information, we will rely on the broker’s advice.
As a member of a global group of companies, there may be circumstances where Chubb discloses your personal information to
our US parent, other affiliates, joint venture partners, employees, service providers, agents, reinsurers and any of their
service providers, some of whom may be located in jurisdictions outside Canada, and your personal information may be subject
to the laws of those foreign jurisdictions. All such persons, whether or not they are located in Canada, are required to
When consent is not required.
Knowledge and consent for the collection, use and disclosure of personal information are not required in many circumstances
when Chubb discloses personal information to an approved investigative body;
when we believe that the information relates to the breach of an insurance policy or other agreement and it would compromise
the availability or accuracy of the personal information relating to that breach;
when we believe that the information relates to the contravention of any
Canadian law, including the detection and prevention of fraud;
for compliance with subpoenas, search warrants, and other court or government
when personal information is disclosed to a lawyer retained by Chubb for claims purposes or to obtain legal advice;
when legal, medical, or security reasons may make it impossible or impractical to seek consent;
when under a public requirement to disclose personal information to appropriate authorities in matters of significant public
where the individual is a minor, seriously ill, or mentally incapacitated, and
seeking consent is impossible or inappropriate;
where the personal information is publicly available and is specified by the
when we are required by law to disclose the information.
How Chubb Ensures the Security of Personal Information.
Personal information recorded in documents is securely stored at Chubb’s offices and its employee’s offices in Canada and
at offices of Chubb’s affiliated companies. Electronically recorded information is stored on computer systems maintained
by Chubb and Chubb’s affiliated companies. Those computer systems and the information stored in them are protected by electronic
Chubb and its affiliated companies restrict access to personal information and Chubb employees, contractors and representatives
are under obligation to access personal information only when they have a legitimate business need to do so. Chubb employees
receive training with respect to proper personal information handling practices and they are under obligation to comply with
privacy laws, this policy and related codes of conduct.
Chubb’s compliance with appropriate personal information practices and privacy laws is overseen by and is the responsibility
of our Chief Privacy Officer.
Retention of personal information.
We will only retain personal information for as long as is necessary to fulfill the purposes for which it was collected or
as required by law.
Accuracy and Access to Personal Information.
Chubb is committed to the accuracy of the personal information that it uses or discloses.
You have the right to access the personal information we hold about you, subject to the following (and any other reasonable
or legal conditions which may be necessary), and, if the case may be, to request that the information be rectified if it is
inaccurate, incomplete, ambiguous or collected in violation of the law. A request to that effect must be sent in writing to
the Chubb Privacy Officer
We will not provide access in any of the following circumstances:
if doing so would likely reveal personal information about a third party;
if the information is subject to solicitor-client privilege;
if revealing the information would reveal confidential commercial information;
if revealing the information could affect the security of another person;
if revealing the information could compromise the investigation of a claim;
if the information relates to the actual or suspected breach of an insurance policy or other agreement or the breach of Canadian
if the information was generated in the course of a formal dispute resolution process.
Withdrawal of Consent.
Subject to certain legal and contractual restrictions and reasonable notice, you may
refuse or withdraw consent to the collection, use or disclosure of personal information at
any time. You should, however, be aware that if you withdraw your consent, we may no longer be able to provide you with insurance
coverage and services or that your coverage must be reassessed. If you wish to withdraw or alter your consent, a request to
that effect must be sent in writing to the Chubb Privacy Officer.
Policy” on our main website at http://www.chubb.com/international/canada/
Requests for further information, personal information access or complaints about Chubb’s handling of personal information
should be referred to Chubb’s Chief Privacy Officer, as follows:
Chubb Insurance Company of Canada
1 Adelaide Street East
Attention: Chief Privacy Officer
Please also refer to “Chubb’s Customer Advocate and Appeal Process” on our main website at http://www.chubb.com/international/canada/
1The Canadian branch of Federal Insurance Company also complies with the applicable elements of this policy. Federal Insurance
Company is an affiliate of Chubb Insurance Company of Canada.
2Personal information means any information that identifies a specific individual, other than information found in a business
3“We”, “our” and “us” refers to Chubb Insurance Company of Canada.
4“Customers” refers to individuals who are current and former policyholders and insureds or applicants for insurance.