Privacy & Security Policy
Our Website Visitor Statistics
Homebrella (a division of Kevin Orr Associates Canada Inc.) is working with a third party provider, Google Analytics, to track usage on our Website. Google uses cookies to provide statistical information about our Website, for example, numbers of visits to pages, the duration of individual page views, paths taken by visitors through the Website and other general information. None of the information can be traced to an individual. Homebrella does not know who you are, merely that there are a certain number of people using the Website. The cookie only relates to what goes on in Homebrella’ Website and it cannot be used for marketing on an individual basis.
What are cookies?
A cookie is a small file of letters and numbers downloaded onto your computer so that it can recognize your computer at a later time. Cookies are commonly used on the Internet and do not harm your system. Cookies enable users to navigate around the website and (where appropriate) enable Homebrella to tailor content to fit the need of users.
You have the opportunity to configure your browser to accept/reject cookies or to notify you when a cookie was issued. Rejecting cookies, however, means that certain personalized services on the Website cannot be provided to you.
Please refer to your computer operating system user manuals for more information on how to disable and delete cookies.
Our Organization
SECTION I. Introduction
We are committed to providing our clients with excellent service and meeting their needs. Whereby interaction involves providing information about yourself, the protection of your personal information is one of our highest priorities.
Canadians are protected by two federal privacy laws, the Privacy Act and the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA is based on the Canadian Standards Association's Model Code for the Protection of Personal Information, which is incorporated into the legislation.
We have a solid track record of respecting your right to privacy and safeguarding your personal information. You can be assured that we'll only handle your personal information in a manner that a reasonable person would consider appropriate as we strive to provide you with the best possible experience and service.
This Privacy & security Policy outlines Homebrella’ responsibilities and commitments to protect your personal information. In particular, the Policy addresses:
SECTION II. Legislation
Federal legislation known as the Personal Information Protection and Electronic Documents Act and similar provincial legislation ("privacy legislation") govern Homebrella’ collection, use and disclosure of personal information. Homebrella has practices and procedures that satisfy the standards set out in privacy legislation.
In accordance with privacy legislation, Homebrella follows ten Fair Information Principles.
SECTION III. What is "Personal Information"?
Personal information is defined in legislation as information about an identifiable individual, excluding the name, title, business address or telephone number of an employee of an organization. Some examples of personal information Homebrella may collect include but are not limited to:
We may obtain this information from:
SECTION IV. When and Why Homebrella Collects Personal Information
Homebrella uses and discloses the personal information collected for various purposes:
In order to protect your personal information and right to privacy, we will:
Homebrella never sells personal information, or other information relating to you, to any organization, including charities or direct marketing groups.
SECTION VI. Consent
SECTION VII. Requests to Access Your Personal Information
You may request access to your personal information that has been collected, used or disclosed by Homebrella. To do so, please contact the Privacy Officer by letter or e-mail at the addresses set out below. Access requests must be in writing. We will reply to your request within 30 days.
Please note that email is not a secure mode of communication. For security reasons, do not include sensitive or confidential information in any email message.
Please note that Homebrella may charge reasonable costs in providing access to and copies of personal information and will inform you if such costs arise.
Homebrella may refuse an access request in situations where:
SECTION VIII. For Further Information
This Privacy & Security Policy sets out Homebrella’s commitment to safeguarding your personal information. The examples clarify Homebrella’ practices with respect to the collection, use and disclosure of personal information, however, they do not represent a complete list of circumstances in which Homebrella collects, uses and discloses information to administer insurance policies.
Homebrella may update its Privacy & Security Policy to adhere to changes in legislation or to improve service to our policyholders. Please refer to our website for the current Privacy & Security Policy or contact Homebrella’ Privacy Officer.
If you would like more information regarding Homebrella’s Privacy & Security Policy and practices, please do not hesitate to contact the Privacy Compliance Officer.
Telephone: +1 (866) 320-7098, Option 3
E-mail: [email protected]
ATTN: Privacy Compliance Officer | Homebrella c/o Kevin Orr Associates Canada Inc.
