Policies, Protocols, Disclaimers

Scrivens Insurance and Investment Solutions are in business to provide you with a broad variety of insurance and financial services. To meet your needs and serve you well, Scrivens Insurance and Investment Solutions needs to know about your personal information, the details of which can differ depending on the types of insurance and financial services you require.

You, as an individual, have a right to know how your broker collects, uses and discloses personal information. You have a right to expect that, to the best of our ability, your personal information held by us remains accurate, confidential and secure.

Scrivens Insurance and Investment Solutions is proud of their reputations in maintaining the confidentiality and security of personal information. We’ve provide the following information to explain how we protect the privacy of individual client’s personal information.

THE NEED FOR CONFIDENTIALITY

As professionals we are committed to holding our clients personal information in strict confidence, and we shall not disclose any such information unless authorized by our clients, required by law to do so or required to do so in conducting negotiations with underwriters or insurers on behalf of the client.

Except as outlined below, a record is kept each time personal information is disclosed, noting the nature of the disclosure, the date and the identity of the party to whom the disclosure was made. Individual records of disclosure are not maintained for regular or routine actions such as transfers of information to insurers, underwriters and claims adjusters.

A copy of the brokerage’s Privacy Declaration is available on request.

THE NEED FOR TRUST

Trust comes with confidence. The more you know about us, the more confident you can feel about dealing with Scrivens Insurance and Investment Solutions. Similarly, the more we know about you, the better we can serve you.

Scrivens Insurance and Investment Solutions collects and uses information about you for only the following purposes:

  • To understand your needs.
  • To analyze the suitability of our insurance and financial products or services for you.
  • To determine your eligibility for our products and services.
  • To set up, manage and offer products and services that meet your needs.
  • To provide you with ongoing service.
  • To meet our legal and regulatory requirements.
  • To facilitate the underwriting process and insurance claims.

Because it is important that we keep your trust, we will only ask for information which we need and when we ask you for information, we’ll let you know why we need it.

Subject to legal and contractual requirements, you can refuse to consent to our collection, use or disclosure of information about you, or withdraw your consent to our further collection, use or disclosure of information at any time by giving us reasonable notice.

If you refuse or withdraw your consent to the collection, use or disclosure of information about you, we may not be able to provide or continue to provide you with some products, services or information of value to you.

With your consent and where the laws allow, a broker may share your personal information (other than health information) with other brokers within the brokerage so that they may directly tell you about their products and services.

THE NEED FOR ACCURACY

While Scrivens Insurance and Investment Solutions tries to ensure that the information we hold about you is accurate, complete and up-to-date, it is in your obligation to inform your broker, promptly of a change of name, address or any other relevant information.

If you believe that personal factual information in your records may be inaccurate, we make it easy for you to access, verify and update it. If information has been provided to third parties, we will convey the corrected information to them, if necessary.

If we do not agree to change your personal information, you may challenge our decision. We will make a record of this challenge and, if necessary disclose the challenge to third parties who also possess the information.

THE NEED FOR ACCESS

To review the personal information, which Scrivens Insurance and Investment Solutions has about you, simply notify your account manager. Basic personal information can be verified on the spot, at no charge.

If you wish to review more extensive information, you’ll be asked to provide details regarding the nature of the information you wish to check.

The information will be obtained from our files and will normally be provided within 30 days of your request. There may be a charge for retrieving this information, in which case you will be notified in advance and may, if you like, withdraw your request. You may also challenge the reasonableness of the charge.

Sometimes we may not provide you with information about you that is within our control. This can occur if your right of access is constrained pursuant to the provisions of the Federal Personal Information Protection and Electronic Documents Act.

For example, we will not provide you with personal information in our control if:

It would reveal personal information about another party and your personal information cannot be separated.

The information is subject to solicitor/client or litigation privilege.

It contains the brokerage’s confidential commercial or proprietary information, or if it cannot be disclosed for legal reasons.

The information is used for the detection and prevention of criminal activity and dealings in the proceeds of crime.

If we deny your request for access to personal information, you will be told why, unless prohibited by law. You may challenge that decision.

Once you have the information, all you have to do is check it for accuracy and let us know if there are any corrections required. We will correct our records or make note of any differences. If information has been provided to third parties, we will convey the corrected information or the note of any differences to them, if necessary.

THE NEED FOR SECURITY

Every Scrivens employee, as a condition of employment, takes responsibility for protecting client privacy, confidentiality and security. This obligation remains in effect even after an employee leaves the Scrivens office.

Suppliers of services to the brokerage such as software vendors are required to sign contracts obligating them to protect the privacy and confidentiality of personal information provided to them to enable them to perform their function.

