Protecting Your Privacy (Abridged)
Information in relation to customers of our funeral service establishment members
GFD serves as a funds management association for Funeral Establishments. By law, all pre-paid contracts for funeral services must be held by a third party financial institution.
Under no circumstances will we deal with the clients of our Member funeral establishments. Any account inquiries must be made by the owner of the funeral contract (the one who paid for the contract) and directed to the Funeral Establishment on the contract.
We are not allowed to give out any information about a client’s account whether it may be a possibility that a pre-paid contract may or may not exist. All inquiries must go back to the funeral establishment including funds moving to a new funeral establishment, account updates, accrued interest, cancellations and partial refund.
Protecting Your Privacy (Unabridged)
This privacy statement applies to Guaranteed Funeral Deposits of Canada (Fraternal) (“GFD”, “we”, “us”, “our”) and explains how we collect, use and disclose the personal information of the individuals we deal with in Canada whether online or offline. “Personal information” is information about an identifiable individual, as more particularly described under applicable privacy legislation. This privacy statement does not apply to personal information about employees or any volunteer or individual assigned to GFD on secondment or contract from a third party (collectively, “employees of GFD”) or to information that is not personal information.
This privacy statement refers to Canadian Funeral Establishment/Transfer Services hereafter referred to as “funeral establishment”.
The Information We Collect and How We Use It
Information in relation to funeral establishment clients and potential clients
GFD offers and provides funding options, services and reporting for preneed funeral establishment services to its funeral establishment clients (“clients”). The kinds of personal information we and our agents and representatives collect and use in relation to clients and potential clients will depend upon the information and services requested. However, it may include:
- name, address, contact details, and any other information you give to us when you interact with us or when you request receipt of materials concerning our services;
- information about individuals we collect in the course of performing services for clients;
- information about you contained in communications within GFD and between us and you, whether online or offline; and
- such other information we may collect with consent or as permitted or required by law.
We generally collect and use personal information necessary to offer and provide clients and potential clients with these services and information and to generally fulfil our legal responsibilities and manage our business including for the following purposes:
- offering and providing information and our services to our funeral establishment clients;
- responding to your requests and inquiries; ·administering our client databases;
- providing you with material on our services; ·managing, administering, collecting or otherwise enforcing accounts;
- maintaining business records for reasonable periods, and generally managing and administering our business;
- meeting legal, regulatory, insurance, security and processing requirements, and otherwise with consent or as permitted or required by law.
Information in relation to customers of our funeral establishment clients
GFD receives information about individuals who are customers of GFD’s funeral establishment clients. The information collected from the funeral establishment about their customers, may include: name, address, amount of the investment, and any other information our clients may deem necessary to provide services on their behalf.
We provide services to our funeral establishment clients and do not deal directly with preneed customers. Accordingly, we rely on our funeral establishment clients to obtain any consent necessary in connection with the collection, use and disclosure of personal information that they provide to GFD. We limit our activities with respect to the personal information provided to us by our funeral establishment clients about their customers to what is necessary to provide and carry out our services to our funeral establishment clients or as permitted or required by law. Preneed customers should direct any questions about their personal information to the funeral establishment they deal with.
How We Collect Information About You
We collect personal information directly from the funeral establishment. For example, in the course of providing services to our funeral establishment clients, they provide us with personal information about their preneed customers.
How We Disclose and Share Your Information
We will disclose the personal information we collect about funeral establishment clients to third parties including:
where the services we are providing to our funeral establishment clients require us to give your personal information to third parties;
where we are required or authorized by law to do so, for example to collect a debt or where a court issues a subpoena or order;
where a funeral establishment client has instructed us to disclose personal information to a third party for a designated purpose.
Where applicable, GFD may also transfer your personal information to our affiliates or a third party service provider hired to administer or provide products, services or information on our behalf. We take reasonable measures to ensure that your personal information that may be collected, used, disclosed or otherwise processed by these service providers on our behalf is protected and not used or disclosed for purposes other than as directed by us.
We may otherwise disclose personal information as necessary to meet legal, regulatory, insurance, audit and security requirements, with your consent, or as permitted or required by law.
Retention of Personal Information
We retain personal information for so long as is necessary to fulfill the purpose for which it was collected, for reasonable business record retention purposes, and to meet our legal and contractual obligations.
The only personal information which we collect about persons using our Website, www.gfd.org, is what that individual tells us about him or herself, for example, by completing an online form when requesting receipt of a GFD publication, or information provided to us through any “Contact Us” section or when sending us an e-mail.
As most Websites do, however, we do track usage patterns on our Website on an anonymous basis. Each time an individual visits our Website, our server records the Internet Service Provider, the date and time of the visit, the pages visited and the documents downloaded, the searches performed, and the referring URL’s the individual came from. We use this non-personal information to optimise our Website service.
For convenience, we may offer links from our Website to other Websites. However, GFD is not responsible for, nor do we accept any liability for, the personal information collection and use practices of other entities to which our Website may link. Individuals should consult the privacy policies of these other entities before providing any personal information on their Websites.
By providing personal information to GFD, we assume that you consent to the collection, use and disclosure of your personal information for the purposes as outlined in this privacy statement, if applicable, or otherwise at the time of collection. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. For example, in most cases, consent to the collection, use and disclosure of personal information by GFD may be implied by the fact that the client has engaged GFD to provide services and the collection, use and disclosure of personal information relates to the performance of those services by GFD. Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information or you may withdraw your consent to our further collection, use and disclosure of information about you by contacting the Privacy Officer. We will explain the consequences of the withdrawal of your consent. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services.
There are instances where GFD may collect, use or disclose your personal information without your consent where permitted or required by law, for example, to collect a debt you owe to us, to comply with a subpoena or court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to comply with the rules of court regarding the production of records.
GFD has implemented physical, organizational and technological measures to help to safeguard personal information from unauthorized access, loss or misuse.
You can generally visit the GFD Website without providing any personal information. However, given that electronically submitted data is not 100% secure, we make no warranties as to the security of any such personal information that you submit, which you do at your own risk.
Changes to this Statement
This privacy statement is effective as of January 1, 2004. GFD reserves the right to change this privacy statement at any time and we will take reasonable steps to advise affected individuals of any material changes if necessary. However, you should review this privacy statement from time to time to ensure that you are aware of and accept any changes made.
Contacting Us - Access, Correction, Inquiries and Complaints
If you wish to request access to, or correction of, your personal information in GFD’s custody or control, please make your request in writing to the Privacy Officer. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not be able to provide access to your personal information, for example if it contains the personal information of other persons, if it constitutes confidential commercial information, or if it is protected by solicitor-client privilege. If we deny your request for access to, or refuse a request to correct, your personal information, we will advise you of the reasons for this refusal.
For example, your continued consent to our collection, use and disclosure practices following notification of any material change and/or your continued access of our Website following the posting on the Website of any material changes to the privacy statement will signify your acceptance of, and agreement to be bound by, the terms of the modified privacy statement.
If you wish to withdraw consent or have any questions, requests or complaints about our personal information practices, please write to:
GFD of Canada
701 Evans Avenue, Suite 408
Toronto, Ontario M9C 1A3