Ouverture de dossier en conformité
Because our firm seeks to ensure that the public is safe, our advisers are required to maintain liability insurance as long as they are registered with the Autorité des marchés financiers. Our minimum requirements vary depending on the status of the registrant. We ensure that you are well protected in case of a dispute. After all, by protecting you, we are protecting ourselves.
We believe in transparency. Our firm, and the partners-advisers, must maintain separate accounts, and cannot appropriate for personal purposes the funds entrusted to them. A register must be created for the separate account. At the very least, they keep an account for commissions, and a personal account. This ensures smooth and reliable accounting.
Representatives are given a training schedule at the beginning of each year. Training sessions with accredited instructors are also provided at our offices to continuing education units. We ask that each representative double the requirements of the Autorité des marchés financiers
Prior to offering any information or making a recommendation, our advisor must find out what your needs are. The client cannot relieve the adviser of this duty. The advisor must refrain from pressuring an individual to retain his services or purchase any products.
Advertising / Representations / Solicitation
When first meeting with a client, the representative will give him a business card or other document stating the following: his name, his business address, his phone number, his titles, his sectors of activity, the sector classes, and the name of the firm or partnership to which he is attached. When communicating with a client by phone, the representative must clearly identify himself. If you wish to have your name removed from our lists, please email us at firstname.lastname@example.org
Each representative is required to keep a register of the commissions received stating the name of the client, the date of transaction, the amount insured, the type of plan sold, the premium submitted, the base commission, the bonuses, the proposal number, the contract number, the date of issuance, the date of delivery, and any surcharge if applicable. There should also be a mention of any authorized commission sharing including the co-sharers’ names and their sectors of activity.
We are committed to high standards of professional responsibility. We ensure that the public is well protected.
Compulsory individual meetings take place weekly to discuss active files. We ensure that the code of ethics is followed to the letter. Furthermore, the firm also ensures that its officers and employees comply with the law.
Any complaint must be handwritten and submitted to the Autorité des marchés financiers with proof of receipt within 5 days.
Privacy / Client Files / Separate Forms
Confidentiality must be ensured in every respect at our representatives’ places of business. No file should be left unattended around the offices, and each one must be assigned its own secure password on our Web sites; filing cabinets must be under lock; client files must be colour-coded, with tan being used for life insurance, blue for critical illness, yellow for disability, red for long-term care, and green for investments. Other documents such as that containing medical information are also protected.
Analysis of Needs / Policy Renewal / Policy Replacement
Prior to filling out an insurance proposal, our representative must complete, with the policyholder or the insured, an analysis of the insurance requirements, the policies or contracts currently held, their features, the names of the insurers who issued them, and any other relevant information such as the policyholder or insured’s income, financial statements, number of dependants as well as personal and family obligations. All this information must be recorded in writing. We do not promote policy replacement but in such a case, the representative is required to fill out a notice of comparison and explain to his client the repercussions of this change. The representative has the burden to establish that such replacement is in the best interest of the policyholder. All relevant documentation must be forwarded to the replaced insurer within 5 days, with proof of receipt (e.g. UPS / ICS next day with signature), and stored in the client’s file.
The responsibility for the accounting records rests primarily on the firm.
Retention & Destruction of Accounting Records
It is our policy to retain data for a period of 10 years. The requirement in force in our industry is 5 years.
Our firm and representatives must handle with fairness all complaints received. Our complaints handling policy is customer-oriented. We maintain a complaints register and take pride in the fact that since its inception in 2005, no complaint has been recorded (as of early 2010).
Files / Documents Held / Documents Used
Discretion, confidentiality. Each client file must include an analysis of the financial needs, an analysis of the risk tolerance with respect to universal life insurance products or investments, a copy of any replacement notice if applicable, copies of any documents sent with proof of signature, proof of all fax transmissions, a log of all communications with the client and the insurer, the insurance proposal, and a notice of receipt of the final contract.
Employment Contract / Non-competition Clause / Non-solicitation Clause / Relations with Attached Individuals / Type of Enrollment
Intended for the protection of the public, and for the honest performance of the representatives’ activities, regardless of the sector classes to which they pertain. We ensure that the employees and agents act in full respect of the compliance policy.
Note: The 16 items selected and explained above do not cover the full extent of our compliance policy. They merely scratch the surface of the broad and complex topic of compliance.
What personal information do we collect?
Canadian privacy legislation defines personal information broadly as information about "an identifiable individual" or as information that allows an individual to be identified. The types of personal information that we may collect from you from time to time include: your name, address, telephone number, e-mail address, your forwarding address (e.g. during a vacation), previous address(es), your mailing preferences (such as "no scents", "no wrappers", etc.), delivery instructions, and individual customer service preferences (such as "do not solicit"). We sometimes ask our customers to complete surveys in order to get a better sense of who they are and what issues, products or services may be of interest to them.
Why do we collect your personal information?
We collect your personal information for the purposes listed below:
(a) To provide the product, service or information you requested
If you are a customer of InfoPrimes, we use your name and address (postal and/or e-mail) in order to deliver the information you requested, such as life or mortgage insurance calculations and to follow up with you about the insurance quote provided. If you enter acquire an insurance policy offered through one of our websites, we use your personal information to represent you on behalf of our insurance partners. (b) To send you information
From time to time we may send you further information about the service requested, its offers, or other products produced under its name.
To whom do we disclose your personal information?
We may disclose your personal information to the following third parties in the following circumstances:
(a) Disclosure to Service Providers
We may disclose your personal information to other companies that provide services on our behalf, including insurers and general insurance agents, auditors, our software developers (including website developers and hosts), data processing, document management and office services. We will only provide those companies the information they need to deliver the service and they are prohibited from using that information for any other purpose.
(b) Law Enforcement and Legal Disclosure
InfoPrimes may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where InfoPrimes has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to InfoPrimes's legal counsel. If you would prefer for us NOT to share your information as described above in sections (a)-(b), simply inform us (see "Contact Us" page).
Control of your personal information
At InfoPrimes, we want you to be able to maintain control over how we use your personal information. In particular:
You may have the right to "opt out" of some or all of the identified purposes, uses and disclosures listed in sections 3 and 4 above. You always have the option to instruct us not to use your name, address, e-mail address, etc. beyond providing you with the product, service or information you requested. See "Contact Us" page. E-mail communications will always include an identification of the sender and an "Unsubscribe" option. We regularly use the Canadian Marketing Association "do not mail/do not call" service to remove customers from marketing campaigns. As mentioned above, we may not be able to provide you with our services if you withdraw your consent to our use of your personal information.