Appropriate controls are in place over computer systems and data processing procedures and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy policies.

The brokerage destroys or erases any personal information when it is no longer needed. When information is destroyed or erased, the brokerage takes care that there is no unauthorized access.

In short, our people are committed, and our systems are designed, to protect your privacy and confidentiality.

QUESTIONS OR CONCERNS

Questions or concerns about personal information held by the brokerage, or brokers compliance with the Brokerage Privacy Code, can be answered readily by the brokerage privacy officer who can be reached at (613) 236-9101, ext 214. However, should the privacy officer be unable to resolve your concerns you may contact the:

Federal Privacy Commissioner
112 Kent Street
Ottawa, Ontario K1A 1H3
Tel: 1-613-995-8210
Toll free: 1-800-282-1376

Broker Point of Sale Commission Protocol

This website is intended for use by residents of the Provinces of Ontario and Quebec. Address comments, questions and general inquiries to info@scrivens.ca There has been much talk over the past year about the profits recorded by Canada’s insurance companies. We’d like to take this opportunity to explain to you, our valued client, where we fit into the equation; in other words, what we do to purchase insurance products and services that are available, affordable, and understandable.

Simply put, our role is to provide you with the best insurance value, one that combines maximum coverage, excellent service and the lowest available price. In addition, we pride ourselves on providing personalized, quality service that includes professional insurance advice, ongoing policy maintenance and claims support. When any issue arises regarding your insurance coverage, we are your advocate, fully committed to using our professional experience to best represent your individual interest.

Brokerage compensation, the money we receive to select your best insurance value and to represent your interests, is included in your insurance premium. To illustrate how W.H. Scrivens & Sons Limited determines its level of compensation, we’ve listed a number of insurers that we represent. Included is the range of compensation we receive from each as a percentage of your overall premium.

Aviva Canada Inc.

  • Personal and Commercial Auto - 7.5% to 15%
  • Personal Property and Commercial Property/Boiler/Liability - 15% to 25%

AXA Insurance

  • Personal - 7.5% to 15%
  • Personal Property - 15% to 25%

Chubb Insurance Company*

  • Personal and Commercial Auto - 7.5% to 12.5%
  • Personal Property - 20%
  • Commercial Property/Boiler/Liability - 15% to 20%

Dominion of Canada General Insurance*

  • Personal and Commercial Auto - 7.5% to 12.5%
  • Personal Property and Commercial Property/Boiler/Liability - 20%

Ecclesiastical Insurance Company

  • Commercial Property/Boiler/Liability - 12.5% to 20%

Facility Association (Royal)

  • Personal and Commercial Auto - 7.5% to 10% Personal Property - 20%

Intact Insurance Company*

  • Personal and Commercial Auto - 7.5% to 12.5%
  • Personal Property - 20%
  • Commercial Property/Boiler/Liability - 15% to 20%

Jevco Insurance Company

  • Personal Auto - 5 to 10%

Perth Insurance Company

  • Personal and Commercial Auto - 7.5% to 17.5%
  • Personal Property and Commercial Property/Boiler/Liability - 15% to 25%

Royal & SunAlliance Insurance*

  • Personal and Commercial Auto - 7.5% to 12.5%
  • Personal Property - 20%
  • Commercial Property/Boiler/Liability - 15% to 20%

Travelers*

  • Personal and Commercial Auto - 7.5% to 12.5%
  • Personal Property and Commercial Property/Boiler/Liability - 20%

Western General Mutual Insurance

  • Personal Auto - 7.5% to 14% Personal Property - 20%

For us to maintain strong relationships with quality insurers, we work with each to provide the type of business they desire. The insurers with an asterisk (*) noted above recognize our efforts through a Contingent Commission contract. Payment of this Contingent Commission depends on a combination of growth, profitability (loss ratio), volume, retention, and increased services that we provide on behalf of the Insurer. Contingent Commission is not guaranteed. For detailed information on Contingent Commission, please go to the individual company’s website.

The Commission percentage is paid annually for both new business and renewals. Should there be an increase in the commission schedule we receive from your insurance, or any other material change that affects compensation arrangements, we will notify you, as we have in the past.

The Scrivens protocol provides customers with a formal process through which they can lodge complaints and have them reviewed and resolved.

Certain provinces have now formalized compliant handling protocols through their respective provincial legislation.