If Homebrella’s Privacy Compliance Officer does not resolve a Privacy & Security issue to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada by writing to:
Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, ON K1A 1H3
Homebrella (a division of Kevin Orr Associates Canada Inc.) is working with a third party provider, Google Analytics, to track usage on our Website. Google uses cookies to provide statistical information about our Website, for example, numbers of visits to pages, the duration of individual page views, paths taken by visitors through the Website and other general information. None of the information can be traced to an individual. Homebrella does not know who you are, merely that there are a certain number of people using the Website. The cookie only relates to what goes on in Homebrella’ Website and it cannot be used for marketing on an individual basis.
What are cookies?
A cookie is a small file of letters and numbers downloaded onto your computer so that it can recognize your computer at a later time. Cookies are commonly used on the Internet and do not harm your system. Cookies enable users to navigate around the website and (where appropriate) enable Homebrella to tailor content to fit the need of users.
You have the opportunity to configure your browser to accept/reject cookies or to notify you when a cookie was issued. Rejecting cookies, however, means that certain personalized services on the Website cannot be provided to you.
Please refer to your computer operating system user manuals for more information on how to disable and delete cookies.
Our Organization
SECTION I. Introduction
We are committed to providing our clients with excellent service and meeting their needs. Whereby interaction involves providing information about yourself, the protection of your personal information is one of our highest priorities.
Canadians are protected by two federal privacy laws, the Privacy Act and the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA is based on the Canadian Standards Association's Model Code for the Protection of Personal Information, which is incorporated into the legislation.
We have a solid track record of respecting your right to privacy and safeguarding your personal information. You can be assured that we'll only handle your personal information in a manner that a reasonable person would consider appropriate as we strive to provide you with the best possible experience and service.
This Privacy & security Policy outlines Homebrella’ responsibilities and commitments to protect your personal information. In particular, the Policy addresses:
- the purposes for which we collect, use and disclose personal information;
- the nature of the personal information we collect, use and disclose;
- when and why Homebrella collects personal information;
- the meaning of implied and express consent to collect, use and disclose personal information and when consent is not necessary;
- how Homebrella uses and discloses personal information; and
- your ability to access your personal information held by Homebrella.
SECTION II. Legislation
Federal legislation known as the Personal Information Protection and Electronic Documents Act and similar provincial legislation ("privacy legislation") govern Homebrella’ collection, use and disclosure of personal information. Homebrella has practices and procedures that satisfy the standards set out in privacy legislation.
In accordance with privacy legislation, Homebrella follows ten Fair Information Principles.
- Accountability. Homebrella’s Privacy Officer is accountable for The Company's compliance with these ten Fair Information Principles.
- Identifying Purposes. Where required, Homebrella will explain why the collection of personal information is necessary.
- Consent. Homebrella relies on your consent prior to collecting, using or disclosing your personal information. Exceptions arise where use or disclosure is required or permitted by law - for example, in the course of a criminal investigation.
- Limiting Collection. Homebrella collects the personal information necessary to initiate employment or contracting applications; and requests for Government of Canada security clearances.
- Limiting Use, Disclosure and Retention. Homebrella will not use or disclose personal information for a reason other than the purpose for which it was collected. Homebrella will retain personal information only as long as necessary to fulfill the purposes for which it was collected and as required by law.
- Accuracy. Homebrella makes best efforts to monitor and update the accuracy of personal information as needed to provide insurance coverage and respond to claims.
- Safeguards. Homebrella takes steps to safeguard personal information by using safe storage procedures and technological measures which limit access to the information to authorized employees. Where personal information is disclosed to third party service providers, Homebrella requires the service providers to also protect the personal information.
- Openness. Homebrella’s Privacy & Security Policy is readily accessible on Homebrella’s Website. On request, a printed copy will be provided.
- Individual Access. Homebrella recognizes your right to access your personal information held by Homebrella. If access must be denied, according to privacy legislation, Homebrella will provide an explanation for the denial.
- Addressing Privacy Concerns. Homebrella’s Privacy Officer welcomes enquiries about our Privacy & Security Policy and privacy practices.
SECTION III. What is "Personal Information"?
Personal information is defined in legislation as information about an identifiable individual, excluding the name, title, business address or telephone number of an employee of an organization. Some examples of personal information Homebrella may collect include but are not limited to:
- Basic information such as your name, address, telephone and mobile numbers, e-mail address;
- Credit and past payment records;
- Employment information.
We may obtain this information from:
- You;
- Credit organizations; and
- Financial institutions.