Notwithstanding any Protocol governing our actions, Scrivens and its employees will, at all times when dealing with a person who has a complaint, act with respect, courtesy, and will always respond in a professional manner. If you have any questions concerning the Scrivens compliant handling protocol, please do not hesitate to contact:

Peter Scrivens

Purpose of the Policy

The purpose of a complaint examination and dispute resolution policy is to set up a free and equitable procedure for dealing with complaints. It is also intended to provide oversight for the receipt of complaints, delivery of the acknowledgement of receipt, creation of the complaint file, transfer of this file to AMF and compilation of complaints for the purpose of preparing and filing reports twice a year to the AMF using the Complaint Reporting System (CRS).

Person in Charge

The person in charge of applying the policy, Peter Scrivens, acts as the respondent with the legislators and the complainant.

This person trains the firm’s staff and provides them with the necessary information for compliance with the policy.

The person in charge is also responsible for:

  • Delivering an acknowledgement of receipt and notice to the complainant;
  • Transferring the file to the AMF, at the complainant’s request;
  • Filing the necessary reports with the provincial legislature(s)

Responsibility of the Person in Charge of Managing the Complaint Handling Policy

The person responsible for managing the Complaint handling policy must respond to the legislative authorities when need be. The person responsible for managing the Complaint handling policy must maintain a register of complaints. The complaints need to be classified as per the categories of complaint set forth by the National Agency.

The person responsible for managing the Complaint handling policy must proceed to send an annual report to the National Agency within two months after the closing date of its fiscal year.

What is a Reportable Complaint

For the purposes of the policy, a complaint is the expression of at least one of the following three elements:

  • A reproach against the registrant;
  • The identification of real or potential harm that a client has sustained or may sustain; or
  • A request for remedial action.

Informal steps to correct a specific problem are not considered a complaint, provided the problem is resolved as part of the registrant’s normal activities and the consumer has not filed a complaint.

If all three elements are not included in the complaint letter, we must insist that the complainant modify the complaint letter and indicate the missing elements.

It is also necessary that all three elements be put in written form by the complainant in order to submit the complaint. The complainant can either send the complaint in a letter or by e-mail.

We offer support to a complainant that is unable to write. The content of the letter must afterwards be validated by the complainant by obtaining with a signature.

The Acknowledgement of Receipt and Notice

The person responsible for managing the Complaint handling policy must proceed to send a letter acknowledging receipt of the complaint and a notice to the complainant within 60 days of receiving all the information necessary for the examination.

After examining the complaint, the person in charge must send the complainant a final response with justifying reasons.

The acknowledgement of receipt must:

  • Give the name and coordinates of the person responsible for the Complaint handling policy
  • Give the delay for the receipt of a final position letter and give the delays for subsequent communications
  • Give the principal elements of the Complaint handling policy.

The Notice must:

  • Advise the complainant that if the complainant is dissatisfied with the complaint examination procedure or its outcome, the complainant may request the firm to forward a copy of the complaint file to the Agency. Advise the complainant that the complainant must wait until the complainant has received a final position letter or until the expiration of the delay to send a final position letter prior to referring this file to the appropriate agency.
  • Advise the complainant that the complainant has 1 year to ask that the file be transferred to the appropriate agency for a review following the expiration of the three month delay that the Firm has to send their final position letter.
  • Advise the complainant that the complainant can ask the appropriate agency to review the complaint and that the appropriate agency can, if it is so inclined, suggest mediation if both parties consent to it.
  • Mention that the statute of limitations before the civil courts are not interrupted because the complainant has asked for a review of the complaint by the appropriate agency

Content of the Complaint File

A complaint file must be maintained by the person responsible for managing the Complaint handling policy.

The complaint file should contain the following elements:

  • Reproach
  • Prejudice (potential or suffered)

Corrective Measure

The detailed analysis completed by the firm

A written and motivated response from the firm to the complainant

The complaint file will be transferred to the appropriate agency within a reasonable time frame.

Transfer of the File to the Appropriate Agency

If not satisfied with the outcome or with the examination of the complaint, the complainant may ask the registrant, at any time, to transfer the file to the appropriate agency.

The transferred file must include all the information related to the complaint.

The registrant is responsible for complying with the rules governing the protection of personal information.

Two Complaint Reports Per Year

Twice a year, the person in charge must use the CRS to file a report with the appropriate agency detailing the number and type of complaints received. The person in charge must do so regardless of whether any complaints were received.

The reporting periods are as follows:

  • No later than July 30, for data collected between January 1 and June 30
  • No later than January 30, for data collected between July 1 and December 31.

On May 25, 2007, the appropriate agency issued guidance intended for independent representatives and firms with only one representative. This guidance states that the appropriate agency no longer requires firms with only one representative or independent representatives governed by An Act respecting the distribution of financial products and services to file a report if they have not received any complaints. However, upon receipt of a complaint, they will still be required to report the complaint according to established procedures.