SECTION IV. When and Why Homebrella Collects Personal Information
- The Collection of Personal Information for Employment or Contract Engagements
To assess your suitability and candidacy, personal information such as your date of birth and occupation, your past employment | work experience may be required. - The Collection of Personal Information for Security Clearance
To assess your suitability for a Government of Canada security clearance, personal information such as your date of birth, family history, occupation, your past employment/work experience, and other information will be required. The type of personnel security clearance you need is determined by the requirements of your contract, as defined by the Contract Security Program.
Homebrella uses and discloses the personal information collected for various purposes:
- to assess an application for employment;
- to assess an application for a contract engagement;
- to initiate and apply for a Government of Canada Security Clearance;
- to analyze risk; and
- as may be required or authorized by law.
In order to protect your personal information and right to privacy, we will:
- not collect, use or disclose your personal information for any purpose other than those that we identify to you;
- keep your personal information only for as long as we need it to fulfill the stated purpose or as required by law;
- maintain your personal information in as accurate, complete and up-to-date a form as possible;
- safeguard your personal information to the best of our ability;
- respond to any request you may make to access or correct the personal information we hold about you;
- obtain the appropriate consent from you for the collection, use or disclosure of your personal information.
Homebrella never sells personal information, or other information relating to you, to any organization, including charities or direct marketing groups.
SECTION VI. Consent
- Implied Consent
Consent to collect, use or disclose personal information can be implied or express. Implied consent is inferred from the circumstances, including the relationship between the parties and the nature of the interaction. - Expressed Consent
When Homebrella handles sensitive personal information; Homebrella obtains express written or verbal consent. In these circumstances, the sensitive personal information is not collected until a request for employment/contract or a security clearance is made and it becomes necessary for Homebrella to help obtain such information to initiate said request. Express consent is obtained at the time of the request/application. - Exceptions to Consent
Privacy legislation sets out situations in which consent to collect, use or disclose personal information is not necessary. Some examples of when it is not necessary for Homebrella to obtain consent include when the information is:
• disclosed to our lawyers;
• used to collect debts owed to us by customers; or
• used during an investigation of potential fraud, other policy breaches, or other illegal acts. - Withholding or Withdrawing Consent
You may withhold or withdraw your consent; however, this may affect Homebrella’a ability to provide services as request. Where the withdrawal or withholding of consent prevents Homebrella from providing adequate customer service, Homebrella may be unable to help process your application(s) or clearance(s). In some cases, we may be unable to honor the withdrawal or withholding of consent.
SECTION VII. Requests to Access Your Personal Information
You may request access to your personal information that has been collected, used or disclosed by Homebrella. To do so, please contact the Privacy Officer by letter or e-mail at the addresses set out below. Access requests must be in writing. We will reply to your request within 30 days.
Please note that email is not a secure mode of communication. For security reasons, do not include sensitive or confidential information in any email message.
Please note that Homebrella may charge reasonable costs in providing access to and copies of personal information and will inform you if such costs arise.
Homebrella may refuse an access request in situations where:
- such access would hinder an investigation relating to the enforcement of any law, including alleged fraud;
- the information is protected by solicitor-client and/or litigation privilege;
- to do so would reveal confidential commercial information - where possible, Homebrella will provide access after removing the confidential information;
- it is prohibitively costly to provide the information;
- the information contains references to other individuals - where possible, Homebrella will provide access after removing the references to other individuals; or
- the information was created in the course of a formal dispute resolution process, such as mediation or arbitration.
SECTION VIII. For Further Information
This Privacy & Security Policy sets out Homebrella’s commitment to safeguarding your personal information. The examples clarify Homebrella’ practices with respect to the collection, use and disclosure of personal information, however, they do not represent a complete list of circumstances in which Homebrella collects, uses and discloses information to administer insurance policies.
Homebrella may update its Privacy & Security Policy to adhere to changes in legislation or to improve service to our policyholders. Please refer to our website for the current Privacy & Security Policy or contact Homebrella’ Privacy Officer.
If you would like more information regarding Homebrella’s Privacy & Security Policy and practices, please do not hesitate to contact the Privacy Compliance Officer.
Telephone: +1 (866) 320-7098, Option 3
E-mail: [email protected]
ATTN: Privacy Compliance Officer | Homebrella c/o Kevin Orr Associates Canada Inc.
If Homebrella’s Privacy Compliance Officer does not resolve a Privacy & Security issue to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada by writing to:
Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, ON K1A 1H3