Effective and Amendment Dates

This policy is in effect immediately and was last amended on February 12, 2021.

For Questions Concerning the Examination of Complaints, Contact the Appropriate Agency

AMF Information Centre

Financial Services Regulatory Authority of Ontario

Scrivens Insurance and Investment Solutions, its affiliates and related companies take no responsibility for the accuracy or validity of any claims or statements contained in the information, or related graphics of this site. Further, Scrivens Insurance and Investment Solutions makes no representations whatsoever about the suitability of any of the information contained in the information or graphics on this site for any purpose. All such information and related graphics are provided without warranty of any kind. Scrivens Insurance and Investment Solutions makes no representations whatsoever about any other Website which you may access through this site. When you access a non-Scrivens Insurance and Investment Solutions website, you understand and acknowledge that it is independent from Scrivens Insurance and Investment Solutions, and that Scrivens Insurance and Investment Solutions has no control over the content on any such Website. In addition, a link to a non-Scrivens Insurance and Investment Solutions website does not mean that Scrivens Insurance and Investment Solutions endorses or accepts any responsibility for the content, or the use, of such Website. It is your responsibility to take precautions to ensure that whatever you select for your use by you is free of such items such as viruses, worms, trojan horses and other items of a destructive nature.

IN NO EVENT WILL Scrivens Insurance and Investment Solutions BE LIABLE FOR ANY DAMAGES WHATSOEVER, INCLUDING SPECIAL, INDIRECT OR CONSEQUENTIAL DAMAGES, ARISING OUT OF OR IN CONNECTION WITH THE USE OR PERFORMANCE OF THE INFORMATION AVAILABLE OR REFERRED TO ON THIS SITE.

Scrivens Insurance and Investment Solutions is committed to making our services accessible to everyone. We comply with the customer service standards of the Accessibility for Ontarians with Accessibility for Ontarians with Disabilities Act, 2005.

If you would like information about our compliance, have a comment or question; please contact us as shown below.

Providing Services to People with Disabilities

Assistive Devices

We serve all people with disabilities, including those who use assistive devices. We ensure that our staff are trained and familiar with various assistive devices that may be used by people with disabilities while accessing our services.

We also ensure that staff know how to use the assistive devices at their respective work locations which are applicable to their positions.

Communication

We communicate with people with disabilities in ways that take into account their disability. We train our staff who communicate with customers on how to interact and communicate with people with various types of disabilities.

Telephone Services

We provide fully accessible telephone service to all. We offer to communicate by email, fax or other methods if regular telephone communication is not suitable to someone’s communication needs.

Use of Service Animals

We welcome people with disabilities, including those who are accompanied by a service animal, on the parts of our premises that are open to the public.

Use of Support Persons

We welcome people with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.

Notice of Temporary Disruption

We give notice when our services are disrupted or our facilities closed in the event of a planned or unexpected disruption in the facilities or services usually used by people with disabilities. This notice includes information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available.

Depending on circumstances we post notice of temporary disruption using such methods as window or door signage and our website.

Training for Staff

Scrivens Insurance provides training to employees, including those who deal with the public and all those who are involved in customer service policies, practices and procedures. The training is in accordance with the Accessibility for Ontarians with Disabilities Act, 2005.

This training is provided to all staff that deals with the public or is involved in customer service policies, practices and procedures within three months of their start date.

Training Will Include

  • An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard.
  • Scrivens Insurance’s plan related to the customer service standard.
  • How to interact and communicate with people with various types of disabilities.
  • How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person.
  • How to use any equipment, devices or otherwise available on-site that may help with providing goods or services to people with disabilities.

Feedback Process

The goal of Scrivens Insurance and Investment Solutions is to meet and surpass expectations while serving people with disabilities. Comments on our services regarding how well those expectations are being met are welcome and appreciated.

Feedback regarding the way Scrivens Insurance provides services to people with disabilities can be made by e-mail, verbally and in writing.

All written feedback will be directed to the President:

Peter Scrivens, President

Once received, the feedback is redirected to the appropriate officer/manager/supervisor. In person feedback should be provided directly to the applicable manager/supervisor. We will acknowledge receipt of phone and email feedback within one business day (24 hours). An acknowledgement will be sent to fax and mailed feedback within 5 business days of receipt.

Modifications to this or other policies

Given our commitment to respecting the dignity and independence of people with disabilities, any policy of Scrivens Insurance and Investment Solutions that does not do this will be modified or removed.